Near East Foundation Privacy Policy

Updated: May 25.2018

Respecting your privacy

We recognize that visitors to our site may be concerned about the information they provide to us, and how we treat that information. The Near East Foundation is committed to protecting the privacy of our online visitors, subscribers, and donors. At our site, we do not collect personally identifiable information unless you provide it to us voluntarily and knowingly. This means we do not require you to register or provide information to us in order to view our site.

This Privacy Policy applies to Personal Information that is Processed by us in the course of our business, including on our websites (each a “Site” or “Sites”), our mobile applications (“App”), forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of the Near East Foundation, (the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of the Near East Foundation are expected to protect that data by adherence to this Privacy Policy.

The Near East Foundation gathers personally identifiable information, such as names, addresses, zip/postal codes, e-mail addresses, etc., when voluntarily submitted by a visitor. We collect personal information for web transactions, newsletters and emails, mailings, and general inquiries. We only use this information for the intended services. For some services, we may request information about background, occupation, demographics, and interests. This information is housed in our donor database, securely hosted by Blackbaud Solutions. You can access their privacy policy and commitment to GDPR compliance here.

Information that We Share with Third Parties

We will not share any Personal Information that we have collected from or regarding you except as described below:

I. Information Shared with Our Services Providers.

We may engage Third-Party services providers to work with us to administer and provide the Services. These Third-Party services providers have access to your Personal Information only for the purpose of performing services on our behalf and, in the case of payment processors, human resources software providers, email subscription services, messaging services, feedback and survey services, data analysis services, and publishing software providers, are expressly obligated not to disclose or use your Personal Information for any other purpose. We may share your Personal Information and any necessary payment information, such as credit card number, expiration date and billing address, with our payment processing services providers in order to complete transactions that are initiated through the Services.

II. Information Shared with other Third Parties.

We may share anonymized or aggregated data we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends and other analysis that we create based on the information we receive from you and other Users.

III. Information Shared with Web Analytics Service Providers.

We use web and email analytics service providers to gather information about how our Users interact with our Services. This information is available to NEF and third-party application service providers involved in the operation of this site. We require all third-party application service-providers to hold personal information in strict confidence. While we believe these companies are upstanding and will treat your personal information responsibly, we do not own or control them.

Third Parties include:

Google. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. You can also choose not to be included in Google Analytics here.

Facebook. We may use certain tools offered by Facebook, Inc. (“Facebook”) that enable it to collect or receive information about actions users take on: (a) our Site and elsewhere on the intZernet through use of Cookies, Web Beacons and other storage technologies; or (b) our App and other mobile applications, in order to provide measurement services, targeted ads and other services. For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php.

Basecamp. We use Basecamp to manage the NEF website to ensure a positive user experience. Basecamp’s privacy policy can be accessed at: https://basecamp.com/about/policies/privacy/privacy-shield

Blackbaud Solutions. We use Blackbaud Solutions as our processor for data received through the website in the form of voluntary information provided when making a donation or signing up to NEF’s mailing list. For more information about Blackbaud Solutions and their privacy policy, visit: https://www.blackbaud.com/privacy-policy.aspx

Policy on Information Disclosure

We collect personal information to deliver the services you request and to understand our audience so that we can better meet their needs. We do not share, sell, trade, or rent any personal information. We may compile aggregate statistics and provide them to third parties, but we do not include information that identifies individual website users.

I. Anonymized and Aggregated Information Use.

Near East Foundation may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within the Near East Foundation and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

We may collect information about computer hardware and software such as IP addresses, browser types, domain names, access times, and the referring websites that visitors use to access web pages. We use this information to maintain the quality of the service and to collect general statistics.

We may save personal information to comply with federal and state policies, but we do not disclose this information to third parties or government agencies unless state or federal law requires us to do so or exigent circumstances require us to protect the safety of our users or the public.

Exceptions to this policy: The Near East Foundation may disclose personal information if compelled by law or a regulating authority.

Your Choices: Voluntary Consent and Opting Out
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.

I. Opt-Out of our Mailings.

We may periodically send you newsletters and e-mails that directly share news about and promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or reaching out to the Near East Foundation at info@neareast.org. We do need to send you certain communications regarding the Services and you will not be able to opt-out of those communications. These include communications regarding updates to our Terms or this Privacy Policy or information about billing.

II. Modifying Your Information.

If you would like to update your information to OPT OUT of receiving correspondence from NEF at any point in time, please let us know by sending your request via email to info@neareast.org, via phone at (315) 428-8670, or via mail to Near East Foundation, 110 Fayette Street, Suite 710, Syracuse, NY 13202.

III. Cookies and Interest-Based Advertising.

You may stop or restrict the placement of Cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that Cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at ww.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu/, www.aboutads.info/choices/

To be clear, whether you are using our opt-out or an online industry opt-out, these Cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Access to Your Information
Although we make good faith efforts to provide you with access to your Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights; where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question; or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Credit Card Security
Protecting your credit card information is of the utmost importance to the Near East Foundation. When you donate to NEF online, the transaction is processed by a reputable service provider (Blackbaud Merchant Services). Your credit card information is secured by BMS and is not stored. Your credit card information is used only for a one-time transaction unless you elect to make a recurring donation. To make a credit card donation by phone, please call 315-428-8670. If you prefer to give by mail, please send your check to Near East Foundation, 110 Fayette Street, Suite 710, Syracuse, NY 13202.

I. Blackbaud Merchant Services’ Security Measures. Blackbaud Marchant Services is used to process your donation on behalf of the Near East Foundation. To protect your credit card information, when used according to manufacturer’s instructions, Blackbaud: (1) encrypts personal and credit card information during all transactions, and (2) sends an automated confirmation email for all transactions. For their full policy on being PCI compliant, visit: https://www.blackbaud.com/security/pci-compliance

Links to Other Sites
Our Services may contain links to websites and services that are owned or operated by Third Parties. Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Information Collected Using Cookies and other Web Technologies
Like many website owners and operators, we use automated data collection tools such as Cookies, Web Beacons, Log Data, and Social Media Widgets (collectively “Web Technologies”) to collect certain information

I. “Cookies”

are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some Third-Party services providers that we engage (including Third-Party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such Third-Parties.

II. “Web Beacons”

(also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

III. “Log Data”

means certain information about how a person uses our Services, including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, MAC address, IMEI, other device identifiers the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage Third-Parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.

IV. “Social Media Widgets”

Social Media Widgets are social media features such as Facebook Share and Twitter Follow. These features may collect your IP address, which page you are visiting on our Site, and may set a Cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

We use Web Technologies generally for the following purposes:

I. Operationally Necessary.

We may use Cookies, Web Beacons, Log Data or other similar technologies that are necessary to the operation of our Sites, Services, applications, and tools. This includes technologies that allow you access to our Sites, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

II. Performance Related

We may use Web Technologies to assess the performance of our Sites, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools;

III. Functionality Related

We may use Web Technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;

IV. Advertising or Targeting Related

We may use first-party or Third-Party Cookies and Web Beacons to deliver content, including ads relevant to your interests, on our sites or on Third-Party sites and to track incoming traffic from paid external campaigns. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

Information Sent by Your Mobile Device
We collect certain information that your mobile device sends when you use our Services, like a device identifier, MAC address, IMEI, user settings and the operating system of your device, as well as information about your use of our Services.

International Transfer
Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.

Information From Other Sources
We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to the Near East Foundation and to enhance our ability to provide you with information about our business, products, and Services.

International Users
By using the Site, Near East Foundation will transfer data to the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of New York and the adjudication of any disputes arising in connection with Near East Foundation or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Privacy Policy.

Revisions to the Privacy Policy
We may revise this privacy policy at any time in response to changes in the law or other factors. We encourage you to periodically visit this page to review the most current policy.

Questions and Concerns

If you have any questions about NEF’s Privacy Policy, the practices of our site, or your interaction with our site, please contact us:

Near East Foundation
110 Fayette Street, Suite 710
Syracuse, NY 13202
Tel: (315) 428-8670

Or e-mail us at info@neareast.org

Definitions

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Near East Foundation or Near East Foundation’s Agents.

Respecting your privacy

Welcome to www.neareast.org (“Site”), a website provided on behalf of the Near East Foundation (“NEF,” “we,” “us,” and “our”).

These Terms and Conditions of Service (“Terms and Conditions”) govern your use of the Site. You should carefully read the Terms and Conditions before using the Site. You should also regularly review these Terms and Conditions as we may change them from time to time. You can review the most current version of the Terms and Conditions at any time through the link at the bottom of any page of this Site

I. Your use constitutes acceptance of these Terms and Conditions and our Privacy Policy.

II. NEF reserves the right to change these Terms and Conditions at any time by posting changes online. Your continued use of this site after changes are posted constitutes your acceptance of these Terms and Conditions as modified. Accordingly, you may wish to visit this page from time to time to review the then current Terms and Conditions.

III. You agree to use this site only for lawful purposes, and in a manner which does not infringe the rights of, or restrict or inhibit the use and enjoyment of the site by, any third party. If NEF reasonably determines that you have violated or are likely to violate the foregoing prohibitions, NEF may take any action it reasonably deems necessary to cure or prevent the violation, including without limitation, the immediate removal from this website of the related materials.

IV. This site and the information, names, images, pictures, and logos regarding or relating to NEF are provided “as is” without any representation or endorsement made and without warranty of any kind, whether express or implied. In no event will NEF be liable for any damages including, without limitation, indirect or consequential damages, or any damages whatsoever arising from the use or in connection with such use or loss of use of the site, whether in contract or in negligence or any other theory of liability.

V. This site and the information, names, images, pictures, and logos regarding or relating to NEF are provided “as is” without any representation or endorsement made and without warranty of any kind, whether express or implied. In no event will NEF be liable for any damages including, without limitation, indirect or consequential damages, or any damages whatsoever arising from the use or in connection with such use or loss of use of the site, whether in contract or in negligence or any other theory of liability.

VI. Copyright restrictions:

— Commercial use or publication of all or any items displayed on the site is strictly prohibited without prior authorization from NEF. Nothing contained herein shall be construed as conferring any license by NEF to use any item displayed.

— Documents may be copied for personal use only on the condition that copyright and source indications are also copied, no modifications are made and the document is copied entirely. However, some documents and photos may have been published on this site with the permission of the relevant copyright owners (who are not NEF). All rights in these documents are reserved to their owners, and permission to copy or otherwise exploit them must be requested and obtained directly from the copyright owners (the sources are indicated within these documents/photographs).

VIII. Any communication or material that you transmit to, or post on, any public area of the site including any data, questions, comments, suggestions, or the like, is, and will be treated as, non-confidential and non-proprietary information.

IX. If there is any conflict between these general Terms and Conditions and any rules and/or specific Terms and Conditions appearing on this site relating to specific material then the latter shall prevail.

X. This website is administered by NEF from its offices in Syracuse, NY. These Terms and Conditions shall be governed by and construed in accordance with the laws of the New York. Any disputes relating to the use of this website shall be subject to the exclusive jurisdiction of the Courts of the New York or the United States District Court of New York.

XI. If these Terms and Conditions are not accepted in full, the use of this site must be terminated immediately.

We are grateful for your support. If you have any questions about NEF’s Privacy Policy and Terms and Conditions, the practices of our site, or your interaction with our site, please contact us:

Near East Foundation
110 Fayette Street, Suite 710
Syracuse, NY 13202
Tel: (315) 428-8670

Or e-mail us at info@neareast.org