1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.
1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.
1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.
1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.
1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.
1. Introduction.
This Privacy Statement(“Privacy Statement”) governs how Hadassah, The Women’s ZionistOrganization of America, Inc. and our subsidiary and affiliate companies,including, without limitation, Hadassah Medical Relief Association, Inc. (collectively,“Hadassah”, “we”, “us”, or “our”) use PersonalInformation (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or“your”) of our owned and operated website, https://Hadassah.org, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Website”), the use of which shall be subject at all times to the Terms andConditions.
We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, Personal Information that may be considered sensitive personal information under Data Privacy Laws (defined below) (collectively, “SensitivePersonal Information”) that is shared with us in connection with users’ use of the Website or users’ offline interactions with us. You may choose whether to provide or disclose Personal Information in connection with your use of the Website.If you choose not to provide the Personal Information we request, you may still visit and use parts of the Website, but may be unable to access or use certain features, options, programs, and services thereof. If you do not agree to be bound by this Privacy Statement at anytime, you should not use the Website.
The Website may contain links to, or advertisements for, websites or mobile applications operated by third parties, including, without limitation, third party social media platforms, and, therefore, not owned or controlled by Hadassah.The links to, and advertisements concerning, third-party websites/mobile applications, social media platforms, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of the sethird-party websites/mobile applications or for your interactions with them, and you visit them at your own risk. Our inclusion of links to, or advertisements for, such third-party websites/mobile applications or social media platforms does not imply any endorsement of the material, products, or services provided by such third-party websites/mobile applications or any association with such third-party websites/mobile applications or their owners or operators whatsoever.
2. Changes to this Privacy statement.
We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all of the terms and conditions of this Privacy Statement that apply to you. We display the effective date of this Privacy Statement at the top of this page, indicated by the “Last Updated” legend.Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Website. If you use the affected Website after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Statement. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Statement that apply to you, so you are aware of the current rights and obligations that apply to you.
3. Children’s Privacy.
The Website is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might be in possession of any information from or about a person under the age of thirteen (13), please contact us at privacy@hadassah.org. Visit www.OnGuardOnline.govfor tips from the Federal Trade Commission on protecting children’s privacy online.
4. Information Collected and How We Collect It.
We may from time to time receive and/or collect the following categories of Personal Information:
· Identifiers, such as your first and last name, gender, date of birth, place of birth, email address, mobile phonenumber, postal address, and Internet Protocol (IP) address;
· Account information, such as your username and account password;
· Financial information, such as the form of payment used to make a donation through the Website and the associatedaccount number and billing address;
· Geolocation information, such as the region in which you are located when you access the Website;
· At each user’s sole option, Sensitive Personal Information, such as your religious affiliation and your racialor ethnic origin;
· Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding your interactions with a website, application, or advertisement; and
· Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Other than as expressly set forth above, we generally do not request on or through the Website, Sensitive Personal Information such as other financial account information(e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport),although we reserve the right to do so when such information is necessary to provide the services offered through the Website and fulfill your requests made through the Website. Pursuant to US Data Privacy Laws (defined below), you have the right to request that Hadassah limits the use or disclosure of yourSensitive Personal Information. To do so, please contact us at privacy@hadassah.org.
Please note that no mobile information (i.e., your mobile phone number) will be shared withor sold (as such terms are defined under US Data Privacy Laws) to third parties/affiliates for marketing/promotional purposes. Further, text messaging originator opt-in data and consent will not be shared with or sold (as such terms are defined under US Data Privacy Laws) to any third parties; provided that the foregoing does not apply to sharing such information (i) with third-party service providers, including, without limitation, our SMS text message marketing partner, who need to access such information to perform work on our behalf (and who will not use such information for their own purposes); (ii) if we believe disclosure is required by any Applicable Law (defined below); and(iii) if you otherwise consent to our sharing of such information.
The sources from which we obtain Personal Information are described below.
4.1 Personal Information You Provide to Us Through the Website.
If you donatet o Hadassah; register to become a member or associate of Hadassah; sign a petition or take action on the Hadassah National Action Center; sign up to receive Hadassah’s email newsletter or other email updates; join one of Hadassah’s Professional Councils; or otherwise contact us on the Website, then you may provide us with, and we may collect, certain information that may constitute Personal Information and/or Sensitive Personal Information.
In addition, from time to time we may provide users with the ability to participate in activities or programs hosted on the Website, on third-party digital platforms, or offline(each, an “Event”). When you register through the Website to participate in an Event, we may require that you provide us or our third-party Event host with certain information that may constitute Personal Information, such as your firstand last name, postal address, and email address.
4.2 Information Provided by Third Parties.
We may from time to time collect information, including Personal Information, about you through non-affiliated third parties, including, without limitation, third-partyEvent hosts and our third-party payment processor(s). Please note that, while our payment processor(s) may provide us with the last four digits of your payment method account number (e.g., credit card number or checking account number), which may constitute Personal Information when combined with other identifiers, all payment information provided by our payment processor(s) is only in encrypted and tokenized form, which, absent such identifiers, does not constitute Personal Information (i.e., Personal Information will be replaced with non-Personal Information identification symbols). If you access the Website from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information.Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.
4.3 Information Collected Automatically.
We may from time to time automatically collect certain information when you access or use the Website by means of various software tools described below. In such circumstances, we have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to trackuser trends, and to analyze the effectiveness of the Website and to otherwise personalize the Website to you. Alone or in combination with other information, such automatically collected information may constitute Personal Information.
We may automatically collect the following information, some of which may constitutePersonal Information, when you access or use the Website:
· Log Files on the Website. The information inside the log files may include, amongst other similar types of information, IP addresses, type of browser, Internet Service Provider(ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.
· Cookies. When you use or visit the Website, our servers may send one or more cookies to your computer, including required cookies (i.e., cookies used for the basic functioning of the Service and to enable features like secure login, page navigation, and access to protected areas), performance cookies (i.e., cookies used to collect information about how visitors use the Service to help us improve its performance and user experience), and functionality cookies (i.e., cookies that allow the Service to remember your preferences and choices to provide a more personalized and seamless experience). Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is thensent back to the server each time the browser requests a page from the server.Cookies do not typically contain information that individually identifies you, butPersonal Information that we store about you may be linked to the information stored in and obtained from cookies. We may use cookies to make interactions with the Website easier and more meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session anddisappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close yourbrowser or turn off your computer. Please note that, if you disable your webbrowser’s ability to accept cookies, you will be able to navigate the Website,but you may not be able to successfully use all the features of the Website. Tolearn how to opt-out of required cookies, performance cookies, and/orfunctionality cookies using your browser settings, click here.
4.4 Other Tracking Technologies.
When you use or visit the Website, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Website. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Website and interaction with email communications from us and to operate and improve the Website and our email communications. For example, we may place web beacons in email communications (including, without limitation, marketing emails) that notify uswhen you click on a link in the email that directs you to the Website.
5. The Purposes For Which We Use Personal Information.
If you submit or we collect Personal Information through the Website or as otherwise described above, we may use such Personal Information for the following general purposes:
· To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time), collectively, “Applicable Law”);
· To provide, analyze, administer, improve, and personalize the Website;
· To communicate with you in connection with the Website, Events, your membership, donations you have made and/or advocacy efforts you have engaged in, and other products, services, events, travel, or offerings made available through the Website;
· To send you updates and promotional materials pertaining to Hadassah and/or the Website;
· To identify and authenticate your access to the parts of the Website that you are authorized to access;
· For research and development relating to the Website and the advocacy efforts and services we make available to you through the Website;
· For electronic direct marketing and/orSMS text message marketing in compliance with Applicable Law;
· To protect our rights and/or our property and to ensure the technical functionality and security of the Website;
· For the performance of our contract with you, to take steps at your request before entering into a contract, or forany other general business purpose that is reasonably necessary for us to provide our products or services to you; and
· Where you have given actual or constructive consent.
6. How We Disclose Personal Information.
We do not sell, share, lease, rent, or otherwise disclose (as such terms are used under DataPrivacy Laws) the Personal Information collected on or through the Website to third parties unless otherwise stated below or with your consent.
6.1 Our Third-Party Providers.
We may transferPersonal Information you provide to us through the Website to our third-party service providers and business partners to perform tasks on our behalf and to assist usin providing the Website, including, without limitation, to third-party hosts and/or sponsors of an Event you have registered for, our email marketing partner, our SMS text message marketing partner and/or our third-party payment processor tasked with processing your donations made through the Website.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party Website providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-partyWebsite providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices and compliance.
6.2 In the Event of Merger, Sale, or Change of Control.
Hadassah may assign or transfer its rights and/or delegate its obligations under thisPrivacy Statement and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hadassah, or is merged with or into Hadassah, as part of a merger, acquisition, sale, or other change of control.
6.3 Other Disclosures.
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to(i) comply with legal process, (ii) enforce the Terms and Conditions, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Hadassah, other Website users, and the public.
7. Retention of Personal Information.
We will keep your Personal Information while you have an account with us or while we are providing services to you (online and/or offline). Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
· To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”),including, without limitation, to comply with Applicable Law; or
· To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Statement.
8. Your Rights.
8.1 Rights Relating to Personal Information.
If you have an Account on the Website, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:
· Delete all content browsing information and opt out of further participation in data associated with the current device you use to use or browse the Website; and
· Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability),object to the processing of Personal Information collected in and through the Website, or withdraw your consent (as applicable), you may submit a request to Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at Hadassah, The Women’s Zionist Organization of America, Inc., 40 Wall Street, New York, NY10005, United States of America. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have aright to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at privacy@hadassah.org so we have an opportunity to address your concerns directly before you do so.
8.2 Email Notifications and Opt Out.
We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt out as provided herein, by accepting this Privacy Statement, you expressly agree that we may use your information to contact you by email to deliver information that is relevant to your use of the Website such as administrative notices, newsletters or other email updates you have registered for, or marketing and promotional information related to the Website, Hadassah, and/or advocacy efforts you have shown an interest in. You may choose to stop receiving newsletters and/or other commercial communications from us by following the instructions included in such communications, modifying your preferences in your Hadassah Subscription Center (which may be accessed by clicking the “Manage Preferences or Unsubscribe” link included in such communications), or by contacting us at privacy@hadassah.org. If a third-party vendor provides such newsletters and/or other commercial communications, you may unsubscribe in accordance with the instructions provided in such newsletters or by such vendor.
If you are having problems unsubscribing, please contact us at privacy@hadassah.org by forwarding the newsletter, if applicable, to privacy@hadassah.org and including in the Subject line the word"Unsubscribe," and you will be removed within ten (10) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
9. Data Security.
The security ofPersonal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard PersonalInformation from unlawful use, unauthorized access, or disclosure. However, nome thod of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
10. How We Respond To Do Not Track Signals.
As explained above in Section 4.4, the technologies used through the Website may be used to track Website users’ activity through the Website. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Website may not respond to Do Not Track signals at this time.
11. Transfers of Personal Information from the European Union (EU) orEuropean Economic Area (EEA), the United Kingdom (UK), or Switzerland to the United States of America.
To communicate with you or provide the Website, the information (including PersonalInformation) that we collect from you may be transferred to, stored, used, and processed by Hadassah in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.
If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individualStates, please note that you are transferring your Personal Information to the UnitedStates of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in thisPrivacy Statement. When you provide Personal Information to us or our service providers or business partners, you consent to the processing of your information in the UnitedStates of America as the Website is offered from the United States of America.We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Statement, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners.
You acknowledge that the laws of the United States of America andits individual States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States of America, you should not share your information with us, or make use of the Website.
To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than the United States of America. However, the foregoing waiver may not be legally binding in some countries, such as the member states of the European Union or the broader European Economic Area. Tothe extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you.
12. NOTICE TO RESIDENTS OF THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, AND UNITED KINGDOM
European Union,European Economic Area and United Kingdom data protection law requires a“lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas and the United Kingdom, respectively. Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (as amended from time to time, and as adopted by the United Kingdom, “GDPR”), which are summarized below.
· Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your PersonalInformation when you contact us through the Website or enter a contract with us.
· Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future transactional services.
· Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website or through our contract with you.
· Legitimate Interests: This is a technical term that means we have a good and fair reason to use your PersonalInformation and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Website by users and to keep the Website secure, (ii) may also send you promotional communications about our Website and/or Hadassah subject to your right to opt out, and (iii) analyze how users interact with our Website so we can understand better what elements do ord o not work well, what services/functionalities may be necessary or desirable to provide you with the best user experience on the Website, and to ensure the safety and security of the Website, which allows us to improve and develop the quality of the online experience we offer all our users.
In accordance with GDPR, as a resident of the European Union, European Economic Area, or theUnited Kingdom, you have the following rights with respect to your PersonalInformation:
· If the processing of PersonalInformation is based on your consent, the right to withdraw consent for futureprocessing of such Personal Information;
· The right to request access to and rectification of your Personal Information;
· The right to request restriction of the processing of your Personal Information;
· The right to request erasure of your Personal Information; and
· The right to receive, in a structured, commonly used and machine-readable format, the Personal Information you have provided to us based on your consent or a contract, and have suchPersonal Information transmitted to another company, where technically feasible(i.e., Data Portability).
To make are quest pursuant to your GDPR rights, you must contact Hadassah’s PrivacyOfficer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America. If you are not satisfied with our response to any appliable request made pursuant to your rights under GDPR, you also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.
13. U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information: These rights may be accorded to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act; the Iowa Data ProtectionAct; the Nebraska Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Tennessee Information Protection Act; theMinnesota Consumer Data Privacy Act; the Maryland Online Data Privacy Act; theIndiana Consumer Data Protection Act (effective January 1, 2026); theKentucky Consumer Data Protection Act (effective January 1, 2026); and the Rhode Island Data Transparency and Privacy Protection Act (effectiveJanuary 1, 2026) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with GDPR, “Data Privacy Laws”). For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” as such term is used under US Data Privacy Laws.
13.1 Requests to Know.
You have the right to request that we disclose:
· The categories of Personal Information we have collected about you;
· The categories of sources from which we have collected Personal Information about you;
· Our use of the Personal Information we have collected about you;
· The business or commercial purposes for selling or collecting Personal Information about you;
· The categories of Personal Information sold, shared, or disclosed about you, as well as the categories ofthird parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
· The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date ofyour request.
The delivery of our response to your request to know may take place electronically or by mail.We are not required to respond to requests to know more than twice in a twelve(12)-month period.
13.2 Requests to Delete.
You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with an obligation underApplicable Law; and/or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
13.3 Right to Opt Out of the Sale or Sharing ofPersonal Information and/or Sensitive Personal Information.
You have aright to opt out of the sale or sharing of Personal Information and/orSensitive Personal Information. You may, at any time, direct us to not sell orshare Personal Information and/or Sensitive Personal Information about you to third parties. If you exercise your right to opt out of the sale or sharing of Personal Information and/or Sensitive Personal Information about you, we will not sell or share Personal Information and/or Sensitive Personal Information about you. Any Personal Information and/or Sensitive Personal Information collected in connection with your request will be used only to facilitate that request.
13.4 Requests to Correct Inaccurate Personal Information.
You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
13.5 Right to Opt Out of Profiling.
You have the right to opt out of “profiling.” This opt out applies to the automated processing of Personal Information that is used to render decisions that could have a legal or similarly-significant effect on a user. Examples of such decisions include those related to credit and access to fundamental goods or services. Hadassah does not engage in profiling as described above.
13.6 Right to Non-Discrimination.
You have the right not to be discriminated against for the exercise of your US Data Privacy Laws rights described above. Unless permitted by US Data Privacy Laws, we will not as a result of such exercise:
· Deny you services;
· Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
· Provide you a different level or quality of services; or
· To the extent applicable, suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
13.7 Authorized Agents.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney may submit a request on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response to Requests.
To make a request pursuant to your US Data Privacy Laws rights, you must contact Hadassah’s Privacy Officer either by email at privacy@hadassah.org or by mail at 40Wall Street, New York, NY 10005, United States of America.
Hadassah reserves the right to verify all requests made pursuant to US Data PrivacyLaws. Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five(45) days of receipt. To protect your privacy and the security of PersonalInformation about you, we verify your request by requesting additional identifying information that will only be used to verify your identity and for no other purpose.
If you are a resident of Colorado, Connecticut,Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, NewJersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your US Data Privacy Law rights. To do so, you must email us at privacy@hadassah.org within forty-five (45) days of your receipt of our denial therefor. We will respond to an appeal within sixty (60) days of receipt for residents of Connecticut, Delaware, Iowa, Maryland, Montana,Nebraska, New Hampshire, Texas, Tennessee, and Virginia, and within forty-five(45) days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.
· If your appeal is denied and you are a Connecticut resident, you may contact theConnecticut Attorney General to submit a complaint at: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
· If your appeal is denied and you are a Texas resident, you may contact the Texas Attorney General to submit a complaint at: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/flow/TCP_Complaint_Input_Data_Privacy.
· If your appeal is denied and you area Maryland resident, you may contact the Maryland Attorney General to submit a complaint at: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
· If your appeal is denied and you are a Montana resident, you may contact the Montana Attorney General to submit a complaint at: https://dojmt.gov/office-of-consumer-protection/consumer-complaints/.
13.9 Categories of Personal Information We Have Sold or Shared in the Last Twelve (12) Months.
We have not sold or shared (as such terms are defined under US Data Privacy Laws) any categories of Personal Information during the last twelve (12) months.
13.10 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.
We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:
· Identifiers, such as your first and last name, email address, mobile phone number, and postal address.
14. Contact Us.
If you have any questions about this Privacy Statement, please contact Hadassah by email at privacy@hadassah.org.