Orthodox Union Web Site Privacy Policy – test

Last updated: September, 2020

Table of Contents

1. Introduction
2. Personal Data We Collect
3. How We Use your Personal Data
4. How We Share your Personal Data
5. Cookies and Other Passive Collection Technologies
6. Interest Based Advertising
7. Security
8. Data Retention
9. International Transfers of Personal Data
10. EU Controller
11. Our Legal Bases for Handling Your Personal Data
12. Your Rights and Choices
13. Links to Third Party Sites
14. Use of Third Party Services
15. Updates and Changes to Our Privacy Policy
16. How to Contact Us

1 INTRODUCTION

Your privacy is a priority for the Union of Orthodox Jewish Congregations of America (sometimes referred to as “OU,” “us,” “we,” or “our”), and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enable your identification (“Personal Data”). This Privacy Policy describes our practices with Personal Data that we (or our service providers) collect from an individual (sometimes referred to as “you” or “your”) through (i) our websites, applications, and our other network-connected products and services that link to this Privacy Policy (collectively, the “Site”), and (ii) through offline means, including by telephone, facsimile, postal mail, personal delivery, or other offline means.  In addition, we may provide you with additional information relating to our privacy practices in the context of particular services (such as on a form or invitation that requests Personal Data).

2 PERSONAL DATA THAT WE COLLECT

2.1 Generally

We respect your privacy and will not collect any Personal Data about you except as set forth in this Privacy Policy. You may freely visit our Sites anonymously and without being required to provide us with any Personal Data, and without being required to register. However, certain online and offline services, requests, activities, and features do require that you provide us with some Personal Data, including the following types of Personal Data:

• contact information, such as name, postal address, telephone number, and email address;
• parent information, such as name, postal address, telephone number, and email address;
• registration information;
• information about your participation in events or activities in which OU is involved;
• payment information, such as credit card numbers and expiration dates;
• photographs taken at OU events or activities or shared on social media by OU participants or partners;
• your mobile device information (e.g., device model, operating system version, device date and time, unique device identifiers, mobile network information);
• how you use our sites and mobile applications, search terms, pages you visit on our websites, and application performance;
• geolocation information;
• user content posted by you in forums, blog posts, comments, or message boards;
• records of your communications and transactions with us;
• information about religious practice and community participation;
• job application data, such as employment history, education and training, and work restrictions;
• when you register for an event or activity, we will ask for your name and contact information, and we may also ask for other information related to dietary restrictions, special facilities or equipment that you may require, health or medical information such as allergies and diagnosis, and emergency contact information;
• insurance information; and
• through your use of the Site, we may also gather certain information about your use of the Site that does not identify you directly but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Site. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you use the Site. We may collect information regarding user traffic patterns and Site usage. This Traffic Data does not, however, contain anything that can personally identify you, though it may identify your computer or device; it is used to analyze and improve the Site and to provide our users with a better experience. Please see the section below in this Policy regarding Passive Information Collection for more information about our use of cookies and other technologies.

If you choose not to provide information, we may not be able to provide you with requested services, programs, or other OU offerings.

We may combine Personal Data you submit to us with other information collected from you, whether online or offline. We treat the combined information as Personal Data in accordance with this Privacy Policy.

We may also collect or receive Personal Data from third-party sources, such as social media or other third-party integrations, your credit card issuing bank, our payment processing partners, and other third parties.

2.2  Data About Children

We do not knowingly collect Personal Data through the Site from children under the age of 13.  We reserve the right to delete any information identified as having been provided through the Site from children under the age of 13.

2.3 Sensitive Information

Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political affiliations or opinions, health information, or criminal background. In those cases where we may request or invite you to provide the foregoing information, we will only do so in accordance with all applicable data protection law requirements. Where you provide us with such information without being requested to do so by OU, we reserve the right (but do not have any obligation) to erase such information at our discretion.

2.4 Social Media

OU engages with its members and other individuals on multiple social media platforms. If you contact us on one of our social media platforms, request service via social media, or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this Privacy Policy, as well as the privacy policy of the social media platform you use.

3 HOW WE USE YOUR PERSONAL DATA

We use Personal Data submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Generally, we use the information you provide to use for the reason for which it was provided.  For example, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.  We may also use Personal Data from our about you as specifically described below:

• Requests, Inquiries, and Applications:  We may use your Personal Data to process, evaluate, and respond to your requests, inquires, and applications. So, if you request certain information from us, we will use your Personal Data to process and respond to your request.

• Manage Our Relationship With You: We may use your Personal Data to send you important information regarding our relationship with you or regarding the Site, such changes to our terms, conditions, policies, and other administrative information.

• To Use or Participate Our Services and Programs:  If you provide Personal Data in order to use or participate in our services and programs, to participate in an event or activity, or interact with some functionality available on the Site, we will use your Personal Data to facilitate such use or participation. For example, if you sign up to participate in an advocacy mission, we will use your Personal Data to register you for that activity and to facilitate your participation in that activity.

• Use of Photographs: We may use your Personal Data in the form of photographs or images taken during OU events, or otherwise taken in conjunction with other OU programs, services, or other offerings, whether by us, you, or other third parties. We share these photographs in newsletters, on our blogs, and on our social media pages so that our members and others can see what OU is up to.

• Contests, Sweepstakes, and Promotions:  We may use your Personal Data in order to administer contests, sweepstakes, and promotions that you sign up for. For example, we may use your Personal Data to notify you if you are the winner of a contest or promotion. If you win a contest, sweepstakes, or other promotion, we may request additional information (e.g., social security number for income tax purposes depending on the prize).

• Donation or Purchase Information:  When you donate online or offline, or register to purchase items from us, we collect your contact information and credit card number so that we can process your donation or order, notify you of order status, or provide a receipt. If you dedicate your donation or send a gift to a specific OU organization, we will also provide your information to that entity.

• Survey Information:  We occasionally conduct voluntary surveys. If you choose to participate in one of our surveys, we collect information related to you and your responses. We do not share Personal Data collected in these surveys with third parties (other than our service providers). We may share aggregate information with third parties to conduct analytics. The aggregate data cannot be used to identify individuals.

• Internal Business Purposes:  We may use your Personal Data for internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of our services and programs; to better understand those individuals that utilize our services and programs; to verify your identity; to prevent, protect against, identify, or address fraud, unauthorized activity, claims, liabilities, and other wrongdoing; to provide you with customer service; to obtain and maintain our funding; and to generally manage our business.

• Marketing:  We may use your Personal Data for marketing and advertising purposes, including determining appropriate advertising channels and venues to place ads, placing advertising on such channels and venues, measuring and managing the effectiveness of our advertising and marketing, conducting surveys, and performing market research and data analytics. To learn more about how we use Traffic Data for Interest Based Advertising, please see Sections 5 and 6 of this Privacy Policy.

• Employment:  If you provide Personal Data to apply for a job with OU, we may use the Personal Data you provide to evaluate your job application, consider you for that job or for similar jobs in the future, and contact you regarding possible employment.

• Legal Requirements, Industry Standards, and Contractual Obligations:  We may use your Personal Data for complying with and enforcing applicable legal requirements, industry standards, and our contractual obligations.

We may use non-personal information or aggregate information that does not identify an individual without restriction, and we may share such information with third parties.

4 How We SHARE Your Personal Data

We may share your Personal Data only as described in this Privacy Policy or as otherwise described to you at the point of collection.    

• Affiliates: We may share your Personal Data with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.

• Related Organizations, Partners, Grantees, and Co-Sponsors: We may share your Personal Data with other reputable nonprofit organizations that share a similar purpose or mission as OU, as well as our partners, grantees, or co-sponsors of our programs, activities, initiatives, and events from time to time. Although our treatment of your Personal Data is governed by this Policy, the treatment of your Personal Data by these third parties will be governed by the privacy policies of such third parties. While we endeavor to share your Personal Data only with partners, grantees, and co-sponsors that will respect your Personal Data, we do not control how these third parties use or disclose your Personal Data.

• Funding Organizations:  As a nonprofit, OU may receive funding from third parties, including from other nonprofits and government entities.  For example, we may share Personal Data in order to document for a funding agency that we have fulfilled our obligation under a grant.

• Agents, Consultants, and Service Providers:  We may share your Personal Data with individuals or companies that we hire to provide services to us, such as website hosting services and payment processors.

• Online Forums:  Certain features on the Site give you an opportunity to interact with us and others, including on message boards, chats, and creating community profiles on the Site. When you use these features, you should be aware that any information you submit, including your name, location and email address, are made available to others who have registered to participate in those online forums.  We do not have any control over how those other users may use and disclose the information that you share on the forums.  It is possible that they could make your information publicly available. We are not responsible for any information you choose to submit through these interactive features.

• Business Transfers:  We may transfer your Personal Data in the event of a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation, or reorganization. We may also disclose your Personal Data in the course of due diligence of such a transaction. You acknowledge and agree that any successor to or acquirer of OU (or its assets) will continue to have the right to use your Personal Data and other information. Whether the recipient of your Personal Data in these cases will handle your Personal Data pursuant to this Privacy Policy will depend on the applicable law and other factors.

• Legal Requirements:  We use and disclose Personal Data as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

• Passively Collected Information: We may share Traffic Data that does not identify you directly, but may identify your computer or device, as described in Sections 5 and 6 of this Policy.

5 COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES

As you navigate our Site, certain Traffic Data may be passively collected, meaning it is gathered without you actively providing it. This is done using the following techniques in the following ways:

• IP Addresses: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

• Through Your Browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.

• Through Your Device: If you access the Site through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Site.

• Using Monitoring Tools: The Site may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Site and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and response rates, and tracking the activities of users of the Site and e-mail recipients.

• Social Media Widgets: Our Site may include social media tools, including social media widgets or plug-ins, to connect you to your social media accounts. These features may set a cookie or use other automatic collection and tracking technologies to collect information about you and your use of the social media features through and in connection with our Site. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.

• Cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor.  We use third-party cookies set by our service provider, Google Analytics, to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site.  We do not use data collected by cookies to identify who you are.  We do not allow Google to use or share our analytics data.  You can visit https://www.google.com/analytics/learn/privacy.html to learn more about Google Analytics’ use of cookies. You can visit https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies.

Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.

6 INTEREST BASED ADVERTISING

6.1 We may collect Traffic Data about your online activities on our Site to provide you with advertising about products and services tailored to your individual interests. We also may obtain Traffic Data for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.

6.2 You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our ad partners’ targeted advertising services to show you our ads on other websites based on your prior visits to our Site and other online activity. The interest-based data collected about you is linked to your computer or device.  Our advertising partners may use the information that they receive to provide advertising services to the OU or to third parties using the same advertising network.    

1. Provided that a company participates in industry-developed programs designed to  provide consumers choices about whether to receive targeted advertising, you also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising).  To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices.  Opting-out does not mean that you will stop receiving ads from us. It means that you still stop receiving ads from us that have been targeted to you based on your visits and browsing activity across websites over time.

Do Not Track

Our Site currently does not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

7 SECURITY

We take what we believe to be reasonable steps to protect the Personal Data collected by us from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or Internet or e-mail transmission is ever fully secure, error-free, or “hacker proof.” Therefore, you should take special care in deciding what information you provide to us. Please keep this in mind when disclosing any Personal Data.

8 DATA RETENTION

We generally retain Personal Data for so long as it may be relevant to the purposes above, or for longer when required by law. To dispose of Personal Data, we may anonymize it, delete it, or take other appropriate steps. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

9 INTERNATIONAL TRANSFERS OF PERSONAL DATA

OU is based in the United States. The recipients of the Personal Data disclosures described in the “How We Share Your Personal Data” Section above may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate. Whenever we transfer personal data outside of the European Economic Area (“EEA”) or the UK, we take legally required steps to make sure that the appropriate safeguards are in place to protect your Personal Data.

10 EU CONTROLLER

European Union data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

OU may act as either a data controller or data processor in connection with your Personal Data, depending on the circumstances. However, under applicable law, OU is considered the “data controller” of the Personal Data we handle under this Privacy Policy. OU’s contact information appears at the end of this Privacy Policy.

11 OUR LEGAL BASES FOR HANDLING YOUR PERSONAL DATA

The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Data.  To the extent those laws apply, our lawful bases for processing your Personal Data are:

• To Honor Our Contractual Commitments to You: In some cases, we process Personal Data to meet our obligations to you, or to take steps at your request, in anticipation of entering into such a contract with you, or as is otherwise necessary for our contractual relationship.

• Consent: Where required by law, and in some other cases, we process Personal Data on the basis of your consent. This may be implied consent where permitted by law, and it will be explicit consent where required by law.

• Legitimate Interests: In many cases, we process Personal Data on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

• • customer service;
  • marketing;
  • protecting our customers, community, users, personnel, and property;
  • analyzing and improving our business;
  • processing job applications; and
  • managing legal issues.

We may also process Personal Data for the same legitimate interests of our customers, business partners, and related organizations.

• Legal Compliance: We need to process, use, and disclose Personal Data in certain ways to comply with our legal obligations.

• To Protect the Vital Interests of the Individual or Others: For example, we may collect or share Personal Data to help resolve an urgent medical situation.

12 YOUR RIGHTS AND CHOICES

12.1 Opt Out From Direct Electronic Communications

Where it is in accordance with your preferences, OU may send you direct electronic communications, such as through email or text message, regarding donation opportunities or events or programs that might be of interest to you. You may “opt out” of receiving these electronic communications by clicking on the opt-out link within the e-mail you receive, or by sending an e-mail to ouinternet@ou.org indicating which communications you no longer wish to receive. Please note that if you opt out of receiving promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to logistical information for an event for which you are registered or regarding changes to this Policy).

12.2 Opt Out From Cookie-Related Processing and Interest Based Advertising

You can opt out from certain cookie-related processing and interest-based advertising as described in Sections 5 and 6 of this Policy.

12.3 How You Can Access, Update, Correct, or Delete Your Personal Data

If you would like to submit a data access, correction, restriction, or deletion request, you can do so by contacting us at ouinternet@ou.org and we will process such request with respect to any Personal Data that we are able to link to you individually based on the information that you can provide to us.  These rights and options that you have with respect to Personal Data are subject to limitations and exceptions under applicable law.  In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority.  However, we encourage you to contact us first at ouinternet@ou.org and we will try to resolve your concerns.

12.4 Notice to California Residents

Subject to certain limits under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with: (1) a list of certain categories of Personal Data that we have disclosed to certain types of third parties for their direct marketing purposes during the immediately preceding calendar year; and (2) the identity of the third parties that received certain Personal Data from us for their direct marketing purposes during that calendar year. To do so, please contact use at ouinternet@ou.org.

13 LINKS TO THIRD PARTY SITES

The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. OU is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. OU does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

14 USE OF THIRD PARTY SERVICES

If you access this Site or any of OU’s services through a third party platform, product, service, or application (“Third Party Services”), the protection of your privacy by the Third Party Service provider is governed by the Privacy Policy of that Third Party. Your use of any Third Party Services is subject to that Third Party’s own rules, policies, and practices, and not those of OU. These Third Parties have separate and independent rules and privacy policies, and therefore OU has no responsibility or liability for the Services, privacy policies, or business practices employed by any Third Party that OU does not own, control, manage, or employ, and expressly disclaims any liability related to the use of such Third Party Services. Please take the time to read and review the privacy policy of any such Third Party, as it is solely your obligation to review and understand the privacy practices and policies of these Third Parties.

15 UPDATES AND CHANGES TO OUR PRIVACY POLICY

The business and operations of OU may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy to reflect changes in the law, our data handling practices, or the features of our services, websites, and apps. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time.  Modifications to this Privacy Policy will be posted at www.ou.org with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances, OU may, but need not, provide you with additional notice of such modifications, such as via e-mail. Modifications will be effective 30 days following the “Updated” date, or such other date as communicated in any other notice to you. Where required by applicable law, we will apply changes only with your consent.

Please review this Privacy Policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued participation in our programs, services, and events following the effectiveness of any modifications to this Privacy Policy constitutes your acceptance of those modifications. If any modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise utilizing OU’s website, as well as its programs, services, and events.

16 HOW TO CONTACT US

If you have any questions regarding this Policy or the use of your Personal Data under this Policy, you can contact us at:

Orthodox Union
11 Broadway
New York, NY 10004
ouinternet@ou.org