PRIVACY POLICY

Effective Date: March 13, 2015

Introduction

Welcome! You have arrived at the www.thewetzelfoundation.org website and/or are otherwise interacting with our Service (defined below), which is owned and operated by The Wetzel Foundation, Inc. (“The Wetzel Foundation” or “we,” “our” or “us”), and/or are otherwise interacting with our Service. This “Privacy Policy” governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Privacy Policy (each a “Site”) (including, without limitation, both mobile and online versions), and also applies to your use of interactive features, widgets, plug-ins, content, downloads and/or other services that we own and control and make available through a Site and/or that posts a link to this Privacy Policy (collectively, the “Service”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, even if they use our technology to collect it, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. 

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Service, which governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below.

The Full Detailed Privacy Policy

 

1. What Information Does the Service Collect?

• Information You Provide to Us(b)        Information Collected or Stored As You Access and Use the ServiceThis Usage Information may include:

 

1. In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service.  To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.
2. Personal Information and Demographic Information.  On the Service, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, credit card number or other payment (or donation) information, phone number and home address (“Personal Information”); and (2) demographic information, such as information about gender, marital status and occupation (“Demographic Information”).  We may collect this information through various forms and in various places on the Service, including contact us forms, e-mail newsletter registration or when you otherwise interact with the Service. To the extent we combine Demographic Information with your Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy.

• your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the URL that referred you to our Service;
• the areas within our Service that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• certain other Device data, including the time of day, among other information.Cookies.  A cookie is a data file placed on a Device when it is used to visit the Service.  A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device.  HTML5 cookies can be programmed through HTML5 local storage.
• Web Beacons.  Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon.  Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
• Tracking Technologies.  We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on.  The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting.  Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or Entity Tag.  A feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.  If the resource content at that URL ever changes, a new and different ETag is assigned.  Used in this manner ETags are a form of Device Identifier.  ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies.  Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Location-identifying Technologies.  Additionally, the Services may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the Services. In addition, you may be able to send your location information via the Services to other Services users. You should consider the pros and cons involved in disclosing your location information to us and to other people.  Where a user of the Services requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Twitter and Facebook.  We are not responsible for the acts, omissions or policies of such third parties.

Tracking Technologies Usage.  We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, and improve security.

Performance‑Related.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, or services offered through the Service.

Functionality‑Related.  We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you sign‑in to our Service or keeping track of your specified preferences, including in terms of the presentation of content on our Service.

Targeting‑Related.  We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Service and third‑party sites based on how you interact with our advertisements or content.  This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you.

Tracking Technologies Choices and Consent.

Third Party Tracking and Do Not Track.

There may be other Tracking Technologies now and later devised and used by us in connection with the Service.  Further, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party web sites or online services.  We may not control those Tracking Technologies and we are not responsible for them.  However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals).  Currently, we do not monitor or take any action with respect to these do not track signals or other mechanisms.

Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings.  Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.  Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies.  For information on disabling Flash cookies go to Adobe’s website www.adobe.com.  Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

(c)        Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with your Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.   In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.

(d)        Interactions with Third Party Sites

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party web site or application.  The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us.  For example, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Site, or otherwise link accounts.  If we offer and you choose to use this functionality to access our Site, the third-party site or application may send Personal Information about you to the Site.  If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Site.  In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site.  For example, we may use third parties to facilitate emails, tweets or Facebook postings.  These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy.  Company may not control or have access to your communications through these third parties.  Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices.  You should review the applicable third-party privacy policies before using such third-party tools on our Site.

2. How Do We Use the Information Collected?

Generally.  We may use your Personal Information, Demographic Information or Usage Information that we collect about you:  (1) to provide you with information or services that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Services’ features such as online entry sweepstakes, contests or promotions; (3) to process your registration with any of the Services, including verifying your information is active and valid; (4) to improve the Services or create new service offerings, to customize your experience on any of the Services, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Services and, in our discretion, changes to any of the Services and/or any of the Services’ policies; (6) for internal business purposes; (7) to complete donations and pledges made through the Service; (8) to provide you with customer support; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Interest-Based Advertising and Location-Based Services.  We may also use your Personal Information, Demographic Information or Usage Information that we collect about you:  (1) to specifically target relevant advertisements or content to you based on how you interact with our Services; (2) to understand the usefulness to you of the advertisements or content that have been delivered to you; and (3) to increase our Services profile, including allowing you to comment or add content to the Services.

Contact Us.  Please note that information submitted to any of the Services via a “contact us” or other similar customer inquiry function may not receive a response.  We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, Usage Information, and Demographic Information with third parties.  We may share your Device Identifiers with third parties along with data related to you and your activities.  We do not share your Personal Information that we have collected directly from you on our Service with third parties for those third parties’ direct marketing purposes unless we have given you the choice to consent or withhold consent to such sharing at the time you provide your Personal Information, in which case we will honor your choice. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.  The Wetzel Foundation may disclose your information as follows:

(a)        When You Request Information From or Provide Information to Third Parties.  You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b)        Third Parties Providing Services on Our Behalf.  We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, processing donations, and enabling us to send you e-mails, newsletters and special offers or perform other administrative services.  We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them.  We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c)        To Protect the Rights of The Wetzel Foundation and Others.  To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of  The Wetzel Foundation or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).  To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d)        Transfer to Affiliates and Business Transfers.  We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates (“Affiliates”).  We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e)        Co-Branded Areas.  Certain areas of the Service may be provided to you in association with third parties (“Co-Branded Areas”) such as sponsors, charities and trade organizations and may require you to disclose Personal Information to them.  Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of you information.  If you elect to register for products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both us and the third party.  Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Service, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  We are not responsible for such third party’s data collection or practices and you should look to such third party privacy policies for more information.  

(f)        Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Service that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. 

(g)       Your California Privacy Rights.  Under California law, California residents who have an established business relationship with The Wetzel Foundation or one of its Affiliates may choose to opt out of The Wetzel Foundation’s disclosure of personal information about them to third parties for direct marketing purposes.  Unless noted at the time of collection, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval.  If you choose to opt-out at any time after granting approval, email: info@thewetzelfoundation.org or write to  .

4. Do Third-Party Content, Links To Third-Party Sites, and/or Third-Party Apps Appear on the Service?

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you.  In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others.  For example, if you “click” on a link, the “click” may take you off the Service onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.

Third-party applications may also be available via the Service.  The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices.  We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others.  These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same.  We are not responsible for these third-party privacy policies or the practices of Third-Party Owners.  Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.  We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

5. Are Ads Served On the Service?

The Service may use third parties such as network advertisers and ad exchanges to serve advertisements on the Service and may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content.  Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited.  Third-party ad serving enables us and/or third parties to target advertisements to you for products and services in which you might be interested.

The Service’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier.  These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you.  You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data.  Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect.  We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice.  The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices.  We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

Some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Privacy Policy.  Further, while we may use a variety of companies to serve advertisements on the Service, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members.  Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads.  Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective.  Additional information is available on the NAI’s web site accessible by the above link.  You may also opt-out of receiving third-party behavioral ads on this site by visiting the Digital Advertising Alliance (“DAA”) web site at http://www.aboutads.info/choices/#completed.  Similar limitations may apply to the DAA opt-out.  We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs.

6. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  The Service may allow you to review, correct or update Personal Information you have provided through the Service’s forms or otherwise, and you may provide registration updates and changes by contacting us at info@thewetzelfoundation.org.   If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for The Wetzel Foundation’s administrative purposes.  You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails.  This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  If you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.”  Subsequent or different subscriptions will be unaffected.  Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail:

7. What About Transfer of Information to the United States?

Our Service is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.  By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

8. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world.  We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent.  In fact, if you are a child under 18 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at privacy@thewetzelfoundation.org.

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information.  We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure .  Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

//End Privacy Policy//

The following third parties that collect information from you on or in connection with our Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

Party	Service	For More Information	Use of Tracking Technologies	Privacy Choices
Google	Google Analytics for Display Advertisers, Ads Preferences Manager, and Google Analytics Opt-out Browser Add-on	http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409http://www.google.com/settings/ads/onweb/?hl=en&sig=ACi0TCg8VN3Fad5_pDOsAS8a4… https://tools.google.com/dlpage/gaoptout/	Yes	See information links in prior column

 

PLEASE NOTE:  We are not responsible for third-party policies or practices.  We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate.  Please contact the applicable third parties regarding their privacy and data security policies and practices.

 

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