Privacy and Information Security Policy (“Privacy Policy” or “Policy”) for GloriaCMacKenzieFoundation.com

Effective Date: August 13, 2015

This Policy is designed to help you understand generally how GloriaCMacKenzieFoundation.com and other Gloria C. MacKenzie Foundation (the “Foundation,” “we,” “us” etc.) Web properties (the “Site”) collect personally identifying information about you and how the Foundation uses and discloses that personal information. GloriaCMacKenzieFoundation.com is a Web site of the Foundation, a charitable corporation and private foundation existing under the laws of the Commonwealth of Pennsylvania, U.S.A. You may contact us at our Address For Legal Notices below. This Policy applies to information that personally identifies you (other than publicly available information) (“personal information”) collected on GloriaCMacKenzieFoundation.com or any additional Foundation Web properties or third-party sites managed by the Foundation or, where indicated, other information you provide to us.

USE OF OUR SITE OR PROVISION OF ANY PERSONAL INFORMATION CONSTITUTES AGREEMENT TO THIS POLICY. DO NOT USE THE SITE OR PROVIDE INFORMATION (OR ALLOW OTHERS TO DO SO ON YOUR BEHALF) IF YOU (AND YOUR PRINCIPAL IF YOU ARE ACTING AS AGENT) DO NOT AGREE WITH ALL OF THE TERMS OF USE INCLUDING THIS POLICY AND ANY APPLICABLE SUPPLEMENTAL PRIVACY POLICY.

Table of Contents

How Does This Policy Relate to Use of the Site?
Information We Collect That You Do Not Provide
Information We Collect That You Do Provide
Information You Provide About Others
What We Generally Do with Personal Information Collected
Your Ability to Update Personal Information
Information Security
Your Particular Consents
Children
Identity Theft
Amendments
Information About Enforcement of Our Policy
HIPAA

1. How Does This Policy Relate to Use of the Site?
This Policy is part of and incorporated into the GloriaCMacKenzieFoundation.com Terms of Use (“Terms of Use”), which is the contract between you and the Foundation governing use of the Site. Parts of the Terms of Use affect this Policy, so, unless you have already done so, please review them prior to using the Site. Please note that, under the Terms of Use in effect, your use of this Site constitutes your agreement to the Terms of Use and this Policy. Terms used but not defined in this Policy have the definitions ascribed them in the Terms of Use.

This Policy is supplemented by additional policies relevant to particular activities, and each of the supplemental policies is incorporated into this Policy. For example, if a supplemental policy is included on the Site with respect to a particular activity, or if one is included on a Third Party site relating to the mission of the Foundation, those supplemental policies will also apply and are also incorporated.

2. Information We Collect That You Do Not Provide
Sometimes we may collect personal information without you having to enter any information on the Site. For example, we may receive personal information from public sources or from Third Parties (which we may combine with other information from other sources).

In addition, we may collect some information automatically from visitors to the Site, for example through the use of “cookies”, “web beacons”, and other tracking mechanisms. We may collect at least the following (though the foregoing list is not exclusive): your domain name and host for Internet access; the Internet address of the site from which you came; the date and time of your access; your computer’s IP address and information about its operating system, browser and host; the date and time you access the Site and the pages you visit. If you do not want to receive cookies, you may set your browser to reject them. However, if you turn cookies off, you may not have access to some of the Site’s services and features. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issues cookies when you access the Site. We also may employ web beacons from Third Parties to help us compile aggregated statistics regarding the operations of our site. We prohibit web beacons on our site from being used by third parties to collect or access your personal information.

3. Information We Collect That You Do Provide
It is always your choice, or the choice of anyone acting for you, whether to provide personal information. However, some must be provided to participate in certain programs or activities (such as to apply for a grant), so the decision not to provide information might limit or eliminate certain functions of the Site or the ability to participate. Other information is up to your good judgment, e.g., do not provide personal information about yourself that could be misused by others in a chat room, bulletin board, blog or similar forum, as appropriate, and do not provide personal information about others without their permission. The kinds of personal information we tend to request about you or others include but are not limited to your name, email address, native language, organization name, job title, city, state / province, region, age, locations for internet access and devices used. Additional information about what we collect is available in any supplemental privacy policies for particular activities.

4. Information You Provide About Others
Do not supply personal information about others unless you are authorized or required to do so by applicable law or contract and you consent to the Terms of Use (including this Policy and supplemental policies) on behalf of yourself and the “Data Subject” (the person about whom you supply personal information). Before supplying personal information about others (except as otherwise allowed by law or contract), you must make available for the Data Subject’s review, and obtain their written consent to, said Terms of Use and policies. By submitting any personal information about others, you represent and warrant that you are authorized to do so and that you did all of the foregoing before submitting the information. If applicable law allows you to supply the information without doing the foregoing, you represent and warrant that you have abided by that law and that it allows us to receive and Disclose (as defined in Section 5 hereunder) the information under this Policy without any further action on our part. You agree to indemnify, defend and hold us harmless against any failure by you to comply with this paragraph.

The Foundation works with Third Parties on certain programs, and often those Third Parties own and/or are responsible for that program’s web site. In those cases, if you provide personal information, you will be giving it to a Third Party and their privacy policy will apply. You agree that if they provide it to us then we may apply our Policy to what we receive.

5. What We Generally Do with Personal Information Collected
In general, we use personal information we collect to pursue our mission and operations and to engage in the activity (and related activities) for which we collect it.  Specifically, we may use your personal information:

to fulfill our obligations to you and to respond to any questions or requests;
to contact you about material changes in our site Terms of Use and/or Policy;
to comply with the law or in good faith belief that such action is necessary to conform with the requirements of law or to comply with legal process served on us;
to provide it to Third Parties as a result of any reorganization process; and/or
to put you on our mailing list or even the list of a Third Party who we think has a similar mission if you sign up for a blog, feed or newsletter.

Further information is available in the supplemental policies for some activities, but you should assume that we will use all information for all lawful purposes. Subject to applicable law, we reserve the right to make all lawful, worldwide uses of personal information, including without limitation, to: collect, use, access (or bar access), process, fulfill, disclose, display, share, respond to legal process or otherwise exercise our rights under applicable law, transfer, store, verify,  enforce, delete, and otherwise deal with personal information, and information other than personal information (collectively “Disclose”).

6. Your Ability to Update Personal Information
To the extent our systems require your personal information, in general, they provide the ability for you to update your information.  If you have any questions about what personal information the Foundation retains about you, please contact us at info@GloriaCMacKenzieFoundation.com. The Foundation endeavors to keep your personal information accurate and up to date.   If your personal information has changed, you may submit your new information there as well. Some activities allow some updating. 

We keep personal information for as long as we think is necessary or advisable and we reserve the right to retain it to the full extent not prohibited by law. We may discard personal information in our discretion, so you should retain your own records, and not rely upon our storage of any personal information or other data.

7. Information Security
We use reasonable technical and organizational measures to protect the personal information received from our users from unauthorized use or disclosure.

8. Your Particular Consents
In addition to consenting to the Terms of Use, including this Policy (and any relevant supplemental policies), the Foundation is interested in letting you know about, and receiving your particular consent to, a few activities relating to personal information that will help us to deal with personal information that is Disclosed in furtherance of our mission, operations and programs. These are described immediately below.

Consent to International Transfer and Disclosure of Personal Information. Although our programs and activities are only based in the United States of America, it may become necessary, in our fulfillment of our obligations, to share your personal information with a foreign entity. You agree that the Foundation and those with whom we share personal information (“Recipients”) may Disclose and transfer your personal information worldwide (including outside the European Economic Area, if you are based in the European Economic Area) for any purpose relating to our or their mission, operations, programs, or otherwise that is not allowed or prohibited by this Policy.

Consent to Electronic Notice If There is a Security Breach: If we or a Recipient is required to provide notice of unauthorized access or other invasion of certain security systems, you agree that we (or they) may do so when required (or voluntarily) by posting notice on our Site or sending notice to any email address we have for you, in our (or their) good faith discretion. You agree that notice to you will count as notice to others for whom you are acting, and agree to pass the notice on to them.

9. Children
We do not want to collect information from children. Do not provide any personal information unless you are at least 13 years of age, and please caution your children not to provide any. If a child under 13 has provided personal information, a parent or guardian may so inform us by writing us at Our Address for Legal Notices (see below) and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Policy.

10. Identity Theft
If you believe that you are a victim of identity theft entitled by law to request information from us, write us at Our Address For Legal Notices and we will explain what information we require in order to respond. After receiving that information, we will supply (without charge) information we then have that we are legally required to provide (subject to applicable law and reserving all rights and defenses).

11. Amendments
We will be changing what we do and how and why we Disclose data periodically—this Policy describes what we currently envision, but that will change as we change. You agree that this Policy amends and replaces any previous privacy policy (or policies). We may further amend all or part of this Policy in the same way that we make amendments to our Terms of Use and such amended versions will be posted on this page.

12. Information About Enforcement of Our Policy
This Policy is part of and supplemented by our Terms of Use, which together with any supplemental privacy policy form a contract. If there is a conflict between the Terms of Use and this Policy, the latest version of this Policy will control. We and you are bound by the Terms of Use, including this Policy. If you think we are in default, you may contact us by writing to Our Address For Legal Notices. There are no third party beneficiaries of this Policy.

Our Address for Legal Notices:

Gloria C. MacKenzie Foundation
Attn: Warren W. Ayres, Legal

Centre Square West, 34th Floor

1500 Market Street

Philadelphia, PA  19102

13. HIPAA
As part of applying for grants from the Foundation, applicants may be required to provide certain medical information as part of such application. The Foundation is committed to following Congressional standards with regard to patient privacy as set forth in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and subsequent federal law. Although the Foundation will not provide any health care services directly, the Foundation nonetheless will maintain the confidentiality of applicant health care information in accordance with HIPAA and
Commonwealth of Pennsylvania law. Prior to the distribution of any such medical information by the Foundation, the Foundation will secure from the applicant any and all required authorizations to release such information except when required to release such information by a law enforcement agency.