1. INTRODUCTION

This is a Privacy Policy for Agudath Israel of Maryland and the Mid-Atlantic Region (sometimes referred to as “Agudah,” “The Agudah”,“Agudah Maryland,” “we,” “us,” “our”).  The Privacy Policy applies to the personal data we collect through:

• Official AIA websites and apps that link to this Privacy Policy (collectively, the “Sites”) including but not limited to:
• agudathisrael-md.org, agudah.org, agudahconvention.org, theagudah.org, knowus.org, agudaharchive.org, dosyiddishvort.org, dafyomidirectory.org, amechadunited.org, yahalomunited.org, vaadhatzalahrescue.org, yeshivosbychoice.org, yeshivasummit.org, agudahyarcheikallah.org
• Agudah’s handling of personal data of individuals located outside the United States for our marketing and fundraising

Your privacy is a priority for the Agudah, and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enable your identification (“Personal Data”). This Privacy Policy describes our practices with Personal Data that we (or our service providers) collect from an individual (sometimes referred to as “you” or “your”) through (i) our websites, applications, and our other network-connected products and services that link to this Privacy Policy (collectively, the “Site”), and (ii) through offline means, including by telephone, facsimile, postal mail, personal delivery, or other offline means.

We may provide you with additional information relating to our privacy practices in the context of particular services (such as on a form or invitation that requests personal data).

Under applicable law, the Agudah is considered the “data controller” of the personal data we handle under this Privacy Policy.  The Agudah’s contact information appears at the end of this Privacy Policy.

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2. PERSONAL DATA THAT WE COLLECT

2.1 Generally

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We respect your privacy and will not collect any Personal Data about you except as set forth in this Privacy Policy. You may freely visit our Sites anonymously, without being required to provide us with any Personal Data, and without being required to register. However, certain online and offline services, requests, activities, and features do require that you provide us with some Personal Data, including the following types of Personal Data:

• contact information, such as name, postal address, telephone number, and email address;
• parent information, such as name, postal address, telephone number, and email address;
• registration information;
• information about your participation in events or activities in which the Agudah is involved;
• payment information, such as credit card numbers and expiration dates;
• photographs taken at Agudah events or activities or shared on social media by Agudah participants or partners;
• your mobile device information (e.g., device model, operating system version, device date and time, unique device identifiers, mobile network information);
• how you use our sites and mobile applications, search terms, pages you visit on our websites, and application performance;
• geolocation information;
• user content posted by you in forums, blog posts, comments, or message boards;
• records of your communications and transactions with us;
• information about religious practice and community participation;
• when you register for an event or activity, we will ask for your name and contact information, and we may also ask for other information related to dietary restrictions, special facilities or equipment that you may require, health or medical information such as allergies and diagnosis, and emergency contact information;
• insurance information; and
• through your use of the Site, we may also gather certain information about your use of the Site that does not identify you directly but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Site. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you use the Site. We may collect information regarding user traffic patterns and Site usage. This Traffic Data does not, however, contain anything that can personally identify you, though it may identify your computer or device; it is used to analyze and improve the Site and to provide our users with a better experience. Please see the section below in this Policy regarding Passive Information Collection for more information about our use of cookies and other technologies.

If you choose not to provide information, we may not be able to provide you with requested services, programs, or other Agudah offerings.

We may combine Personal Data you submit to us with other information collected from you, whether online or offline. We treat the combined information as Personal Data in accordance with this Privacy Policy.

We may also collect or receive Personal Data from third-party sources, such as social media or other third-party integrations, your credit card issuing bank, our payment processing partners, and other third parties.

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2.2 Data About Children

We do not knowingly collect Personal Data through the Site from children under the age of 13 without a parent or guardian’s consent. We reserve the right to delete any information identified as having been provided through the Site directly from children under the age of 13 without their parent or guardian’s consent.

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2.3 Sensitive Information

Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political affiliations or opinions, health information, or criminal background. In those cases where we may request or invite you to provide the foregoing information, we will only do so in accordance with all applicable data protection law requirements. Where you provide us with such information without being requested to do so by the Agudah, we reserve the right (but do not have any obligation) to erase such information at our discretion.

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2.4 Social Media

The Agudah engages with its members and other individuals on multiple social media platforms. If you contact us on a social media platform, request service via social media, or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this Privacy Policy, as well as the privacy policy of the social media platform you use.

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3. HOW WE USE YOUR PERSONAL DATA

We use Personal Data submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Generally, we use the information you provide to us for the reason for which it was provided. For example, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came. We may also use Personal Data about you as specifically described below:

• Requests, Inquiries, and Applications: We may use your Personal Data to process, evaluate, and respond to your requests, inquiries, and applications. So, if you request certain information from us, we will use your Personal Data to process and respond to your request.
• Manage Our Relationship With You: We may use your Personal Data to send you important information regarding our relationship with you or regarding the Site, such as changes to our terms, conditions, policies, and other administrative information.
• To Use or Participate In Our Services and Programs: If you provide Personal Data in order to use or participate in our services and programs, to participate in an event or activity, or interact with some functionality available on the Site, we will use your Personal Data to facilitate such use or participation. For example, if you sign up to attend one of our programs, we will use your Personal Data to register you for that activity and to facilitate your participation in that activity.
• Contacting you (such as by text message, email, phone calls, mail, push or messages on third-party platforms) about programs, products, services, companies and events, sponsored by us and others, that you have registered for or that we think might interest you.
• Use of Photographs: We may use your Personal Data in the form of photographs or images taken during Agudah events, or otherwise taken in conjunction with other Agudah programs, services, or other offerings, whether by us, you, or other third parties. We share these photographs in newsletters, on our blogs, and on our social media pages so that our members and others can see what Agudah is up to. We may also share these images with the media.
• Contests, Sweepstakes, and Promotions: We may use your Personal Data in order to administer contests, sweepstakes, and promotions that you sign up for. For example, we may use your Personal Data to notify you if you are the winner of a contest or promotion. If you win a contest, sweepstakes, or other promotion, we may request additional information (e.g., social security number for income tax purposes depending on the prize).
• Donation or Purchase Information: When you donate online or offline, or register to purchase items from us, we collect your contact information and credit card number or bank account information so that we can process your donation or order, notify you of order status, or provide a receipt. If you dedicate your donation or send a gift to a specific Agudah organization or division, we will also provide your information to that entity.
• Survey Information: We occasionally conduct voluntary surveys. If you choose to participate in one of our surveys, we collect information related to you and your responses. We do not share Personal Data collected in these surveys with third parties (other than our service providers). We may share aggregate information with third parties to conduct analytics. The aggregate data cannot be used to identify individuals.
• Internal Business Purposes: We may use your Personal Data for internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of our services and programs; to better understand those individuals that utilize our services and programs; to verify your identity; to prevent, protect against, identify, or address fraud, unauthorized activity, claims, liabilities, and other wrongdoing; to provide you with customer service; to obtain and maintain our funding; and to generally manage our business.
• Marketing: We may use your Personal Data for marketing and advertising purposes, including determining appropriate advertising channels and venues to place ads, placing advertising on such channels and venues, measuring and managing the effectiveness of our advertising and marketing, conducting surveys, and performing market research and data analytics. To learn more about how we use Traffic Data for Interest Based Advertising, please see Sections 5 and 6 of this Privacy Policy.
• Employment: If you provide Personal Data to apply for a job with the Agudah, we may use the Personal Data you provide to evaluate your job application, consider you for that job or for similar jobs in the future, and contact you regarding possible employment.
• Legal Requirements, Industry Standards, and Contractual Obligations: We may use your Personal Data for complying with and enforcing applicable legal requirements, industry standards, and our contractual obligations.

We may use non-personal information or aggregate information that does not identify an individual without restriction, and we may share such information with third parties.

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4. How We SHARE Your Personal Data

We may share your Personal Data only as described in this Privacy Policy or as otherwise described to you at the point of collection.

• Affiliates: We may share your Personal Data with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.
• Marketing. We share personal data with joint marketing partners.
• Related Organizations, Partners, Grantees, and Co-Sponsors: We may share your Personal Data with other reputable nonprofit organizations that share a similar purpose or mission as the Agudah, as well as our partners, grantees, or co-sponsors of our programs, activities, initiatives, and events from time to time. Although our treatment of your Personal Data is governed by this Policy, the treatment of your Personal Data by these third parties will be governed by the privacy policies of such third parties. While we endeavor to share your Personal Data only with partners, grantees, and co-sponsors that will respect your Personal Data, we do not control how these third parties use or disclose your Personal Data.
• Funding Organizations: As a nonprofit, Agudah may receive funding from third parties, including from other nonprofits and government entities. For example, we may share Personal Data in order to document to a funding agency that we have fulfilled our obligation under a grant.
• Agents, Consultants, and Service Providers: We may share your Personal Data with individuals or companies that we hire to provide services to us, such as website hosting services and payment processors.
• Online Forums: Certain features on the Site give you an opportunity to interact with us and others, including on message boards, chats, and creating community profiles on the Site. When you use these features, you should be aware that any information you submit, including your name, location and email address, may be made available to others who have registered to participate in those online forums. We do not have any control over how those other users may use and disclose the information that you share on the forums. It is possible that they could make your information publicly available. We are not responsible for any information you choose to submit through these interactive features.
• Business Transfers: We may transfer your Personal Data in the event of a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation, or reorganization. We may also disclose your Personal Data in the course of due diligence of such a transaction. You acknowledge and agree that any successor to or acquirer of Agudah (or its assets) will continue to have the right to use your Personal Data and other information. Whether the recipient of your Personal Data in these cases will handle your Personal Data pursuant to this Privacy Policy will depend on the applicable law and other factors.
• Legal Requirements: We use and disclose Personal Data as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
• Passively Collected Information: We may share Traffic Data that does not identify you directly, but may identify your computer or device, as described in Sections 5 and 6 of this Policy.

Some third parties’ embedded content or plugins on Sites may allow their operators to learn that you have visited or interacted with us, and they may combine this information with other, identifiable information they have collected about your visits to other websites or online services. These third parties may handle this information, and other information they directly collect through their content and plugins, pursuant to their own privacy policies.

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5. COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES

5.1 As you navigate our Site, certain Traffic Data may be passively collected, meaning it is gathered without you actively providing it. This is done using the following techniques in the following ways:

• IP Addresses: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
• Through your device: If you access the Site through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Site.
• Using Monitoring Tools: The Site may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, tracking links, and other similar technologies, both on certain aspects of the Site and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and response rates, and tracking the activities of users of the Site and e-mail recipients.
• Social Media Widgets. Our Site may include social media tools, including social media widgets or plug-ins, to connect you to your social media accounts. These features may set a cookie or use other automatic collection and tracking technologies to collect information about you and your use of the social media features through and in connection with our Site. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.
• Cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users, to help us make improvements, and to deliver personalized content and/or advertisements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor. We also use cookies to select which of our advertisements or offers are most likely to appeal to you and display them, as described below in the Interest Based Advertising section of this Policy. We also use third-party cookies set by our service provider Google Analytics, to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site. We do not use data collected by cookies to identify who you are. We do not allow Google to use or share our analytics data. You can visit https://www.google.com/analytics/learn/privacy.html to learn more about Google Analytics’ use of cookies. You can visit https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies

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5.2 How to Control & Delete Cookies

You can also refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies.

Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.

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6. INTEREST BASED ADVERTISING

6.1 We may collect Traffic Data about your online activities on our Site to provide you with advertising about products and services tailored to your individual interests. We also may obtain Traffic Data for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.

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6.2 You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our ad partners’ targeted advertising services to show you our ads on other websites based on your prior visits to our Site and other online activity. The interest-based data collected about you is linked to your computer or device. Our advertising partners may use the information that they receive to provide advertising services to the Agudah or to third parties using the same advertising network.

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6.3 Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you also may opt out of ad network interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising).  To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices.

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6.4 Opting-out does not mean that you will stop receiving ads from us. It means that you will stop receiving ads from us that have been targeted to you based on your visits and browsing activity across websites over time.

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6.5 Do Not Track

Our Site currently does not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

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7. SECURITY

We take what we believe to be reasonable steps to protect the Personal Data collected by us from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or Internet or e-mail transmission is ever fully secure, error-free, or “hacker proof.” Therefore, you should take special care in deciding what information you provide to us. Please keep this in mind when disclosing any Personal Data.

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In the event that we believe the security of your personal data in our possession or control may have been compromised, we may seek to notify you of that development. If we believe a notification is appropriate and we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the United States postal service to notify you in this situation, please contact us as described below.

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Please visit your mobile device manufacturer’s website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

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8. DATA RETENTION

We generally retain Personal Data for so long as it may be relevant to the purposes above, or for longer when required by law. To dispose of Personal Data, we may anonymize it, delete it, or take other appropriate steps. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

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9. INTERNATIONAL TRANSFERS OF PERSONAL DATA

The Agudah is based in the United States. The recipients of the Personal Data disclosures described in the “How We Share Your Personal Data” Section above may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate.

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10. EU CONTROLLER

European Union data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

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The Agudah may act as either a data controller or data processor in connection with your Personal Data, depending on the circumstances. However, under applicable law, the Agudah is considered the “data controller” of the Personal Data we handle under this Privacy Policy. The Agudah’s contact information appears at the end of this Privacy Policy.

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11. OUR LEGAL BASES FOR HANDLING YOUR PERSONAL DATA

The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Data. To the extent those laws apply, our lawful bases for processing your Personal Data are:

• To Honor Our Contractual Commitments to You: In some cases, we process Personal Data to meet our obligations to you, or to take steps at your request, in anticipation of entering into such a contract with you, or as is otherwise necessary for our contractual relationship.
• Consent: Where required by law, and in some other cases, we process Personal Data on the basis of your consent. This may be implied consent where permitted by law, and it will be explicit consent where required by law.
• Legitimate Interests: In many cases, we process Personal Data on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
• customer service;
• marketing;
• protecting our customers, community, users, personnel, and property;
• analyzing and improving our business;
• processing job applications; and
• managing legal issues.

We may also process Personal Data for the same legitimate interests of our customers, business partners, and related organizations.

Legal Compliance: We need to process, use, and disclose Personal Data in certain ways to comply with our legal obligations.

To Protect the Vital Interests of the Individual or Others: For example, we may collect or share Personal Data to help resolve an urgent medical situation.

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If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by emailing privacy@Agudah.org.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• • Analyze how our Services are used so we can improve them to engage and retain users
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

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If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

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12. YOUR RIGHTS AND CHOICES

12.1 Opt Out From Direct Electronic Communications

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Where it is in accordance with your preferences, Agudah may send you direct electronic communications, such as through email or text message, regarding donation opportunities or events or programs that might be of interest to you. You may “opt out” of receiving these electronic communications by clicking on the opt-out link within the e-mail you receive, or by sending an e-mail to privacy@Agudah.org indicating which communications you no longer wish to receive. Please note that if you opt out of receiving promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to logistical information for an event for which you are registered or regarding changes to this Policy).

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12.2 Opt Out From Cookie-Related Processing and Interest Based Advertising

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You can opt out from certain cookie-related processing and interest-based advertising as described in Sections 5 and 6 of this Policy.

Under the laws of the European Economic Area (and in some cases in Israel and other countries outside the United States), individuals have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances.  They may also object to our uses or disclosures of personal data, request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect.  This also will not affect our ability to continue processing data in lawful ways (for example, if you opt out of the use of your telephone number for direct marketing, we might still decide to contact you by phone in an emergency).

For example, individuals in the European Economic Area have the right to opt out of all of our processing of their personal data for direct marketing purposes.  To exercise this right, they may contact us as described at the end of this Privacy Policy.

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12.3 How You Can Access, Update, Correct, or Delete Your Personal Data

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If you would like to submit a data access, correction, restriction, or deletion request, you can do so by contacting us at privacy@Agudah.org and we will process such request with respect to any Personal Data that we are able to link to you individually based on the information that you can provide to us. These rights and options that you have with respect to Personal Data are subject to limitations and exceptions under applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first at privacy@Agudah.org  and we will try to resolve your concerns.

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12.4 Notice to California Residents

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California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

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What categories of personal information do we collect?

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

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We have collected the following categories of personal information in the past twelve (12) months:

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We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at privacy@agudah.org, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

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Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

The Agudah has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The Agudah will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

The Agudath does not share SMS opt-in consent with any third- party organizations.

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Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;

• the categories of personal information that we collect;

• the purposes for which the collected personal information is used;

• whether we sell or share personal information to third parties;

• the categories of personal information that we sold, shared, or disclosed for a business purpose;

• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

• the business or commercial purpose for collecting, selling, or sharing personal information; and

• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.

• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at privacy@agudah.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

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13. LINKS TO THIRD PARTY SITES

The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. Agudah is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. Agudah does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

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14. USE OF THIRD PARTY SERVICES

If you access this Site or any of the Agudah’s services through a third party platform, product, service, or application (“Third Party Services”), the protection of your privacy by the Third Party Service provider is governed by the Privacy Policy of that Third Party. Your use of any Third Party Services is subject to that Third Party’s own rules, policies, and practices, and not those of the Agudah. These Third Parties have separate and independent rules and privacy policies, and therefore the Agudah has no responsibility or liability for the Services, privacy policies, or business practices employed by any Third Party that the Agudah does not own, control, manage, or employ, and expressly disclaims any liability related to the use of such Third Party Services. Please take the time to read and review the privacy policy of any such Third Party, as it is solely your obligation to review and understand the privacy practices and policies of these Third Parties.

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15. UPDATES AND CHANGES TO OUR PRIVACY POLICY

The business and operations of the Agudah may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy to reflect changes in the law, our data handling practices, or the features of our services, websites, and apps. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time. Modifications to this Privacy Policy will be posted at www.agudah.org with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances, the Agudah may, but need not, provide you with additional notice of such modifications, such as via e-mail. Modifications will be effective 30 days following the “Updated” date, or such other date as communicated in any other notice to you. Where required by applicable law, we will apply changes only with your consent.

Please review this Privacy Policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued participation in our programs, services, and events following the effectiveness of any modifications to this Privacy Policy constitutes your acceptance of those modifications. If any modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise utilizing the Agudah’s website, as well as its programs, services, and events.

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16. SMS Terms And Conditions

Upon messaging opt-in, the end user agrees to receive messages from AGUDATH ISRAEL OF MARYLAND regarding GENERAL COMMUNICATIONS and CUSTOMER SUPPORT. End users can opt out by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply. If you need assistance or have questions about our SMS service, reply with “HELP” to any SMS message you receive, or contact our customer support team at 773.279.8400

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17. HOW TO CONTACT US

If you have any questions regarding this Policy or the use of your Personal Data under this Policy, you can contact us at: Agudath Israel of Maryland, 23 Walker Ave, Baltimore, Maryland 21208 — Phone: 410-484-3632 — Fax: 443-450-3748 — Email: info@agudathisrael-md.org