PERSONAL AND OTHER INFORMATION WE MAY COLLECT
Collection of Personal Information
“Personal Information” is information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other information that is linked or linkable to a specific individual, for example:
- Your name
- Identifying information such as birth date, gender, occupation, or state of residency
- Contact information such as mailing address, e-mail address, or fax or telephone numbers
- Account information such as login name, password, or answers to security questions
- Grant applicant information
- Organizational affiliation
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, trade union membership, or criminal background) to us. Furthermore, the Sites are not intended for you to submit Personal Information relating to persons other than yourself.
By using the Sites, you represent that all Personal Information collected by us from you is not sensitive Personal Information (unless we have specifically requested that piece of sensitive Personal Information) and relates to you and not to any other person.
We (with the help of our service providers) collect Personal Information in a variety of ways, including:
- Through the Sites: We collect Personal Information through the Sites, for example, when you sign up for a newsletter, download a publication, register for an event, request information, or submit a grant application.
- Offline: We collect Personal Information from you offline, for example, when you attend an event.
The purposes for which we collect Personal Information are described below (see “How We May Use Personal Information”).
Collection of Other Information
“Other Information” is any information that does not by itself reveal your specific identity and does not directly relate to an identifiable individual, such as:
- Browser and device information
- IP addresses and location
- Information collected through cookies, pixel tags, and other technologies
- Information about the pages you visited, what you searched for, and the domain name of the website from which you came
- Demographic information and other information provided by you that is not identifiable to you personally
- Information about you that is aggregated with information about other users such that your information is no longer identifiable to you personally.
We (with the help of our service providers) may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, referring URL, and the name and version of the Sites you are using.
- IP Address: 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 may be identified and logged automatically in our server log files whenever a user accesses the Sites, along with the time of the visit and the pages visited.
- From you: Information other than Personal Information is collected when you voluntarily provide it.
HOW WE MAY USE AND DISCLOSE PERSONAL INFORMATION AND OTHER INFORMATION
How We May Use Personal Information
We, and our service providers acting on our behalf, may use Personal Information for legitimate business purposes including: (1) providing the functionality of the Sites and fulfilling your requests; (2) providing you with our newsletter and/or marketing materials; and (3) to accomplish our business purposes relating to the Sites. Additional information about each purpose is provided below.
We may use Personal Information to provide the functionality of the Sites and fulfill your requests, including:
- To provide you with customer service and support.
- To respond to your inquiries and fulfill your requests, when you contact us via an online contact form or otherwise.
- To process and review grant applications.
- To better understand your preferences so that we can deliver content via our Sites that we believe will be relevant and interesting to you.
- To send administrative information to you, such as changes to our terms, conditions, and/or policies.
- To otherwise fulfill our contractual obligations to you and/or to comply with a legal obligation in conjunction with your requests or the operation of the Sites.
We may use Personal Information to provide you with our newsletter and/or other marketing materials, including:
- To send you marketing related emails with information about the Sites, new products or services, available grants, and other news about our activities.
We may use Personal Information to accomplish business purposes relating to the Sites, including:
- For the purposes of ensuring the Sites function properly.
- For data analysis, for example, to calculate usage levels, diagnose server problems, derive approximate locations of users, improve the efficiency of the Sites, and otherwise administer the Sites.
- To analyze or predict our users’ preferences.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes.
- For developing new products and services.
- For enhancing, improving, or modifying the Sites or our current products and services.
- For identifying usage trends, for example, understanding which parts of the Sites are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- To resolve disputes.
- For the fulfillment of a legal obligation related to our business purposes.
Aggregating and/or anonymizing Personal Information
How We May Disclose Personal Information
Your Personal Information may be disclosed:
- To our third-party service providers (which may include Booz Allen Hamilton Inc. and its affiliates), to facilitate services they provide to us, including website hosting, data analysis, information technology, customer support, email delivery, auditing, and other services.
- To comply with applicable law and regulations.
- To respond to requests from public and government authorities.
- To cooperate with law enforcement
- To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
- In connection with a sale or other business transaction involving The Education with Purpose Foundation for Pacific Islanders. We have a legitimate business interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business assets or stock (including in connection with due diligence regarding such a transaction as well in any bankruptcy or similar proceedings).
- For other purposes where we have a legal obligation or legitimate interest to do so.
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where prohibited to do so under applicable law.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use of your Personal Information
If you have provided us with your email address to subscribe to our newsletter (whether directly through the Sites, at an event, or in conjunction with a grant application), we may periodically send you marketing-related emails that promote or otherwise contain information relating to our organization. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the instructions contained in each email. Please note that, if you opt out, we may still send you important administrative messages, from which you cannot opt out.
If you have provided us with your email address and other Personal Information for the purposes of submitting a grant application, you may request that we cease review of your application and delete your application by contacting firstname.lastname@example.org.
How you can access, change or suppress your Personal Information
If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information, object to the processing of your Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at email@example.com. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that if you or we delete certain of your Personal Information, you may be required to re-submit that information in order to use certain features of the Sites in the future. Please also note that we may need to retain certain Personal Information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Sites to you (for example, for as long as you have an account with us or keep using the Sites);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Do Not Track
USE OF THE SITES BY MINORS
The Sites are not directed to individuals under the age of 18, and we do not knowingly collect or maintain Personal Information from persons under the age of 18. You must be at least 18 years of age in order to create an account or submit an application for a grant.
JURISDICTION AND CROSS-BORDER TRANSFER
The Sites are controlled and operated by us from the United States and are not directed to persons outside of the United States. Your Personal Information may be stored, transferred, used, and processed in any country where we have facilities or in which we engage service providers, and by using the Sites, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. By using the Sites, you explicitly consent to such transfer. You acknowledge that in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.