Effective July 20, 2021
The Services are owned and operated by NCH and its affiliates.
INFORMATION WE COLLECT
“Personal Information” means information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as name and e-mail address; (2) demographic data (such as location or country of residence); (3) payment data such as card number and related information such as expiration date and any required codes; (4) certain Usage Data (defined below) such as IP address and (5) User-generated content.
“Usage Information” or “Usage Data” is information about an individual’s online activity that, by itself, does not identify the individual, such as browser type, operating system, searches conducted, and webpages visited.
Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data may be linked together. Different types of Usage Information also may be linked together and, once linked, may identify an individual person. Also, some Usage Data may be Personal Information under applicable law.
SENSITIVE PERSONAL INFORMATION
Certain Personal Information (e.g., social security numbers, financial information, information related to racial or ethnic origin, political opinions, religion or other beliefs, information about personal health, biometrics or genetic characteristics, criminal background, or trade union membership) is characterized as sensitive and subject to stricter regulation than other Personal Information.
HOW WE COLLECT INFORMATION
We collect information about you in the following ways:
From You. We collect information from you when you:
- Use the Services. You can access many of our Services without submitting any Personal Information to us. However, if you wish to access additional content or participate in some of our activities, we may ask that you provide Personal Information. For example, we collect Personal Information from you when you: email us; use the site’s “Contact Us” feature to contact us for help or information; complete and submit a form, petition, registration, survey, or poll on or through our site; or otherwise voluntarily provide any of your Personal Information to us through the Site or otherwise by or through the Services.
- Supply Your e-mail Address. When you sign up on or through our Services, join our mailing list, take an advocacy action, share your story, or complete some other data form, you will be asked to supply your email address. NCH does not sell or rent your email address to any third party. Email addresses gathered from subscribers to NCH are only available to employees managing this information for purposes of contacting you or sending you emails based on your request for information, and to contracted service providers and vendors for purposes of providing services relating to our communications with you. NCH will only use your email address to send information about NCH (such as news and events, special programs, and fundraising). From time to time, we may send out email messages that might include information about like-missioned organizations and companies, but we do not provide them with access to any Personal Information that you have provided. NCH complies with those provisions of the CAN-SPAM Act applicable to charitable organizations. All email messages contain a link to unsubscribe from NCH email. You may subscribe or unsubscribe to NCH at any time by contacting us at email@example.com or sending a notice by United States mail to our address provided at the end of this policy.
- Include Personal Information in User Content. Some parts of our Services may allow users to post or transmit messages, comments, screen names, computer files, and/or other materials. If you choose to make Personal Information public through the Services, NCH will consider that information public. We will collect the information and content that you post or transmit through the Services, such as when you or post any information, comments, or messages to any chat groups, bulletin boards, forums, blogs, or other facilities that may exist on the Site or as part of the Services.
From our business partners and service providers. Third parties that assist us with our business operations also collect information (including Personal Information and Usage Data) about you through the Services and share it with us. For example, our third-party payment processor collects and shares information with us in connection with charitable donations to NCH through the Services.
Usage Data. We also automatically collect Usage Data when you interact with the Services, including, among other things, your IP address, browser type, mobile device type, content visited while on our website and the duration of your visit to the Site.
WEB BROWSER COOKIES
Our Site may use “cookies” to enhance User experience. “Cookies” are small computer files sent to or accessed from your web browser or your computer’s or tablet’s hard drive that contain information about your computer, such as a user ID, user settings, browsing history, and activities conducted while using the Services. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your interaction with the Services. A Cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the Cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.
Cookies help us improve the Services by customizing users’ experience with the Services; enabling us to analyze technical and navigational information about the Services; and helping to detect and prevent fraud.
We also use other Cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “Data Collection Tools,” to help improve your experience with the Services. For example, Data Collection Tools help us make the Services more relevant to users. The Services also may use Data Collection Tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used, and the country and time zone in which the computer or device is located.
We use essential Cookies to help make the Site and other web applications usable by enabling basic functions like session management. Certain Cookies may also help us comply with legal requirements (e.g., the European Union’s General Data Protection Regulation). The Site may not function properly without these Cookies. Many of the essential Cookies we use are transient. A transient Cookie expires when you close your browser. We use analytics Cookies that collect information about how visitors interact with and use the Site. This information enables us to improve how the Site works generally. We use functional Cookies to remember the choices you make and provide enhanced features such as support that may be of particular interest to you. These Cookies allow us to personalize your return visits and to save you time during certain activities.
Control of Cookies
You do not have to accept our Cookies and can block them by activating the setting on your browser. Most web browsers have settings allowing a user to reject Cookies or to alert a user when a Cookie is placed on the user’s computer, tablet, or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept Cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org.
HOW WE USE YOUR INFORMATION
We may use the information we collect for any of the following business, commercial, or charitable purposes:
- to provide the Services to you;
- to operate, improve, and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
- for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of the Services;
- to communicate with users using email or text message;
- to better understand how Users access and use the Services, for the purposes of trying to improve the Services, and to respond to User preferences, including language and location customization, personalized help and instructions, or other responses to Users’ usage of the Services;
- to help us develop our new products and services and improve our existing products and Services;
- to provide Users with advertising and direct marketing that is more relevant to you; and
- to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services.
Please note that, in order to provide you with a better experience and to improve the Services, information collected through the Services may, subject to user privacy controls (if available), be used in an aggregated or individualized manner.
HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell, trade, or rent User Personal Information to others. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
We may share and disclose information as described at the times information is collected or as follows:
When you consent. We may share Personal Information with third parties if you have given us your consent to do so. Your Personal Information may be disclosed:
- By you, on message boards, chat, profile pages, blogs, and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to users of the Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site.
Internal Operations and Affiliates. Your Personal Information may be shared within NCH and among its program affiliates, which is defined for this purpose as corporate affiliates of NCH with your consent.
In aggregated form. We may share Personal Information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our services.
For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.
INFORMATION RETENTION AND DISPOSAL
We retain information as long as it is necessary and relevant for our operations. We also retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.
HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. However, the security of information transmitted through the internet can never be guaranteed.
We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any form of authentication involved in obtaining access to secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
If you have reason to believe your interaction with us is no longer secure, please notify us immediately at firstname.lastname@example.org.
You are able to access and review the Personal Information we have about you, make corrections to it, and/or request that we delete it. You contact us to correct the information we have about you and make additional requests by contacting us at email@example.com. Our team will review your request and respond to you as quickly as possible.
THIRD PARTY WEBSITES
Users may find advertising and other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties with which we have no affiliation. A link to any third-party site does not mean that we endorse it, or the quality or accuracy of information presented on it. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.
INFORMATION FROM CHILDREN
Consistent with the requirements of the Children’s Online Privacy Protection Act (“COPPA”), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and, subsequently, we will delete that information.
We will not transfer Personal Data (defined below) relating to individuals within the European Economic Area (“EEA”) to third parties (i.e., those outside of NCH’s group of affiliates and service providers) located outside of the EEA without ensuring adequate protection under the applicable European law. Where a third party is located in a country not recognized by the European Commission as ensuring an adequate level of protection, we (or our affiliates or service providers) will take appropriate steps, such as implementing standard contractual clauses recognized by the European Commission, to safeguard your Personal Data.
NCH is headquartered in the United States and the Services are hosted in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States or to another country in which we (or our affiliates or service providers) operate. Any Personal Information collected through the Services about visitors located outside of the United States is processed in the United States by us or by a party acting on our behalf.
WHEN YOU PROVIDE PERSONAL INFORMATION TO US THROUGH THE SERVICES, YOU CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES.
The European Union’s General Data Protection Regulation (“GDPR”) and other privacy laws protect Personal Data (defined below) collected from citizens of European Union Member States. The GDPR is a comprehensive data protection law that strengthened the protection of Personal Data in light of rapid technological developments, the increasingly global nature of business, and more complex international flows of Personal Data. The GDPR replaces a patchwork of national data protection laws with a single set of rules, directly enforceable in each European Union Member State.
If the GDPR applies to you, then you may request information about:
- The general purpose of the Personal Data processing;
- The categories of Personal Data concerned;
- Who else outside NCH may have received Personal Data from NCH;
- What the source of the Personal Data was (if you did not provide it directly to NCH;
- How long the Personal Data will be stored.
NCH will store your Personal Data for as long as necessary to fulfill the purpose for which the Personal Data was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use of disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve these purposes through other means, and the applicable legal requirements. Upon expiration of this time frame, NCH will securely erase and destroy all of your collected Personal Data, in accordance with applicable laws and regulations.
The term “Personal Data” includes any information relating to an identified or identifiable natural person, so called “data subjects” (e.g., information such as your name, address, email address, telephone number, IP address, credit card information, identification number, website Cookies, occupation and location).
Personal Data does not include data from which you can no longer be identified due to encryption or anonymity. In some circumstances, NCH may completely anonymize your Personal Data so that it is no longer attributable to you. In this case, the information will no longer be considered Personal Data for GDPR purposes.
Rights to your Personal Data under the GDPR
If the GDPR applies to you, then you have particular rights as an individual under this regulation, including the right to:
- Request access to your Personal Data stored by NCH and request certain information in relation to its processing;
- Request a change and/or update be made to your Personal Data stored by NCH;
- Request restriction of processing of your Personal Data;
- Request erasure of your Personal Data stored by NCH; and
- Object to the processing of your Personal Data.
Reasonable access to your personal data will be provided at no cost to you upon request made to NCH at firstname.lastname@example.org. If access cannot be provided within a reasonable time frame, NCH will provide you with a date when the information will be provided. If for some reason access is denied, NCH will provide an explanation as to why access has been denied.
Withdrawal of Consent
NCH acknowledges that even though you may initially consent to the processing of your Personal Data, you may want to withdraw your consent from time to time. You may withdraw your consent from the processing of Personal Data either entirely or in part. To withdraw your consent, please contact us at email@example.com.
Questions or Concerns
If you have any questions or concerns regarding the rights established under the GDPR, please contact us at firstname.lastname@example.org.
CALIFORNIA CONSUMER PRIVACY RIGHTS
If you are a California resident, you may have the rights described below with respect to the Personal Information we have collected about you as a user of the Services.
Right to Know and Right to Request Information
Under the CCPA, California residents have certain rights regarding their Personal Information, including:
- The right to know the categories of Personal Information that we have collected and the categories of sources from which we got the information;
- The right to know the business purposes for sharing Personal Information;
- The right to know the categories of third parties with whom we have shared Personal Information;
- The right to access the specific pieces of Personal Information we have collected and the right to delete your information;
- The right to not be discriminated against if they choose to exercise their privacy rights;
- Notice at collection of categories of Personal Information collected under the CCPA.
To review, request access to, or exercise your rights under the CCPA, please contact us at email@example.com.
Right to Request Deletion
You have the right to request that we delete your Personal Information. “Deleting” Personal Information is defined by:
- Permanently and completely erasing the Personal Information on existing systems with the exception of archived or back-up systems;
- De-identifying the Personal Information; or
- Aggregating the Personal Information.
If Personal Information is stored, archived, or listed in a backup system, we reserve the right to delay compliance with the consumer’s request to delete, with respect to data stored on the archived or backup system, until the archived or backup system is next accessed or used. We will inform the person(s) of this in the event is it applicable to their request.
We must maintain a record of the individual requesting deletion pursuant to the Civil Code section 1798. 105(d).
NCH is not required to comply with a consumer’s request to delete the consumer’s Personal Information if it is necessary for us or a service provider to maintain the consumer’s Personal Information in order to:
- Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of an organization’s ongoing business relationship with the consumer, or otherwise perform a contract between the organization and the consumer;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the organization;
- Comply with a legal obligation;
- Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
To submit a request to delete your Personal Information and exercise your rights under the CCPA, please contact us at firstname.lastname@example.org.
Right to Opt-out
Right to Non-Discrimination
Submitting a Data Subject or California Consumer Request
All requests received will be reviewed and verified prior to the request being processed by our privacy team. You may designate an authorized agent to make a request to know or a request to delete your Personal Information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly. We will deny any requests from agents that do not submit proof of authorization. To submit your questions and inquiries related to your rights, please contact us at email@example.com.
THIRD PARTY PAYMENT SERVICE
We will use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy statement, rather than this Privacy Statement. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
YOUR ACCEPTANCE OF THESE TERMS
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed as your acceptance of those changes.
Personally identifiable information
We may collect personally identifiable information from Users in a variety of ways, including, but not limited to, when Users visit our site, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number. Users may, however, visit our Site anonymously. We will collect personally identifiable information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identifiable information, except that it may prevent them from engaging in certain Site related activities.
Non-personally identifiable information
We may collect non-personally identifiable information about Users whenever they interact with our Site. Non-personally identifiable information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
How we use collected information
NCH may collect and use User personal information for the following purposes:
· To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently.
· To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
· To improve our Site
We may use feedback you provide to improve our products and services.
· To send periodic emails
We may use an email address to respond to User inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include news, updates, related product or service information, etc.
· To provide targeted services and content
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sharing your personal information
We do not sell, trade, or rent User personally identifiable information to others. We may share generic aggregated demographic information not linked to any personally identifiable information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed as your acceptance of those changes.