User Data Privacy & Protection Policy | May 2018
1. Types of Information Collected
In order to better advance our mission and engage in our work, we may collect two types of information about our constituents and community: Personally Identifiable Information and Nonpersonally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our site, taking advantage of our programs and grants, and keeping abreast of developments in our community.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this site, such as applying for making a donation, applying for a grant or fellowship, registering for a conference, forum, or event, inquiring about our grants or programs, or sending us feedback, we may ask you to provide certain information about yourself. It is completely optional for you to engage in these activities. However, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, employer, job title, telephone numbers, academic and professional qualifications, transcripts, CVs, and other personal identifying information. When registering for a conference, forum or event, or when you offer us a donation, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
Nonpersonally Identifiable Information: This refers to information that does not by itself identify a specific individual. In order to understand who is interfacing with our online activities and services,
we may in some situations gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
2. Collection Methods, Use of Information, and Length of Retention
We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you: (a) make a donation; (b) apply for a grant or fellowship; (c) register to attend a conference or event; (d) send email messages, submit forms, or transmit other information through the website; or (e) submit your credit card or other payment information when registering for a conference or event through our site. We may also collect information from you at other points on our site that state that such information is being collected.
In addition, we or our third party analytics providers may collect certain Nonpersonally Identifiable Information. This information is ultimately stored in the form of categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our site and to gather demographic information.
We will primarily use your Personally Identifiable Information to provide our services to you. We will also use Personally Identifiable Information to enhance the operation of our site; process your donation, grant or fellowship application, or conference or event registration; respond to your questions or inquiries; send periodic communications to you about our services and activities; improve our marketing and promotional efforts; statistically analyze site use; improve our offerings; and customize our site’s content, layout, and services. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems, and enforce our agreements with you.
We keep your Personally Identifiable Information for as long as we need it to fulfill the purposes for which we have collected it and for a reasonable period afterward.
3. Release of Information
We do not sell, trade, or rent your Personally Identifiable Information to others. We do provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties. We and our service partners use your Personally Identifiable Information to operate our sites and to deliver our services. For example, we must release your credit card information to the card-issuing bank to confirm payment; correspond with your institution if you receive a grant or fellowship; provide your name and contact information to the hotel or conference center hosing our conference; and provide other information to third parties that help us provide our services. The use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.
Occasionally, we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
4. Data Protection Laws
You may have rights under European and other laws to have access to your Personally Identifiable Information and to ask us to rectify, erase and restrict use of, your Personally Identifiable Information. You may also have rights to object to your Personally Identifiable Information being used, to ask for the transfer of Personally Identifiable Information you have made available to us and to withdraw consent to the use of your Personally Identifiable Information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. If you are located in the European Union, you have the following rights under European laws, and may have similar rights under the laws of other countries:
- Right of subject access: The right to make a written request for details of your Personally Identifiable Information and a copy of that Personally Identifiable Information.
- Right to rectification: The right to have inaccurate information about you corrected or removed.
- Right to erasure ('right to be forgotten'): The right to have certain Personally Identifiable Information about you erased.
- Right to restriction of processing: The right to request that your Personally Identifiable Information is only used for restricted purposes.
- Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by changing your account information.
- Right to object: The right to object to processing of your Personally Identifiable Information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.
- Right to data portability: The right to ask for the Personally Identifiable Information you have made available to us to be transferred to you or a third party in machine-readable format.
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your Personally Identifiable Information. If you withdraw your consent, this will not affect the lawfulness of our use of your Personally Identifiable Information prior to the withdrawal of your consent.
- Right to notice of automated decision-making: The right to be informed of the existence of any automated decision-making, including profiling, that involves your Personally Identifiable Information and, in some cases, meaningful information about the logic involved, and the significance and the envisaged consequences of such processing for the data subject.
These rights are not absolute and they do not always apply in all cases.
In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
In order to exercise your rights please contact us by sending an email message to: privacy@FoundationIFS.org. In addition to contacting us, you have the right to lodge a complaint with a supervisory authority.
5. Legal Bases for Processing (for EEA users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable European Union laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the site, including to operate the site and to protect the safety and security of the site.
- It is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development.
- You give us consent to do so for a specific purpose.
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services you receive from us.
The hosting facilities for the site are situated in the United States. We work with third-party providers that may be based in other countries or have facilities in other countries. The information you provide us will be transferred outside of the EEA to countries that do not adequately protect your data and that may not have equivalent privacy and data protection laws to the country in which you reside. The possible risks of transferring your data outside of the EEA include financial loss, identity theft, and being unable to exercise the rights you would usually have under data protection laws against the organizations or individuals who receive and have access to your data in those jurisdictions. You consent to this transfer of your data by providing it to us. You have the right to revoke your consent at any time.
6. User Choices on Collection and Use of Information
We may, from time to time, send you email regarding our activities, events, products, and services.
In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our organizations with which we work, we may occasionally send you direct mail or email about products and services that we feel may be of interest to you. If you do not want to receive such mailings, simply tell us when you give us your personal information or contact us at any time to indicate that you no longer desire receive such offers and mailings.
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our site may not work properly in your case.
7. Security of Information
At our site, you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our user is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to via password. We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us. Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password.
In order to most efficiently serve you, credit card transactions are handled by established third party banking, processing agents, and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
When you use our site, we will store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and other information to recognize you as a previous visitor to the site. The cookies make your use of the site easier, make the site run more smoothly, and help us to maintain a secure site. You are always free to decline our cookies if your browser permits, but some parts of our site may not work properly in that case.
9. Privacy Policies of Third Party Sites
10. Miscellaneous Privacy Issues
You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use, or disclose Personally Identifiable Information about visitors that are under 18 years of age.
You should also be aware that when Personally Identifiable Information is voluntarily disclosed
(i.e., your name, email address, etc.) on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to public areas on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your information to be viewed by third parties, you are advised not to make any submissions.
Please be careful and responsible whenever you are online. Thank you for engaging with the Foundation for Self Leadership.