Privacy policy.

Updated as of Jan 23, 2023

 

Scope of This Policy

The purpose of this Privacy Policy (this “Policy”) is to explain the privacy practices of Free The Girls and its affiliates and designees (“we” or “us”) in connection with the following digital services (collectively, the “Digital Services”): (i) this website (www.freethegirls.org) (the “Website”); (ii) any communications or materials made available by us for use on or through computers, mobile devices, or offline (the “Resources”); and (iii) any other digital communications or content that we may publish that link to this Policy, including advertisements that we may place on third-party websites such as social media pages (e.g., Facebook, Instagram, Twitter).  

Your Consent

Please take a few minutes to review this Policy before using this Website or our Digital Services. By accessing or using the Digital Services, you are agreeing to this Policy. If you do not agree with this Policy, please do not access or use the Digital Services or provide us with any of your Personal Information (defined below).

This Policy is Part of Our Terms of Use

Please also visit our Terms & Conditions, which will govern the terms that will apply to your use of the Digital Services, including if you wish to enforce any of your rights – freethegirls.org/termsconditions . By accessing or using the Website or Digital Services, you are also agreeing to our Terms & Conditions.

Third-Party Practices

Please remember that this Policy only governs our own practices. If you are interacting with any website, application, or other digital service managed by any third parties, their own privacy policies will govern, even if you access that website, application, or service through our Digital Services, or through software, applications, APIs, or widgets that are integrated with our Digital Services. We are not responsible or liable for any actions of those third-parties or their data protection practices. Please review the privacy policies of those third parties to understand how your Personal Information may be collected and/or processed by those third parties.

Types of Information We Collect and Use

Our Digital Services may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a particular consumer or device (“Personal Information”), such as:

·       Identity Data includes your name, date of birth, gender, unique personal identifiers or numbers, signature, physical characteristics or description, employment, or other similar information.

·       Contact Data includes billing address, mailing address, email address, and telephone numbers.

·       Transaction Data includes details about types and amounts of donations and credit card information, bank account numbers, credit card numbers, debit card numbers, or any other financial information. We do not disclose credit card account information provided by donors, except for the proper processing of donations.

·       Technical Data is information about your equipment, browsing actions, and patterns, including includes internet protocol (IP) addresses, your browser type and version, time zone setting and location, geolocation, cookies, carrier information, browser plug-in types and versions, operating system and platform, sensory data (e.g., audio, electronic, visual, or similar information), or other technology on the devices you use to access the Digital Services.

·       Usage Data includes information about how you use the Digital Services, such as the session duration, pages served, the source of the request, and the preceding page views. We also collect data about events attended.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, and the materials that you have viewed and interacted with.

We also collect, use, and share “Aggregated Data” such as statistical or demographic data. Aggregated Data could be derived from your Personal Information but is not considered Personal Information as this data will not directly or indirectly reveal your identity. We may collect, retain, use, and share Aggregate Data in any manner without restriction. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

We do not collect any special categories of personal information about you, including any details about your race or ethnicity, citizenship, medical condition(s), physical or mental disability, marital status, religious or philosophical beliefs, veteran or military status, sexual orientation, political opinions, criminal history, information about your health, and/or genetic and biometric data.

How do we Collect Personal Information?

Information You Manually Provide. We collect the information you manually provide (using your keyboard, mouse, or touchpad) when you use our Digital Services; when you contact us by phone, mail, email, or in person; when you register for an event or donation drive; or when you make a contribution, either on our website, at an event or donation drive, over the phone, or by mailing a check. For example, we collect the information you provide when you subscribe to our newsletter, make a donation, sign up to host a bra drive or become a bra drop-off location, ask us a question, respond to a survey or leave us feedback, or otherwise interact with this Website or our Digital Services.

Information From Third-Party Social Media Platforms. You may be able to register with, log on to, or enhance your user experience on this Website by choosing to automatically populate the requested data fields with information you previously provided to a third-party social media platform (such as Facebook, Instagram, or Twitter). By doing this, you are asking the third-party platform to send us information, including Personal Information, from your profile on that platform. 

Information From Other Third-Party Sources. In addition to the Personal Information that we collect directly from through your use of the Digital Services, we may have access to other Personal Information from third parties, depending on the privacy policies of those third parties and the information you have authorized them to share with us. For example, we may obtain Personal Information from digital service and software management providers, research and analytic companies, marketing partners, public databases, payment processors, mobile carriers, third-party login authentication services, and similar third-party sources. We may also receive your Personal Information from other sources, such as people that you are in some way connected with, or our own affiliates and representatives. 

Information From Your Browser or Device. We collect information that is sent to us automatically by your web browser or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. An IP address is a number that is automatically assigned to your computer whenever you access the Internet. When you request pages from any Digital Services, we automatically log your IP address. The information we receive from your web browser and device is not, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.

Information Collected by Cookies and Similar Automatic Tracking Technologies. The Digital Services may use cookies, flash cookies, web beacons, embedded scripts, location-identifying technology, or similar technology to collect Personal Information automatically as you use the Digital Services. These technologies also allow us to collect or interact with Personal Information stored on your device or browser and monitor your usage of the Digital Services. We may also engage third-party companies to help us collect and track this data (e.g., Google Analytics). You may be able to deactivate or opt out of some of these technologies through your browser settings, device settings, or by taking other steps, depending on the methods you use to access the Digital Service. For more information, please click here to read the Network of Advertising Initiative’s Recommendations for Opting Out of Internet Advertisements. Please note that disabling cookies or deleting information contained in cookies or flash cookies may interfere with the performance and features of the Digital Services, including not being able to store your preferences or any login information. (Your browser settings may also allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com).

Information Collected by our Volunteers. Our volunteers may collect Personal Information through your use of the Digital Services or our programming, including but not limited to, attending, or donating to bra drives, hosting bra drives, or becoming a bra drop-off location. Volunteers are required to transmit your Personal Information to us.

Information Collected from Location-based Tracking Technologies. When you visit our Website, or use any Digital Services, we may collect information about your location using technologies like GPS, Wi-Fi, Bluetooth, or cellular tower proximity. This type of information may be used to locate your proximity to nearby bra drop-off locations, or to identify other location-specific items or events that may be of interest to you.

Credit Cards

In order to process transactions through the Digital Services, you will need to give us certain personal information (name, email address, telephone number, address(es), credit card type, number, expiration, and CVV2 value). We may store your contact information in an order entry system. We do not store your credit card details. In fact, your credit card information never passes through our site—it is captured directly by our designated third-party payment gateway. Anyone involved with the processing, transmission, or storage of card data must comply with the Payment Card Industry Data Security Standards (PCI DSS).

How is the Personal Information that We Collect Used?

We use Personal Information in a variety of ways, including:

  • to establish a relationship and communicate with you about Free The Girls’ programming, events, funding, and needs;

  • to learn about our donors and what matters to you;

  • to handle, respond to, or otherwise provide information and services you request;

  • for security, credit, or fraud prevention purposes;

  • to detect security incidents; prevent possibly fraudulent, illegal or harmful activities; and to otherwise enforce our Terms & Conditions and other policies;

  • to process donations and event registrations and issue tax receipts;

  • to contact you with information and notices related to your donations or use of our Digital Services;

  • to invite you to participate in surveys and provide feedback to us in accordance with any privacy preferences you have expressed to us;

  • to fill contractual obligations to and with third parties, including for compliance with all laws and regulations, including reporting requirements;

  • to improve the content, functionality, and usability of our Digital Services;

  • to improve our products and services;

  • to analyze giving patterns; and

  • for any other purpose identified in an applicable privacy notice or other agreement between you and us.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Communications. We will from time to time communicate with you, including by email, telephone, text message, and mail, concerning the organization’s charitable activities, events, and requests for support. We will not call or email you or send mailings to you on behalf of other organizations. To opt out of receiving these communications, you may contact us as described in the “Contact Us” section below, or by clicking the “unsubscribe” link in any email communications.

Confidentiality. All information about any financial or non-financial transactions between you and us is considered highly confidential and we employ appropriate security measures designed to protect it. While the information is kept confidential, it is shared with our board members, staff, volunteers, and professionals on a need-to-know basis and in compliance with all laws, regulations, court orders, and other governmental requests.

Security

We use industry standard safeguards to protect your personal information against the unauthorized access, use, alteration, or destruction of your personal information. We will not share, sell, or exchange your personal information with any other entity for third-party fundraising or marketing purposes, except as provided in this Policy or as expressly consented to by you. However, data transmitted over the Internet is not completely secure and we cannot guarantee the security of any information that is provided to us.  If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us (See “Contacting Us” below).

How We Share Information with Others

With Third–Party Vendors and Service Providers. We may share your Personal Information with vendors and service providers with whom we, our affiliates, or our licensees have a business relationship. For example, we may share your Personal Information with insurance companies, payment and credit card processing companies, accountants and legal advisors, advertising agencies and partners, and other vendors.

With Other Users of this Website. You may be able to submit User-Generated Content on or through this Website. In this Policy, “User-Generated Content” or “UGC” refers to content that you post using the social networking tools we make available to you and that does not constitute “Feedback,” which is defined as any suggestions, ideas, enhancement requests, recommendations, or other information provided by users of the Website or Digital Services related to any feature, functionality, or operation of the Website, Digital Services, or related offerings. Any Personal Information contained in UGC can be read, collected, or used by others. In addition, we may use UGC you submit for advertising campaigns and other marketing efforts. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the content for such purposes. Therefore, you should have no expectation of privacy with respect to UGC you submit on or through this Website.

With our Related Parties. We may disclose your Personal Information to any of our direct or indirect subsidiaries or affiliates, and/or any of our or their respective affiliates, subsidiaries, owners, managers, officers, directors or agents, licensees, and/or any other entity that is in common control with any of the foregoing, whether by beneficial ownership, voting power, or the ability to control or direct the management or policies of any such entity, whether by contract or otherwise.

With Volunteers. We may share your Personal Information with our volunteers who host bra drives and/or operate as a bra drop-off location, or with volunteers who host and/or operate any events or gatherings related to the organization.

As Part of a Merger or Acquisition. We may share your Personal Information with a third party who directly or indirectly acquires any ownership interest in us or any of our affiliates, or acquires the Digital Services, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets.

To Comply with Laws and Protection of Our Rights and the Rights of Others. We may share your Personal Information if: (i) we believe that we are required to do so by law or legal process; (ii) we believe that we are permitted to do so by law or legal process; (iii) to respond to a claim; or (iv) to protect the rights, property, or safety of us, our affiliates, or others.

With Your Consent.  We may also share any Personal Information from or about you with any party if you consent to that disclosure.  For example, we may need your consent to share information with a social media platform or other sharing functionality.

Sales to Third Parties. We may also sell your Personal Information to certain third parties, including for financial compensation or other valuable consideration. In some states, you may have the right to opt out of sales of your Personal Information. If you wish to opt out, please email info@freethegirls.org. Please note that the “sale” of information may be defined differently in different jurisdictions, and your opt out will only apply to the types of disclosure for which the laws in your jurisdiction require us to offer you an opt-out right. We encourage you to review these laws to understand your rights to opt out of this type of data sharing.

The third parties with whom we share this Personal Information may use it for their own purposes and in accordance with their own policies. We are not responsible for their actions.

We take reasonable steps to help protect your Personal Information under our control. However, data transmitted over the Internet is not completely secure and we cannot guarantee the security of any information that is provided to us. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us (See “Contacting Us” below).

How to Access, Update, or Correct Your Information

You can review and request changes to the personal information that we have collected about you by contacting the organization as described in the “Contact Us” section below. However, please be aware that we may not accommodate a change request that would impact record retention or other operational requirements like remembering email opt-out preferences, violate any law or legal requirement, or cause the information to be incorrect. Deleting your personal information may also require deleting your donor records. If you seek deletion or alteration of information that you provided to a third-party platform through use of the Website or Digital Services, please contact that third party directly, as we do not have access to their database of information.

Retention, Correction, and Deletion

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We comply with all Internal Revenue Service, state, and local regulations and our internal policies governing the retention, management, and destruction of donor information collected and maintained by us.

You may request that we update or correct any of your Personal Information or delete any of your Personal Information. We will respond to all requests for corrections or deletions in accordance with applicable data protection laws, but we may reject your request if we determine it is unreasonable or not required by law, or if we determine that it could expose us to operational risks or fraud.

United States Jurisdiction

We are headquartered in the United States and the Digital Services are exclusively for access and use in the United States, by United States residents. You consent to the transfer, storage, and processing of all Personal Information we collect in the United States.  

Children’s Online Privacy

The Website and the Digital Services are intended for general audiences and are not intended for children under 13 years of age. We do not knowingly collect “personal information” as defined by the U.S. Children’s Online Privacy Protection ACT (“COPPA”) from children in a manner that is not permitted by COPPA. If you are under 13 years of age, please do not use or provide any information on this Website or through any of its features. If we become aware that a child under 13 has provided us with “personal information” as defined by COPPA, without verification of parental consent, we will delete it from our records. We will not be liable for any collection of children “personal information” or failure to comply with COPPA by a third party. Children can access many parts of the Digital Services and its content and use many of its features without providing us with “personal information,” as we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Digital Services. If you believe we might have any information from or about a child under 13, please contact us as described in the “Contact Us” section below.

This Policy May Change

This Policy is current as of the date stated at the top of this page. We reserve the right to amend this Policy from time to time, without prior notice to you. We will notify you of any material changes to the Policy by email, if you have provided such information via the Website or alternative means, and/or through a notice on the Website home page. You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Webpage and this Policy to check for any changes. Your continued use of this Website after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.

You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of this Website.

Donor Bill of Rights

We subscribe to the Donor Bill of Rights as created by the Association of Fundraising Professionals, Association for Healthcare Philanthropy, the Council for Advancement and Support of Education, and the Giving Institute. A copy of the Donor Bill of Rights may be obtained by requesting such material in a manner described in the “Contact Us” section below.

Applicable to California Residents

Shine the Light Law. Residents of the State of California may ask us to provide them with a list of the types of personal information we have disclosed during the preceding year to third parties for their direct marketing purposes, as well as the identity of such third parties.  If you are a California resident and would like to request this information, please contact us at info@freethegirls.org.

Consumer Privacy Rights and Choices. Residents of the State of California may have certain rights in connection with the Personal Information collected the Digital Services, subject to exceptions under applicable laws. 

Twice per twelve-month period, you have the right to request the following information about the Personal Information collected through the Digital Services for the preceding year:

1.     The categories and specific pieces of personal information we have collected about you;

2.     The categories of sources from which we collected the Personal Information;

3.     Our business or commercial purpose in connection with collection or sale of the Personal Information;

4.     The categories of third parties with whom we shared the Personal Information; and

5.     The categories of Personal Information we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to complete transactions, protect and maintain the Digital Services, or comply with applicable laws and legal obligations.

Certain information may be exempt from such requests under applicable law.  We need certain types of information in order to provide services through the Digital Services. 

To exercise your rights to disclosure or deletion, please submit a verifiable consumer request to us at info@freethegirls.org. Only you or a person legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Information.

Applicable to Colorado, Utah and Virginia Residents

If you are a resident of Colorado, Utah, or Virginia, you may have certain additional data protection rights regarding the access, rectification, deletion, processing, storage, portability, transfer, and restriction of your Personal Information under the Colorado Privacy Act (the “CPA”), the Utah Consumer Privacy Act, (the “UCPA”), or the Virginia Consumer Data Protection Act (the “CDPA”), respectively, such as:

  • Request access to your Personal Information – Upon your request, we will provide you the following information about the Personal Information we collected from you over the previous twelve (12) months:

    • The categories of Personal Information we collected about you;

    • The categories of sources for the Personal Information we collected about you;

    • Our business or commercial purpose for collecting or selling your Personal Information;

    • The categories of third parties with whom we share your Personal Information;

    • The specific pieces of Personal Information we collected about you; and

    • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

  • Request erasure of your Personal Information –You have the right to ask us to delete or remove your Personal Information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  For example, we may not be able to fulfill your request if retaining the information is necessary for us or our service provider(s) to:

    • Complete the transaction for which we collected your Personal Information or provide a good or service that you requested;

    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

    • Debug products to identify and repair errors that impair existing intended functionality;

    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

    • 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it; and

    • Comply with applicable law and regulations.

  • Right to opt out of sale or disclosure to third parties – For Colorado and Virginia residents, you have the right to “opt out” of our practice of disclosing or selling your Personal Information, including with respect to using such Personal Information for cross-context behavioral advertising. Please see our description in this Privacy Policy above about your opt-out rights for “sales” to third parties.

To exercise these rights, you or a person that you authorize to act on your behalf, must email info@freethegirls.org. We may require you or your authorized representative to verify your request by providing us with additional information, including providing us information to verify your identity before disclosing any Personal Information to you. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You may only submit a request to access your Personal Information twice within a 12-month period.

We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

During the preceding 12 months, we have collected each of the categories of Personal Information we describe in the Privacy Policy above, but we have not sold Personal Information to third parties.

If you are under the age of 18, you may request and obtain removal of any content or information that is publicly posted through any of the Digital Services. To remove this content, please email us at info@freethefgirls.org and indicate in your email the exact specific information or content you would like removed. Please know that this removal does not mean that all copies will be destroyed, we may retain copies for various reasons, including to comply with law.

Contact Us

To opt out of receiving communications from us, to review the personal information that we have collected about you, or to ask any other questions regarding this Policy, please contact us at the below address or email, or submit your request via the Website’s Contact Us form.

 

Free The Girls
1552 Pioneer Trail
Chesterton, Indiana 46304

 

(720) 383-4384
info@freethegirls.org