Orthodox Union Web Site Privacy Policy - KGOU
Last updated: October, 2020
Table of Contents
1. INTRODUCTION
This is a Privacy Policy for the Union of Orthodox Jewish Congregations of America (sometimes referred to as “OU,” “we,” “us,” “our”). The Privacy Policy applies to the personal data we collect through:
Your privacy is a priority for the Union of Orthodox Jewish Congregations of America, and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enable your identification (“Personal Data”). This Privacy Policy describes our practices with Personal Data that we (or our service providers) collect from an individual (sometimes referred to as “you” or “your”) through (i) our websites, applications, and our other network-connected products and services that link to this Privacy Policy (collectively, the “Site”), and (ii) through offline means, including by telephone, facsimile, postal mail, personal delivery, or other offline means.
We may provide you with additional information relating to our privacy practices in the context of particular services (such as on a form or invitation that requests personal data).
Under applicable law, OU is considered the “data controller” of the personal data we handle under this Privacy Policy. OU’s contact information appears at the end of this Privacy Policy.
2. PERSONAL DATA THAT WE COLLECT
2.1 Generally
We respect your privacy and will not collect any Personal Data about you except as set forth in this Privacy Policy. You may freely visit our Sites anonymously and without being required to provide us with any Personal Data, and without being required to register. However, certain online and offline services, requests, activities, and features do require that you provide us with some Personal Data, including the following types of Personal Data:
If you choose not to provide information, we may not be able to provide you with requested services, programs, or other OU offerings.
We may combine Personal Data you submit to us with other information collected from you, whether online or offline. We treat the combined information as Personal Data in accordance with this Privacy Policy.
We may also collect or receive Personal Data from third-party sources, such as social media or other third-party integrations, your credit card issuing bank, our payment processing partners, and other third parties.
2.2 Data About Children
We do not knowingly collect Personal Data through the Site from children under the age of 13. We reserve the right to delete any information identified as having been provided through the Site from children under the age of 13.
2.3 Sensitive Information
Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political affiliations or opinions, health information, or criminal background. In those cases where we may request or invite you to provide the foregoing information, we will only do so in accordance with all applicable data protection law requirements. Where you provide us with such information without being requested to do so by OU, we reserve the right (but do not have any obligation) to erase such information at our discretion.
2.4 Social Media
OU engages with its members and other individuals on multiple social media platforms. If you contact us on one of our social media platforms, request service via social media, or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this Privacy Policy, as well as the privacy policy of the social media platform you use.
3. HOW WE USE YOUR PERSONAL DATA
We use Personal Data submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Generally, we use the information you provide to use for the reason for which it was provided. For example, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came. We may also use Personal Data about you as specifically described below:
We may use non-personal information or aggregate information that does not identify an individual without restriction, and we may share such information with third parties.
4. How We SHARE Your Personal Data
We may share your Personal Data only as described in this Privacy Policy or as otherwise described to you at the point of collection.
5. COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES
5.1 As you navigate our Site, certain Traffic Data may be passively collected, meaning it is gathered without you actively providing it. This is done using the following techniques in the following ways:
5.2 How to Control & Delete Cookies
5.2.1 Osano Consent Tool
The Osano Consent Tool https://www.osano.com/ can be utilized to customize your cookie preferences. The tool will record when you have consented to our cookie policy. The tool also specifically controls the marketing, personalization, and analytics cookies set by using our Site. Essential cookies cannot be disabled, nor can the tool be used to block cookies on third-party websites linked from our Site.
5.2.2 Using Your Web Browser
You can also refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.
You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies.
Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.
6. INTEREST BASED ADVERTISING
6.1 We may collect Traffic Data about your online activities on our Site to provide you with advertising about products and services tailored to your individual interests. We also may obtain Traffic Data for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.
6.2 You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our ad partners’ targeted advertising services to show you our ads on other websites based on your prior visits to our Site and other online activity. The interest-based data collected about you is linked to your computer or device. Our advertising partners may use the information that they receive to provide advertising services to the OU or to third parties using the same advertising network.
6.3 You may opt-out of receiving interest-based advertisements by disabling marketing cookies using the Osano Consent Tool https://www.osano.com/ on our Site.
6.4 Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at http://www.networkadvertising.org/choices.
6.5 Opting-out does not mean that you will stop receiving ads from us. It means that you still stop receiving ads from us that have been targeted to you based on your visits and browsing activity across websites over time.
6.6 Do Not Track
Our Site currently does not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.
We take what we believe to be reasonable steps to protect the Personal Data collected by us from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or Internet or e-mail transmission is ever fully secure, error-free, or “hacker proof.” Therefore, you should take special care in deciding what information you provide to us. Please keep this in mind when disclosing any Personal Data.
In the event that we believe the security of your personal data in our possession or control may have been compromised, we may seek to notify you of that development. If we believe a notification is appropriate and we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the United States postal service to notify you in this situation, please contact us as described below.
Please visit your mobile device manufacturer’s website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.
8. DATA RETENTION
We generally retain Personal Data for so long as it may be relevant to the purposes above, or for longer when required by law. To dispose of Personal Data, we may anonymize it, delete it, or take other appropriate steps. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
9. INTERNATIONAL TRANSFERS OF PERSONAL DATA
OU is based in the United States. The recipients of the Personal Data disclosures described in the “How We Share Your Personal Data” Section above may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate. Whenever we transfer personal data outside of the European Economic Area (“EEA”) or the UK, we take legally required steps to make sure that the appropriate safeguards are in place to protect your Personal Data.
10. EU CONTROLLER
European Union data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
OU may act as either a data controller or data processor in connection with your Personal Data, depending on the circumstances. However, under applicable law, OU is considered the “data controller” of the Personal Data we handle under this Privacy Policy. OU’s contact information appears at the end of this Privacy Policy.
11. OUR LEGAL BASES FOR HANDLING YOUR PERSONAL DATA
The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Data. To the extent those laws apply, our lawful bases for processing your Personal Data are:
We may also process Personal Data for the same legitimate interests of our customers, business partners, and related organizations.
12. YOUR RIGHTS AND CHOICES
12.1 Opt Out From Direct Electronic Communications
Where it is in accordance with your preferences, OU may send you direct electronic communications, such as through email or text message, regarding donation opportunities or events or programs that might be of interest to you. You may “opt out” of receiving these electronic communications by clicking on the opt-out link within the e-mail you receive, or by sending an e-mail to ouinternet@ou.org indicating which communications you no longer wish to receive. Please note that if you opt out of receiving promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to logistical information for an event for which you are registered or regarding changes to this Policy).
12.2 Opt Out From Cookie-Related Processing and Interest Based Advertising
You can opt out from certain cookie-related processing and interest-based advertising as described in Sections 5 and 6 of this Policy.
12.3 How You Can Access, Update, Correct, or Delete Your Personal Data
If you would like to submit a data access, correction, restriction, or deletion request, you can do so by contacting us at ouinternet@ou.org and we will process such request with respect to any Personal Data that we are able to link to you individually based on the information that you can provide to us. These rights and options that you have with respect to Personal Data are subject to limitations and exceptions under applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first at ouinternet@ou.org and we will try to resolve your concerns.
12.4 Notice to California Residents
Subject to certain limits under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with: (1) a list of certain categories of Personal Data that we have disclosed to certain types of third parties for their direct marketing purposes during the immediately preceding calendar year; and (2) the identity of the third parties that received certain Personal Data from us for their direct marketing purposes during that calendar year. To do so, please contact use at ouinternet@ou.org.
The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
13. LINKS TO THIRD PARTY SITES
The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. OU is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. OU does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.
14. USE OF THIRD PARTY SERVICES
If you access this Site or any of OU’s services through a third party platform, product, service, or application (“Third Party Services”), the protection of your privacy by the Third Party Service provider is governed by the Privacy Policy of that Third Party. Your use of any Third Party Services is subject to that Third Party’s own rules, policies, and practices, and not those of OU. These Third Parties have separate and independent rules and privacy policies, and therefore OU has no responsibility or liability for the Services, privacy policies, or business practices employed by any Third Party that OU does not own, control, manage, or employ, and expressly disclaims any liability related to the use of such Third Party Services. Please take the time to read and review the privacy policy of any such Third Party, as it is solely your obligation to review and understand the privacy practices and policies of these Third Parties.
15. UPDATES AND CHANGES TO OUR PRIVACY POLICY
The business and operations of OU may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy to reflect changes in the law, our data handling practices, or the features of our services, websites, and apps. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time. Modifications to this Privacy Policy will be posted at http://www.ou.org with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances, OU may, but need not, provide you with additional notice of such modifications, such as via e-mail. Modifications will be effective 30 days following the “Updated” date, or such other date as communicated in any other notice to you. Where required by applicable law, we will apply changes only with your consent.
Please review this Privacy Policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued participation in our programs, services, and events following the effectiveness of any modifications to this Privacy Policy constitutes your acceptance of those modifications. If any modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise utilizing OU’s website, as well as its programs, services, and events.
16. HOW TO CONTACT US
If you have any questions regarding this Policy or the use of your Personal Data under this Policy, you can contact us at:
Orthodox Union
11 Broadway
New York, NY 10004
ouinternet@ou.org
