Effective Date: May 6, 2022
If you are a data subject in the European Economic Area, please see the “Additional Disclosures for People in the European Economic Area” sections respectively. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
- Information Collection.
- Information You Provide.
We collect information about you when you interact with the Sites and voluntarily provide information to us, including:
- Contact Data, including your first and last name, email address, postal address, and phone number.
- Demographic Data, including your age, gender, and country.
- Donation Data, including your payment instrument number (such as a credit or debit card number), expiration date, security code as necessary to process your payments, and donation amounts.
- Medical Information, including next of Kin, prescriptions, doctor’s notes for prescriptions, and medical conditions.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
- Information Collected Automatically.
In addition, we automatically collect information when you use the Sites.
- Service Use Data, including data about pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
We use various tracking technologies to automatically collect information when you use the Sites, including the following:
- Log Files, which are files that record events that occur in connection with your use of the Sites.
- Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Sites. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Sites.
- Information from Other Sources.
We also collect information from other sources, including:
- Social networks when you engage with our content, reference our Sites, or grant us permission to access information from the social networks.
- Partners that offer co-branded services or engage in joint marketing activities, including local Chabad houses throughout the world.
- Publicly-available sources, including data in the public domain.
- Use of Information.
We may use the information we collect for any of the following purposes:
- Operate and manage our Sites.
- Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service.
- Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Preventing and addressing fraud, breach of policies or terms, and threats or harm.
- Monitoring and analysing trends, usage, and activities.
- Conducting raffles that you have voluntarily entered through donating or otherwise.
- Conducting research, including focus groups and surveys.
- Improving the Service or other Chabad websites, apps, marketing efforts, products and services.
- Developing and sending you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
- Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
- Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
- Service Providers. We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support.
- Grant-Making Organizations. We are a non-profit organization that relies on funding from organizations that provide grant funding and we may need to share certain information collected in the process of applying for a respective grant.
- Partners. We share information with our partners in connection with offering our services including raffles and the ability to sign up for Chabad arranged trips.
- Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Sites, or anyone else.
- Consent. We share information with notice to you and your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
- Social Media and Technology Integrations. We offer parts of our Sites through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Sites. Some examples include:
- Links. Our Sites includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Sites that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
- Your Rights and Choices.
- Tracking Technology Choices.
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Our Sites do not currently take any actions when it receives a “Do Not Track” request. For more information on “Do Not Track,” including how to turn on “Do Not Track,” please visit http://www.allaboutdnt.com.
- App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
Please be aware that if you disable or remove tracking technologies some parts of the Sites may not function correctly.
- Analytics and Interest-Based Advertising.
We use analytics services, such as Google Analytics, to help us understand how users access and use the Sites. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Sites (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”)
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
- Email Communications.
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your transactions, servicing, or Chabad’s ongoing business relations. Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
The Sites are intended for a general audience, and is not directed at children under (13) years of age.
- Data Security.
We implement and maintain reasonable security measures designed to prevent unauthorized intrusion to the Sites and the alteration, acquisition or misuse of personal information, however, we will not be responsible for loss, corruption or unauthorized acquisition or misuse of personal information that you provide through the Sites that is stored by us, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse. We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.
- International Transfer.
- Contact Us.
719 Eastern Parkway, Suite 1
Brooklyn, NY 11213
- Additional Disclosures for People in the European Economic Area
Data protection laws in the European Economic Area (“EEA”) distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Chabad acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.
- Lawful Basis for Processing.
Our lawful bases for processing personal data include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
- Your Data Subject Rights.
If you are a data subject in the EEA, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. Please refer to the section entitled “Contact Us” for contact information to send us any questions.