PRIVACY POLICY

Safety, security, privacy.

Introduction

Take Action Institute respects your privacy and is committed to the responsible handling and protection of personal data. This Global Privacy Policy (“Privacy Policy”) provides information about how Take Action Institute handles and protects personal data and how we look after your personal data, including when you visit our website (regardless of where you visit it from) rights.

1. Important Information and Who We Are

Purpose of This Privacy Policy

This Privacy Policy aims to give you information on how Take Action Institute collects and processes your personal data through your use of this website and otherwise, including any data you may provide through this website when you subscribe to our newsletter, make a donation, register with us to form an account or become a member, submit a report via our contact form, post comments, take part in our contests and surveys, and otherwise use this website.

This website and our activities and services are not directed at children. Children are considered to be younger than 13 years of age.  You may not use our Website or provide us any Personal Information (for example, your name, address, telephone number) if you are less than 13 years of age. If we discover that you are under 13 years of age and registered on our systems, we will remove any Personal Information about you on our systems. 

We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will delete such data, unless we are required by law to retain it. Please contact us using the contact details at the end of this Privacy Policy if you believe that we have mistakenly or unintentionally collected personal data from a child.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

Take Action Institute is the controller and is responsible for your personal data.

It is important that you check frequently to see if there have been any updates to this Privacy Policy. If we make changes we consider to be important, we will place a notice on this website, and/or contact you to let you know.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, photograph, tax identification (including Social Security number), date of birth, and gender.
• Contact Data includes postal address, email address, and telephone numbers.
• Transaction Data includes details about your donations and volunteer actions.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, details about donations made by you, your interests, preferences (including language preference and voter method preference), voter registration status, reports, feedback, survey responses, and information associated with accounts you have with social media organizations.
• Usage Data includes information about how you use our products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) with your explicit written consent when you take part in certain surveys. Less commonly, we may process special categories of data about you where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We do not collect any information about criminal convictions and offenses.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. For instance, we may not be able to award a scholarship without collecting personal data, including your address and tax identification or social security number.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and Profile Data when you subscribe to our newsletter, register with us to form an account or become a member, submit a report via our contact form, post comments, take part in our contests and surveys, win a Take Action Institute Strategic scholarship, and otherwise communicate with us (by post, phone, SMS, email or otherwise) or use our platform.
• Automated technologies or interactions. In addition, our servers, logs, and other technologies automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. Not all of the personal data Take Action Institute holds about you will always come directly from you. It may also come from social media organizations (where individuals have linked their Take Action Institute accounts to social media accounts, and have made personal data associated with their social media accounts available for Take Action Institute to access), third-party service providers (including Identity and Contact Data from data brokers or aggregators), and fundraising platforms or publicly accessible sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to surveys which involve the disclosure by you of special categories of personal data, and sending certain direct marketing communications to you via email or text (SMS) message. You have the right to withdraw your consent at any time by contacting us using the contact details at the end of this Privacy Policy, or by emailing info@holocaustedu.org .

This Take Action Institute website provides a platform for you to post content including photos, comments, and other materials to the website, and to share that content publicly. Note that by default, all sharing through the website is public, and when you provide us with content (including information, photographs, etc.) it is published so that anyone can view, use, or share it, consistent with our Terms of Service. Content published and shared publicly is accessible to everyone, so you may lose any privacy rights you might have regarding that content. In addition, information shared publicly may be copied and shared throughout the internet, including through features native to this website. While you are free to delete your account with Take Action Institute, content may live on through re-publishing of your content by others, and due to the way the web works, copies of that content may exist elsewhere and be retained indefinitely. We urge you to make careful judgments about any personal data you disclose to this or any other website.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

“Legitimate interest” means the interest of Take Action Institute in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the contact details at the end of this Privacy Policy.

“Performance of a contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To register you as a new member, account holder, or donor	(a) Identity; (b) Contact	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to keep our records updated)
To manage our relationship with you, including communicating with you regarding your volunteer actions, scholarships, and otherwise, notifying you about changes to our terms of service or Privacy Policy, or asking you to leave a review or take a survey	(a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (for running Take Action Institute, keeping our records updated and studying how our services are used); (d) Consent
To enable you to partake in a prize draw or competition, or to complete a survey	(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how our services are used, to develop them and grow our charity)
To administer and protect Take Action Institute and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity; (b) Contact; (c) Technical	(a) Necessary for our legitimate interests (for running Take Action Institute, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganization or restructure); (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical	Necessary for our legitimate interests (to study how customers, supporters, and donors use our products and services, to develop products and services, to grow Take Action Institute, and to inform our marketing strategy)
To use data analytics to improve our website and SMS user experience, server and application performance, services, marketing, customer, member, supporter, and donor relationships and experiences	(a) Technical; (b) Usage	Necessary for our legitimate interests (to keep our website and services updated and relevant (and to otherwise improve them), to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about our activities and/or volunteer opportunities that may be of interest to you	(a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile	Necessary for our legitimate interests (to develop our activities and grow Take Action Institute)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications (in the form of our email newsletters and SMS updates) from us if you are a member or account holder and you have given us your express opt-in consent to receiving such marketing communications. You can manage your subscription preferences for these communications on your Profile page on the website www.takeactioninstitute.org.  

URLs contained in emails may contain an ID that enables us to correctly identify the person who takes an action using a web page. We may occasionally present a shortened URL that references a longer URL which contains an id — we do this to simplify the display, to prevent links from becoming broken when copied, and to ensure compatibility with email programs which do not handle long URLs. When a shortened URL is displayed in an email, you will see the full URL in the browser’s address bar when you access the page.

Third-Party Marketing

We will not share your personal data with any third party for their own marketing purposes.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing communication sent to you or by contacting us at any time using the contact details at the end of this Privacy Policy.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this websites may become inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details at the end of this Privacy Policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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

Disclosures of Your Personal Data

Take Action Institute does not share or sell donor information collected online or offline.

Take Action Institute shares or discloses personal data when necessary for the purposes set out in the above table in Section 4. When we share personal data, we do so in accordance with applicable law. Below are the parties with whom we may share your personal data and why we share it.

• Our business partners: We may partner with other organizations in order to carry out our activities. Occasionally, these arrangements may involve us sharing your personal data with the organization in question.
• Our third-party service providers: We engage third-party service providers throughout the world (including in the US and Spain) who provide IT (e.g. data storage, analytics, and infrastructure), member support, communications, administration, consultancy, banking, legal, insurance, and accounting services.
• Third parties for legal reasons: We will share personal data when we believe it is required, such as:
  • To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
  • In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, investments, or assets (including in connection with any bankruptcy or similar proceedings); and/or
  • To protect our rights, privacy, safety, or property, or those of other persons.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Our security policies and procedures include:

• To protect against accidental loss, data is routinely backed up off-site. All network traffic is encrypted with SSL to protect your personal data while in transit.
• We use monitoring & alerting tools and an on-call rotation to ensure technical and security issues are routed to engineers and addressed promptly. We also monitor publicly disclosed vulnerabilities in our software dependencies & patches are promptly applied.
• We engage an external team of security researchers to test our systems for vulnerabilities on a yearly cadence. Any findings are reviewed by the engineering team & fixes are validated by the external researchers.
• All code written by the engineering team is peer-reviewed before reaching production systems, and we use automated testing & static analysis to prevent mistakes.
• Training and informing staff: We provide privacy and data security information to all new staff as well as making them aware of our protocols and procedures regarding the protection of personal data to ensure that they are informed about our information security policies and procedures and aware of their responsibilities; and
• Third party risk management: We require any third party service providers with whom we share personal data to protect such personal data in accordance with our security policies and procedures.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as necessary to fulfil the purposes for which it is processed, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer need personal data, we seek to ensure that it is securely deleted or destroyed.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us using the contact details at the end of this Privacy Policy.

7. Your Right Regarding Use of Your Data

Under certain circumstances, you have the ability to access, control or alter our use of your personal data. Below is a summary of your rights in relation to your data:

• Access to personal data: We will give you access to your personal data upon request, subject to any relevant legal requirements and exemptions.
• Correction and deletion: you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
• Withdrawal of consent: where Take Action Institute is processing your personal data on the basis that you have consented to such processing, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Objection to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Restriction of processing of your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data (where we are relying on a legitimate interest, or that of a third party) but we need to verify whether we have overriding legitimate grounds to use it.
• Filing a complaint: if you are not satisfied with how Take Action Institute manages your personal data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. We would, however, appreciate the chance to deal with your concerns before you approach a National Data Protection Authority, so please contact us in the first instance.

If you wish to exercise any of the rights set out above, please contact us using the contact details set out below.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

8. Contact Us

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights regarding the processing of your personal data, please contact us as outlined below:

Contact Details

Legal entity: Holocaust Memorial Resource & Education Center of Florida DBA Take Action Institute

851 N. Maitland Avenue Maitland, Florida 32751

Telephone: 407-628-0555