Last updated: May 2018
WHAT DATA WE COLLECT Our Visitors/Users voluntarily provide us with data, including data that can be used to identify, either directly or indirectly, an individual (“Personal Data”) when they access our Websites and Portals, sign up for our website newsletters, submit questions or comments on our Contact Us form, and participate in our blogs or surveys. • Data Provided by Visitors/Users. • Name, address, email and telephone number (collectively "User Information") • Information submitted as a result of completing forms on our websites, participating in a blog or survey, subscribing to our website newsletters, commenting on or downloading information from our Websites or Portals. • Technical information such as IP addresses, browser-type, device-type, internet service provider, referring or exiting pages, operating system, date and time stamp or clickstream data • Any other information shared with us directly or indirectly through a user’s use of our Websites or Portals Aggregate Information. To the extent permitted by applicable law, our websites may use, process, transfer and store customer and user data in an anonymous (or pseudonymous) and aggregated manner. We may combine such data with other information collected, including information from third-party sources. By using our Websites and Portals, our Visitors/Users agree that we are permitted to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through our Websites and Portals for benchmarking, analytics, metrics, research, reporting, machine learning and other legitimate non-profit organization purposes.
Automated Decisions. To the extent permitted by applicable law, our Websites and Portals may collect data in an automated manner and make and use automated decisions about Visitors/Users, including using machine learning algorithms, in order to provide or optimize our Websites and Portals, for security or analytics purposes, to display notices based on individual preferences and for any other lawful non-profit organization purpose.
WHY WE USE DATA Our Websites and Portals process data, including Personal Data, for a variety of purposes, such as: • With visitor/user consent, e.g., to receive website newsletters and other requested information • Where the processing is necessary to facilitate backing-up and restoring data, for archiving purposes, or to provide technical support • Where necessary to comply with law Where the processing is necessary for the purposes of our legitimate interests, taking into account individual interests. Our legitimate interests include providing the Websites and Portals, internal record-keeping and administrative purposes and to operate, maintain and improve the Websites and Portals
Cookies. Cookies are small text files placed on a computer by a web server when browsing online and are used to store user preference data so that a web server doesn't have to repeatedly request this information. A user may block cookies by activating the settings on the browser that blocks all or some cookies. However, if a user blocks all cookies (including strictly necessary cookies), a user may not be able to access all or parts of our Websites and Portals. We use the following cookies:
Strictly Necessary Cookies. These cookies are required for the operation of our Websites and Portals. They include, for example, cookies that enable Visitors/Users to log-in to secure areas of our Websites and Portals.
Analytical and Performance Cookies. These cookies allow us to recognize and count the number of users visiting our Websites and Portals and see how those users navigate our Websites and Portals. This helps us to improve our Websites and Portals.
Functionality Cookies. These cookies recognize a user that returns to our Websites and Portals. This enables us to personalize our content, greet the user by name and remember preferences, for example, choice of language or region.
Targeting Cookies. These cookies record visits to our Websites and Portals and the links followed. We use this information to improve our Websites and Portals and ensure the information displayed is relevant to users.
Web Beacons. A web beacon is a small pixel incorporated into a web page or email to keep track of activity on the page or email. A web beacon helps us better manage the content of our Websites by informing us of what content is effective.
Cross-device Tracking. We may use third-party cross-device tracking. For example, a user may use multiple browsers on a single device, or use various devices, which can result in the customer having multiple accounts or profiles across various devices. Cross-device tracking may be used to connect these various accounts or profiles and the corresponding data from different devices.
GLOBAL DATA MANAGEMENT Our Websites and Portals are designed to serve Southern California, but reach a global audience. Please note that by using our Websites and Portals or by providing Personal Data to us, Visitors/Users acknowledge and agree that Personal Data may be sent to and processed in countries outside your country of residence, including the U.S. For individuals residing in the European Economic Area (“EEA”), and for Personal Data subject to European data protection laws, this includes transfers outside of the EEA. Some of these countries may not have data protection laws that provide an equivalent level of data protection as the laws in your country of residence, however, we will take steps to ensure Personal Data is handled in accordance with the EU-U.S. and Swiss Privacy Shield Frameworks and/or the General Data Protection Regulation, as applicable. WHEN AND WHY WE SHARE YOUR PERSONAL DATA We do not and will not share, rent or sell Personal Data to marketers or other vendors. We may share data, including Personal Data, in the following circumstances:
Service Providers. Our Websites and Portals may share data, including Personal Data, with our contracted third-party service providers in order to provide and improve our Websites and Portals or to administer surveys and user analysis to better understand user needs and preferences. These third-parties include delivery services, analytics providers, social media companies, email distributors, marketing automation partners, customer survey companies, data storage and hosting partners, IT specialists and product developers.
Legal Purposes. Our Websites and Portals may share data, including Personal Data, as necessary to comply with applicable law, court orders, governmental agencies, for the administration of justice, to protect vital interests, to protect the security or integrity of our Websites and Portals, or to take precautions against legal liability.
Transfer. In the event of a merger, consolidation, or acquisition of all, substantially all or a portion of our Websites and Portals, we may share data, including Personal Data. Visitors/Users acknowledge and agree that data, including Personal Data that our Websites and Portals have collected, may be securely shared, disclosed and transferred to such successor or assignee.
RETENTION OF DATA We may retain data, including Personal Data, for as long as necessary or as needed for other lawful purposes. We may retain anonymized or pseudonymized, aggregated data indefinitely or to the extent permitted under applicable law.
YOUR RIGHTS Subject to applicable data protection laws, Visitors/Users have the following rights with respect to our Websites and Portals handling of Personal Data: Access. The right to access Personal Data held by our Websites and Portals.
Opt-Out. The right to object to certain processing of Personal Data.
Rectification. The right to request correction of Personal Data that is incomplete, incorrect, unnecessary or outdated.
Right to be Forgotten. The right to request erasure of all Personal Data that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. Our Websites and Portals will do everything possible to erase Personal Data if a Visitor/User so requests. However, our Websites and Portals will not be able to erase all Personal Data if it is technically impossible due to limitations of existing technology or for legal reasons.
Data Protection Contact. The right to contact the relevant data protection regulator regarding our Websites and Portals handling of Personal Data. To exercise any of the above listed rights, email email@example.com,
CALIFORNIA PRIVACY CODE California Civil Code Section §1798.83 permits users of our Websites and Portals that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share, rent or sell Personal Data to any third parties for their direct marketing purposes.
OTHER INFORMATION Our Websites and Portals have reasonable and appropriate technical and organizational security measures in place to protect against unauthorized processing, loss, misuse and alteration of Personal Data under its control. Please be advised that we cannot, and we do not believe that anyone can, genuinely guarantee or warrant absolute security of Personal Data disclosed or transmitted via the Internet to us or a third-party. As a result, absent our Websites and Portals' gross negligence, Visitors/Users agree to not hold our Websites and Portals responsible for the theft, destruction, loss, damage or inadvertent disclosure of Personal Data or other data provided to our Websites and Portals.
We do not knowingly collect or solicit personally identifiable information from anyone under the age of 13. If you are under the age of 13, please do not provide us with any Personal Information. If we learn that we have inadvertently obtained personally identifiable information from a minor under the age of 13, we will delete that information as soon as possible. If you believe that a minor under the age of 13 has submitted Personal Information to us, please contact us using the contact information listed below.
LINKING The Websites and Portals may contain links to third-party websites that our Websites and Portals do not control or maintain. Our Websites and Portals are not responsible for the privacy practices employed by these third-party websites. Our Websites and Portals encourage users to read the privacy statements of such other websites before submitting any Personal Data.