CPM (collectively “CPM,” “us” "our," or “we”) is committed to protecting the privacy of our donors, members, viewers, and site visitors (collectively “you,” “your” or “yours”). We value your trust, which means that we will properly collect any personal information that you give us, that we will only use it for the purposes for which it is collected and that we will dispose of it in a secure and timely manner when it is no longer needed.
For purposes of this Policy “personal information” means your name, acknowledgment name, financial information associated with payment for a product or donation, address, telephone number, fax number, email address, and personal preferences you may designate when creating an account profile. Unless there is a specific legal requirement, we do not collect your Social Security Number. Personal information does not include “aggregate” information, which we collect automatically about the use of the Site. “Aggregate” information means collective data that relate to a group or category of website visitors, from which individual identities or characteristics have been removed. This Policy does not restrict or limit our collection and use of aggregate information.
PERSONAL INFORMATION WE COLLECT
We may automatically collect certain information when you use the Site including, without limitation, your Internet Protocol ("IP") address, your operating system, the browser type, the address of a referring site and your activity on the Site. We may also collect information from mobile phone users in a similar manner to optimize the mobile experience. Beyond mobile phone numbers, we may collect mobile screen resolution, device make and manufacturer, and may also collect the device’s unique identifier (in the iPhone’s case, a UDID), and, with your permission, your location. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate only.
We may also receive personal information from users about third parties, and may process this information with other personal information we maintain about you for purposes of fulfilling user requests or providing services. However, such information is not otherwise stored by us, is not re-used in connection with other user accounts, and is not sold to third parties.
The Site may now or in the future allow users to send messages to each other. These messages may be stored for retrieval at later times in order to facilitate user communication.
The Site may now or in the future allow users to make transactions. Data will be securely stored when a transaction is made, including the date and type of purchase made, your credit card number, expiration date, billing address, and CW or security code number.
Even after you remove information from your profile or delete your account or cease use of our services, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. If you post any of your information to a public area of the Site, please be aware that it is no longer “personal information” for purposes of this Policy, and we or anyone else may use such information without restriction. If you provide access to personal or other information, including your email address or name, to other users through the application of any of our privacy controls or other service or Site settings, you hereby acknowledge and agree that we have no control over nor liability for how others may collect, use, or disclose such information.
PURPOSE FOR COLLECTION AND USE OF INFORMATION
Personal information may be collected and used by CPM in connection with the following:
- Delivering the products and services that you have requested;
- Managing your account and provide you with customer support;
- Communicating with you by email, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
- Tailoring your user experience;
- Contest or sweepstakes registration;
- Subscription registration for sites or services which require subscription (such as our e-newsletters, event RSVPs, etc.);
- Requests for donor information;
- E-commerce transactions;
- Donations of any kind;
- Managing our business; and
- Performing functions as otherwise described to you at the time of collection.
In addition, we may use your personal information to:
- Distribute receipts and send you a “thank you” for donations;
- Inform you about upcoming fundraising and other activities you might be interested in;
- Internal analysis, such as research and analytics;
- Reporting to applicable government agencies as required by law;
- Surveys, metrics, and other analytical purposes; and
- Other purposes related to fundraising operations.
Anonymized donor information or donor comments may be used for promotional and fundraising activities. We may ask you during the donation process for your consent to use your name publicly in connection with your donation. You can always refuse consent or let us know that you do not wish to allow us to use your personal information as we describe in this section either by email at CustomerService@KCTS9.org or over the phone when you call to donate.
However, in some circumstances, opting out may prevent you from participating in activities for which personal information is needed, such as contests. If you want to remain completely anonymous you may still take advantage of the wealth of content available on our Site that does not require registration.
CONSENT TO COLLECT PERSONAL INFORMATION
Please note that we may be required to keep your personal information and not delete it (or to keep this information for a certain time, in which case we will comply with a deletion request you may submit to us only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
INFORMATION RETENTION AND DISPOSAL
We may retain personal information for as long as we have a business need for it or as applicable laws, regulations, or government orders require us to retain it. Additionally, the Site and/or our services may enable you (or other users) to save information including information that you have made public or allowed certain users to access or see.
USE OF FINANCIAL INFORMATION
We may require your payment or credit card information in order for our payment vendor or us to process purchases. This includes your name, payment or credit card number, expiration date, billing address, and authentication codes or related information as needed to authorize the charge and complete the transaction. Credit card data is transferred over a Secured Sockets Layer (“SSL”) line if you are using an SSL enabled browser such as Microsoft Internet Explorer, Firefox, Safari, or Google Chrome.
Information from financial transactions made through a CPM Site is stored and served from a secure server. Each page you view on our Site and any financial information you submit is encrypted during transmission between your computer and our websites. In the highly unlikely event that your data is intercepted, the encrypted data may not be usable by a third party. If you send us a check, the financial information on it is entered into a secure check processing system.
We take reasonable measures to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Our Site hosting provider applies security updates routinely and monitors to address known security issues, consistent with industry standards. Our employees with access to the personal information you provide to us through the Site or through any other means are bound by a confidentiality agreement prohibiting the unauthorized disclosure and/or use of your personal information.
Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. To mitigate this risk, you should (a) use secure usernames and passwords and carefully protect them from disclosure; and (b) implement updated internet security and virus protection on your computer. If you suspect that your computer’s security or your information has been compromised or your password accessed or used by an unauthorized third party, please contact us immediately to have your password changed.
If we become aware of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. We agree with the Fair Information Practice Principles of the Federal Trade Commission. Your credit card information will be used only for your intended purpose — be it a donation or a purchase — and nothing else.
CPM has no control over other sites that are linked to ours and we cannot tell you how those sites will treat your personal information. For all online financial transactions you make through organizations that link to our site, be sure to review those organizations’ privacy policies. If you have any questions regarding how the organizations use your personal information, please contact them directly.
CPM will maintain your financial information only as long as necessary to satisfy the purpose for which it was obtained or as legally required. Thereafter it will be destroyed via appropriate, secure methods.
We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Site. We also may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer visitors to our Site to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming, or other activities.
You can prevent or delete our cookies by adapting your browser settings, but this can affect the functionality of the Site. Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. We support and honor “Do Not Track” web browser settings. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features or services we may offer.
AUTHORIZED THIRD PARTIES
We may use third-party service providers to place advertisements to market on sites across the internet. The third-party service providers may collect anonymous information about your visits to one of our Sites and may use that information to target ads for products and services. They may collect web log data or place or recognize a unique cookie on your browser to enable you to receive customized ads. No personally identifiable information is collected in this process. They do not know your name, address, email address, phone number, or any personally identifiable information. We may also share your personal information with our authorized service providers, including advertisers and corporate partners, who perform certain additional services on our behalf. These services may include fulfilling orders, processing credit card payments, providing customer service and marketing assistance, performing business analysis, supporting the functionality of the Site and our services, and supporting surveys, offering additional or related services, and other features offered through or in connection with the Site. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
The NAI (Network Advertising Initiative) allows for the central opting out of all its members’ cookies from a single opt-out page. If you prefer not to receive relevant advertising on web pages or are concerned about third-party cookies served by networks, please visit the Network Advertising Initiative opt-out page: http://optout.networkadvertising.org/?c=1
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
- With the third party or third parties that perform(s) maintenance and operation of our Site on our behalf. These parties are bound by a confidentiality agreement prohibiting the unauthorized disclosure and/or use of your personal information;
- As required by a court or government agency or to respond to a claim by you or a third party;
- As part of a transfer of our assets, for example in the event of a merger, acquisition, corporate change; and
- As you may otherwise request or agree.
CHILDREN’S ONLINE PRIVACY PROTECTION
Some of our Sites may present educational content for children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 ("COPPA"), we will not knowingly request or collect personal information from any child under age 13. If we learn that a user under 13 years of age has submitted personal information through or using one of our Sites we will take reasonable measures to delete such information from our databases and not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). Please visit http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online.
If a child submits stories, artwork, comments, or anything else to us which is to be posted at one of our Sites we will first contact the child's parent or guardian for permission to use the submission. If permission is granted the child will be identified only by first name, age or grade level, city and state. Please remind your child never to provide personal information on this site or any other site without first getting your consent.
Our Site may link to third-party sites and we are not responsible for the content or safety and privacy practices of those sites. Therefore we encourage adults and children to discuss these choices together before giving out any information at these outside sites.
YOUR CALIFORNIA PRIVACY RIGHTS
Effective January 1, 2005, under California Civil Code Section 1798.83, if an individual who is a California resident has provided personal information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s personal information to a third party and knows or should have known that such third party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what personal information was shared and with whom it was shared.
Any request for a disclosure required under this California law should be sent to us via email to our Donor & Audience Relations Manager at CustomerService@KCTS9.org
Please note that under this law, we are not required to respond to a customer’s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email address designated above.
TERMS APPLICABLE TO DATA FROM EU MEMBER COUNTRIES
We are based in and operate from the U.S. In most cases, the personal information we collect is stored and used in the U.S. While we do not direct our services to residents of the EU, it is possible that EU residents may access and use the Site.
If we collect personal information from EU residents in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:
Compliance with Privacy Shield Principles: When handling information from residents of the EU member countries, we strive to comply with the EU-U.S. Privacy Shield Framework principles (Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability) regarding the collection, use and retention of Personal Information from EU member countries. However, our compliance with these principles may be limited (a) to the extent necessary to meet applicable national security, public interest, or law enforcement requirements; or (b) by statute, governmental regulation, or case law. If there is a conflict between the policies set forth below and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
Basis for Collection: As set out above, we collect and process personal information for which you have given your express consent at the time of collection. For example, we collect personal information when you elect to participate in one of our promotions. We also collect and process personal information to order improve our Site, to deliver services and perform obligations under contracts we have with you, and to comply with our own legal obligations.
Sensitive Data: We do not intentionally collect sensitive data, for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to the Site.
Authorized Transfer: We also may disclose personal information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of personal data to third parties.
Data Processors: We may retain third parties to process or analyze personal information we collect from the Site. For example, a Site may be maintained or hosted by a third party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler. These suppliers and other third parties who provide services for us are contractually obligated not to use personal information about you except as we authorize.
Profiling: We may analyze personal information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use personal information about you to detect and reduce fraud and credit risk.
Your Rights: Your rights include: (a) a right to withdraw your consent to the processing of personal information about you to which you have previously given consent; (b) a right to object to processing of personal information about you for the purpose of direct marketing; and (c) a right to have incorrect personal information about you corrected or removed.
If you request to have incorrect personal information removed, we may retain some of your personal information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with the Privacy Shield Principles. Any personal information you have shared publicly with others may continue to be publicly visible on the Site.
You also have the right to obtain a copy of the personal information we have about you, although we reserve the right to charge a fee for this depending on the nature and frequency of your request(s) and our cost to provide the information.
Enforcement and Disputes: In compliance with the EU-U.S. Privacy Shield and the U.S. / Swiss Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may complain to your home data protection authority and can invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Contact details for the EU data protection authorities can be found at .
TELL US WHAT YOU THINK
Your comments and questions help us serve you better and make your visit a pleasant one. If you have any questions or concerns regarding this statement, please send them to our Donor & Audience Relations Manager at CustomerService@KCTS9.org.
Last updated and effective as of: October 2019.