Except as otherwise defined in this Policy, capitalized terms have the meanings set forth herein.
“Identifiable natural person” means a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
“Personal data” or “personal data” means any information about an identified or identifiable natural person.
Compliance with Local Laws
This Policy is meant to guide JFC with respect to personal data collected from or about you at this Website. While this Policy applies to personal data generally, the local laws, rules and regulations of jurisdictions that are applicable to JFC (“Local Laws”) may require standards which are stricter than this Policy and, in such event, JFC will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.
Consent to Data Collection and Processing
You hereby agree with and consent to the collection and processing of your personal data as described in this Policy.
Consent to International Data Transfers
Your personal data may be collected, processed, and stored by JFC or its service providers in the United States and other countries where our, or our service providers’, servers reside. Please be aware that privacy protections and legal requirements, including the rights of authorities to access your personal data, in some of these countries may not be equivalent to those in your country. You hereby agree and consent to the transfer of your personal data to the United States and other countries where our, and our service providers’, servers reside.
Collection, Use, and Disclosure of Personal Data
The privacy and security of the personal data that JFC collects from you is a priority for JFC. Generally you can visit the Website without providing personal data, unless otherwise mentioned in the Website itself. However there may be circumstances when you may be asked or choose to provide personal data that could reasonably be used to contact you or to identify you personally. The categories of information that JFC collects about you may include, but are not limited to:
- Identifiers and contact information (such as name, home address (including city, state and zip code), email address, telephone number, unique personal identifier, online identifiers, IP address, social security number, driver’s license number, passport number, or other similar identifiers)
- Demographic information (such as gender, date of birth, marital status, and household composition)
- Professional or employment related information (such as current or past job history)
- Payment information (such as your credit card number, security code, expiration date, and bank account information)
- Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information)
- Marketing profile information
- Photographs and videos such as those that you may submit for contests or social sharing
- Relationships you have with JFC
- Inferences drawn from other personal information (such as personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)
JFC collects and uses personal data for the following purposes:
- JFC may collect and use personal data that you submit at our Website to communicate with you, better understand your needs, and to provide you with better service. For example, when you visit our websites, or send e-mails to JFC, you are communicating with us electronically and may be submitting personal data to JFC. We may use this personal data to communicate with you either electronically, by e-mail, or using other means.
- By way of example, JFC may collect and use personal data that you submit at our Website when you (1) register with JFC for an event or service, (2) make a donation to JFC, (3) register your e-mail address with us, (4) opt-in to receive newsletters, (5) enter contests sponsored by us, (6) sign up for special offers from select third parties, (7) send e-mail messages or feedback, submit forms or transmit other information by e-mail, (8) submit your credit card or other payment information when registering for an event or making a donation at our Website, (9) complete a survey, (10) register for a user account, (11) submit directory information, or (11) submit event information. If you elect to engage in such activities, we may ask that you provide us personal data, such as your first and last name, date of birth, age, mailing address (including zip code), e-mail address, telephone numbers, credit card type and number, credit card security code, children’s name and date of birth (for registering with PJ Library or other events or services as provided by JFC) and other personal data. If you do not provide certain personal data with respect to a particular activity, you will not be able to engage in that activity.
- We may also use your personal data that you submit to provide you with a more efficient and customized experience, process your services or event registration, improve our marketing and promotional efforts, statistically analyze Website use, improve our event and service offerings, contact you to solicit donations, and enhance our Website’s content, layout, and services. We may contact you regarding administrative notices and/or send you occasional e-mails or regular mail regarding our services, special offers and upcoming events that may be of interest to you. If you do not wish to receive this information, please click on either the “Update your preferences” or “Unsubscribe” link shown on all our e-mails and electronic newsletters to you or contact us at the address or telephone number listed herein and we will remove your name from our mailing lists.
- To help JFC improve your experience on our Website, JFC may also track your use of our Website. We may collect certain information about you, including personal information, based upon how you search and interact with our Website, including which pages you view while visiting our Website. For system administration and statistical analysis purposes, this information is compiled and analyzed on both a personal and an aggregated basis. This information may include a website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, general geographic location, device type, what browser you are using, Internet service provider, date/time of visit information, operating system, and your Internet Protocol (“IP”) address, which tells us the country and state you are searching our Website from. A URL is the global address of documents and other resources on the World Wide Web.
- We may also use your personal data that you submit at our Website to update your profile information on our off line database.
- We also collect, or enlist a third party service provider to collect, store, process and manage certain non-personally identifiable information to diagnose problems with our servers and software, administer our Website, connect you to the credit card payment platform and gather and analyze demographic and other statistical information. Our third party service providers may also provide us with summary, but not individual, reports that will tell us how our Website is being used. We may also share such aggregate statistical and demographic information with select third parties, such as our partners; however, these reports do not contain any personal data.
- Any information you give us through this Website may be transmitted to servers outside the country where the information is entered, and may be used, stored, and processed outside the country where it was entered. As you browse our Website, our servers may collect information about your visit. For example, to help us better serve you and improve our Website, we may monitor statistics such as how many people visit our Website, which pages people visit on our Website, and which browsers people use to visit our Website.
JFC also may use and disclose your personal data: (1) to the extent required to respond to a legal or ethical obligation, (2) to the extent necessary to meet national security, public interest or law enforcement obligations, and (3) to the extent expressly permitted by an applicable law, rule or regulation.
Of course, you may choose not to provide JFC with personal data. However, this choice may prevent JFC from providing you with the product, service, event, or other information you requested or that could be offered to you.
JFC may use your personal data as set forth in this Policy (or any other JFC policy, as applicable), and for any other purposes for which your consent is required under applicable law so long as JFC obtains your consent.
Additionally, where JFC is permitted to do so under applicable law, JFC may share your personal data with its affiliates, employees, contractors, volunteers, consultants, and other parties who provide services to JFC or otherwise support our business including, without limitation, parties that provide information technology and data and payment processing services to JFC with respect to the operation of its businesses. We may disclose your personal information to third parties to market their products and services to you. You may opt out of such disclosures by contacting us using one of the methods set forth in the “Opt Out” section below.
Where JFC is permitted to do so under applicable law, JFC may transfer or provide your personal data to affiliates or third parties for the purposes set forth herein both in and outside of the nation where you reside.
Additionally, your personal data may be disclosed as required by applicable law, to comply with a court order, subpoena, warrant or other legal process, or where the personal data is publicly available (unless otherwise restricted by applicable law).
Like many websites, JFC uses “cookies” and similar tools on the Website to improve its performance and enhance your user experience.
What are Cookies?
A cookie is a small text file which is placed on your Device. Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain cookies may contain personal data – for example, if you click to “remember me” when logging in, a cookie may store your username. Most cookies won’t collect personal data that identifies you, and will instead collect more general information, such as how users arrive at and use our Website, or a user’s general location.
JFC may place cookies or similar files on your Device for security purposes, to tell us whether you have visited the Website before, to remember your language preferences, if you are new visitor or to otherwise facilitate site navigation, and to personalize your experience while visiting our Website. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our Website and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Website. Cookies may enhance your online experience by saving your preferences while you are visiting a particular Website. Overall, cookies help us provide you with a better Website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your Device or any information about you, other than the data you choose to share with us.
What kinds of Cookies do we use?
Generally, the cookies that are used on the Website can be broken down in to the following categories:
- Session Cookies – These cookies are used ‘in-session’ each time you visit and then expire when you leave a Website or shortly thereafter: they are not stored on your Device permanently, do not contain any personal data and help by minimizing the need to transfer personal data across the internet. These cookies can be deleted or you can refuse to allow their use, but this will hamper the performance and your experience in using the Websites. These cookies also take time stamps that record when you access a Website and when you leave a Website.
- Tracking Cookies – These cookies enable us to recognize repeat visitors to our Website. By matching an anonymous, randomly generated identifier, a tracking cookie keeps track of where a user of our Website came from, what search engine they may have used, what link they clicked on, what keyword they used and where they were in the world when they accessed a Website. By monitoring this data, we can make improvements to our Website.
- Persistent Cookies – This type of cookie is saved on your Device for a fixed period (sometimes for a few hours, sometimes for a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to remember who you are for more than one browsing session. For example, this type of cookie can be used to store your preferences, so that they are remembered for the next visit to a Website.
- Performance or Analytical Cookies – Performance cookies are used to analyze how the Website is used and to monitor its performance, which allows us to improve your experience in using the Website. These cookies help us to tailor the content of the Website to reflect what the Website users find most interesting and to identify when technical issues with the Website arises. We may also use this data to compile reports to help us to analyze how a Website is used, what the most common issues are and how we can improve the Website.
Can the Cookies be blocked?
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Website may not work properly because we may not be able to recognize and associate you with your JFC account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
- We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.
- Google Analytics Demographics and Interest Reporting – allows us to see the age, gender and interests of website visitors to better understand them and personalize advertising.
- Google Display Network Impression Reporting – for banner ads.
- Remarketing through Google Analytics for Display Advertising – allows personalization of ads on our ad networks.
- User ID Extension for Google Analytics – allows us to connect multiple devices, sessions and engagement data.
- We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Even after you have consented to JFC’s collection and use of your personal data and submitted personal data to JFC at this Website, you may opt-out of having your personal data collected or used by JFC by contacting JFC. Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any events or services you request. You may contact JFC by sending us a letter at:
Jewish Federation of Cleveland
25701 Science Park Drive
Cleveland, OH 44122
Attention: Privacy Officer
Or by e-mail to: email@example.com
Or by telephone at: 216-593-2900
Or by facsimile at: 216-593-2901
General Principles for the Processing of Personal Data
Personal data will be collected, stored, processed and transmitted in accordance with JFC’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of JFC with respect to the processing of personal data are as follows: (1) personal data will be processed fairly and lawfully, (2) personal data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal data collected by JFC will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) personal data collected by JFC will be accurate and, where necessary, kept up to date to the best of our ability, and (5) personal data collected by JFC will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal data was collected.
If JFC engages in the processing of personal data for purposes other than those specified in this Policy, JFC will provide notice of these changes, the purposes for which the personal data will be used, and the recipients of personal data.
Your Rights Over Your Information
By law, you have a number of important rights. In summary, those include the following:
- fair processing of your personal data and transparency over how we use it;
- requiring us to correct any mistakes in your personal data in our possession or under our control;
- requiring the erasure of your personal data, in certain situations;
- receiving your personal data in a structured, commonly used, and machine readable format, and the right to transmit that data to a third party, in certain situations;
- objecting at any time to the processing of your personal data for direct marketing;
- objecting to decisions being made by automated means that produce legal effect concerning you or significantly affecting you; and
- objecting in certain other situations to our continued processing of your personal data.
If you would like to exercise any of these rights, please call, email, or write to us with the following information to identify you; (2) proof of your identity and address; and (3) the information to which your request relates.
Transfers of Personal Data
We do not sell any of your personal data (including your name, mailing address, or e-mail address) to any companies or third parties. We do provide some of our services through contractual arrangements with affiliates, service providers, volunteers, and other third parties that require us to share your personal data with them in order to deliver those services. For example, we must release your credit card information to the card-issuing bank to confirm payment for events and services purchased on this Website; release your address information to our mailing service to deliver letters; release your name, children’s names, and address for families registering children to receive books and services from PJ Library; provide your name, phone number, or other contact information to volunteers that help with donation solicitation and events; and provide name and address to third parties that help us provide donor services. We require our service providers to adopt and post privacy policies consistent with this Policy.
Linking to and Privacy Policies of Third Party Sites
This Policy applies to information collected from this Website by JFC. Once you click on a link to another website (the “Linked Site”), you are no longer on this Website. This Policy does not apply to the content or privacy practices of any Linked Site. We encourage you to read the privacy statements of each and every website or Linked Site that collects personal data. You should contact advertisers, other websites or Linked Sites directly if you have any questions about their privacy policies or their use of the information they collect.
Miscellaneous Privacy Issues
JFC is committed to protecting the privacy of children. Though this Website is not directed to individuals under the age of 13, JFC may collect personal data of children from a child’s parent(s) or legal guardian(s) for purposes of soliciting a donation or registering with PJ Library, or other events or services as provided by JFC. JFC will never use personal data of children for any commercial marketing purposes.
You should be aware that when personal data is voluntarily disclosed (e.g., your name, e-mail address, etc.) in any public areas on this Website (such as a message board) – that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to public areas on this Website are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any public submissions.
User Registration and Password
Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. To ensure effectiveness of your password, we recommend that you do not disclose your user identification or password to anyone. Please be careful and responsible whenever you are online.
JFC will take reasonable steps to protect the personal data in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction, and will take useful precautions with regard to the nature of the data and the risks of the processing, to preserve the security of the data and, in particular, prevent its alteration and damage or access by non-authorized third parties. JFC has put in place appropriate technical, physical, and organizational procedures and security measures to safeguard and secure the personal data from destruction, loss, alteration, unauthorized access or disclosure, or other forms of unauthorized or unlawful processing commensurate with the risks posed by the particular type of processing, the nature of the personal data and in accordance with applicable law and applicable guidelines, and taking into consideration the cost of implementing such measures.
Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please notify us as soon as possible.
It is your responsibility to provide JFC with accurate personal data. Except as otherwise set forth in this Policy, JFC shall only use personal data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, JFC shall take reasonable steps to ensure that personal data is accurate, complete, current and relevant to its intended use.
Upon request by you, JFC will grant you reasonable access to your personal data, except where your rights are limited by applicable law. JFC will permit you to correct, amend or delete inaccurate or incomplete personal data, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Subject to the above, you may change any of the personal data you have provided to us by writing us at:
Jewish Federation of Cleveland, 25701 Science Park Drive, Cleveland, OH 44122, Attention: Privacy Officer, or by e-mail at firstname.lastname@example.org. Please include your name, address, and/or e-mail address when you contact us.
You may ask to have the information on your account deleted or removed; however, we may be required in certain circumstances to retain information related to your donor history and other past transactions on this Website. In addition, it may be impossible to completely delete your information without some residual information because of backups. Such information will be deleted from our backups in accordance with our retention policy.
We retain your personal data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
JFC will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.
If you believe that your personal data has been processed or disclosed in violation of this Policy, JFC encourages you to raise any concerns using the contact information provided in this Policy. JFC will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal data.
Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of applicable law. A notice will be posted by JFC on this Website when this Policy is changed.
Date of last update: September 14, 2021