Privacy Policy

I. OUR COMMITMENT TO PRIVACY

Thornwell is committed to respecting and protecting your privacy. Thornwell has developed this Privacy Policy (“Privacy Policy”) to help to protect your personal information. The Privacy Policy discloses the information we gather on www.thornwell.org (the “Site”), as well as ways in which we process and, share such information and how you can correct or change such information. Except where otherwise expressly indicated herein or on the Site, this Privacy Policy applies only to information collected on the Site and does not apply to information collected outside of the Site.

This Privacy Policy addresses our privacy practices relating to the general use of our Site by anyone who visits, browses or otherwise uses the Site (collectively, “You”). Before submitting information to the Site, please read this Privacy Policy. By visiting the Site, submitting information or making a donation you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and/or processed in the United States. If you do not agree to this Privacy Policy, please do not use the Site.

II. THE INFORMATION WE COLLECT

The Thornwell Site is intended to provide information and a positive donor experience without requiring you to submit any more Personally Identifiable Information (“PII”) than is necessary to use the Site effectively. We do not require you to register or submit PII in order to visit the Site. Some activities on the Site can be performed without providing PII. When we ask for PII to, for instance, make a donation, we will not require anyone to disclose more PII than we believe is reasonably necessary to participate in the activity. We collect the following categories of information from you.

A. Personally Identifiable Information Collected from Individuals

We may receive and store any information you enter on the Site or provide to us in any other way through or via the Site that would allow us to identify you personally or contact you. The PII you provide to us only will be used by Thornwell in accordance with this Privacy Policy. Examples of PII we may collect from you:

      • PII you provide about yourself when you send us an email or Contact Us.
      • PII you provide about yourself anywhere on the Site. For example, if you use any third party platforms, such as Facebook or Twitter, to share information about yourself on the Site, we collect that information.

You can choose not to provide us with certain PII, but then you may not be able to take advantage of all of the services offered on the Site.

B. Passive Gathering of Information Electronically

  1. Cookies

During the course of any visit to the Site, the pages you see, along with something called “cookies,” are downloaded to your computer. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. These cookies do not contain or collect any PII, but they do enable us to provide features such as personalization. Most web browsers automatically accept cookies, but you usually can change your browser to limit or prevent cookies. Cookies in themselves do not personally identify the individual user, but rather the computer that is being used to access the Site. You may have the opportunity to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently. If you set your browser to not accept cookies, it may result in certain personalized services not being provided to you when you use that computer.

2. Web Beacons

A web beacon is a transparent image file. Web beacons enable Thornwell to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. They may be used in association with cookies to understand how visitors interact with the pages and content on the pages of the Site.

Web beacons also may be used to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon that then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked.

Thornwell does not use web beacons to collect or otherwise record any type of PII provided by or about any User.

We may automatically collect Site usage information, such as the numbers and frequency of users to the Site, pages visited and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that is intended to identify you personally. Aggregate information generally is collected through the use of cookies and web beacons as discussed above. This aggregate information helps Thornwell determine general usage patterns and modify the Site in order to improve your experience.

III. HOW WE USE INFORMATION

When you provide us with your PII, we may use such information for a number of purposes, including:

    • To facilitate communication between Thornwell and you including, without limitation, responding to your questions or comments or sending emails concerning our programs;
    • To process donations.

IV. DISCLOSURE OF INFORMATION TO THIRD PARTIES

Thornwell may give, share, sell or trade your PII to or with any third parties under the following circumstances:

Fulfillment of Services

We may retain other companies and individuals to perform certain functions on our behalf. Examples include, but are not limited to, companies and individuals who: (i) process donations; (ii) conduct surveys; (iii) provide customer support, web hosting, internet service, and data analysis. Such third parties may be provided with access to PII needed to perform their functions but may not use such information for any other purpose.

Compliance with Law and Fraud Protection

We may disclose any information, including, without limitation, PII, that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information, including, without limitation, PII, with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property or safety of Thornwell, its employees or residents or others. Thornwell reserves the right to disclose PII for a user who we believe is in violation of our Privacy Policy or other terms of service as posted on the Site, even without a subpoena, warrant, court order or other governmental request.

V. CREDIT CARD INFORMATION

Thornwell does not collect, store or otherwise maintain any credit card information from individuals who make a donation through the Site. Donations, including information associated with your credit card, are processed by Network for Good. The privacy policy for Network for Good states in part:

Donations through the Network for Good giving system are made to a nonprofit, donor advised fund, which will distribute your donation. Network for Good respects and protects your privacy and will never sell, trade or rent your personal information to other individuals or companies. The information that you provide is used only to complete your donation.

Network for Good uses industry-leading Secure Sockets Layer (SSL) technology to keep your personal information as secure as possible and protect against the loss, misuse and alteration of the information under our control. Network for Good helps to protect your information by working with partners that provide a secure and safe environment for credit card donations. All information is stored in a secure database.

Thornwell previously used Greater Giving. The privacy policy for Greater Giving states in part:

At Greater Giving, your privacy, and that of your donors is of utmost importance to us. We will never sell your information, or release it without your permission – except to deliver services for which you’ve contracted with us. For complete details, please read the complete Greater Giving Privacy Policy.

Greater Giving is in compliance with the Payment Card Industry (PCI) Data Security Standard. Since we process credit card transactions for our clients and their donors, ensuring the privacy and security of your information is an integral part of Greater Giving’s services and is the top priority for our operations.

VI. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

A. Data Security

We maintain a variety of commercially reasonable safeguards designed to protect your PII from unauthorized access and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems.

You should be aware, however, that Thornwell has no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites from our Site. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

We want you to feel confident using the Site. However, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the email address(es) we have on record for you. You should also take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission’s Web site for information about how to protect yourself against identity theft.

B. Children

The Site is not intended for persons under the age of 13. Thornwell does not knowingly collect information from any person under the age of 13. If Thornwell becomes aware that any person submitting information to the Site is under the age of 13, we will attempt to delete the account and any related information as soon as possible. We require that only persons 13 years of age or older use the Site. By using the Site, you hereby represent that you are at least 13 years old.

C. Changes to this Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices. When we post changes to this Privacy Policy, we will revise the updated date at the top of this Privacy Policy. If we make any material changes to our Privacy Policy, we only will notify You by sending an email to the email address(s) you provided to us, and by prominently posting notice of the changes on the Site. We will give you an opportunity to opt-out of any materially changed Privacy Policy or alternatively, delete the information you have provided to us. We recommend that you check the Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

D. Contacting Us

If you have any questions about Thornwell generally, this Privacy Policy or the Site, please feel free to contact us either by sending an email to info@thornwell.org or through the Contact Us feature.

E. Users From Outside the United States

The Site is hosted in the United States and is governed by United States law. If you are visiting the Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

F. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

Effective January 15, 2014

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