The Fund for American Studies (TFAS) is committed to protecting your privacy and we honor your right to make choices about the information you share. This privacy policy (“Privacy Policy”) describes how TFAS collects information, including certain personal information, and how TFAS may use, process, and share such information.
TFAS services and benefits are not designed to appeal to minors under the age of 13 and we do not knowingly attempt to solicit or receive any personal information from children. To the extent that minors under the age of 13 do use a TFAS website and TFAS is able to determine the age of website users by their submissions to, or communications with TFAS websites, TFAS will not knowingly collect personal information from such minors without their parent’s or guardian’s verifiable consent.
COLLECTION AND USE OF PERSONAL INFORMATION
To serve our vision, TFAS collects personal information about those who engage with us and/or visit our Websites. This personal information and the data derived are used, in part, to understand and improve programs and websites, and to serve the interests of our constituencies.
Personal information is any information about individuals and includes your name, mailing address, phone number, email address, gender, birthdate, other contact information, business and work information, educational history, and credit card number. We may collect other personal information, such as your education, employment data, demographic information, and other related information.
We collect personal information directly from you, from publicly available sources and from third parties. Where an individual has donated to TFAS, we will use their personal information to provide them with information, services and to request additional donations. We will collect and use personal information on users who visit our Sites. We also collect and use personal information from supporters and attendees of our events and programs to provide them with information and services associated with the event, program and TFAS.
Once collected, TFAS may use this personal information for the following purposes:
- To communicate with you about your donation, if applicable, or to communicate information about TFAS and other items we believe will be of interest to you.
- To provide you with prompt and effective customer service.
- To fulfill and/or deliver products and services such as event registration, submission of articles, administer awards and honors, and in various other interactions.
- For fundraising purposes, to understand our supporter base better and to ensure improved use of marketing resources to develop our profile and donor base.
- To build higher-quality, more useful services, such as by analyzing usage trends, and by measuring demographics and interests regarding specific areas of the Sites.
- To conduct internal assessments of TFAS programs and supporters; additionally, such personal information, in a consolidated and aggregate form, may be used in publicly distributed statistical descriptions and studies of the TFAS constituency.
- To help us understand trends, and gender and age differences with respect to perspectives about and usage of programs and the creation of new program
offerings. - Text messaging originator opt-in data and consent will not be shared with any third parties unless required by law.
TFAS donors and supporters may add, correct, or update their personal information through a form on the TFAS website or by contacting our Database Manager by phone at: 202.986.0384 or by email at info@TFAS.org.
SHARING WITH THIRD PARTIES
TFAS does not sell or rent postal or email lists containing personal information of European Union (“EU”) and European Economic Area (“EEA”) data subjects. TFAS may occasionally mail or email a notice or information on behalf of another organization to selected groups of TFAS supporters and donors and others who are engaged with TFAS, when such material is deemed to be beneficial to those to be contacted, or to help advance the mission of TFAS.
TFAS may publicly recognize and thank donors for their generosity, and occasionally releases a list of its donors, with the donors’ prior consent.
TFAS may ask third party processors to assist us or we may disclose your personal information to selected third party processors (such as agents or sub-contractors) for the purposes outlined above. The third party processor in question will be obligated to use any personal information they receive in accordance with our instructions.
Non-exhaustively, third parties who we may share personal information with include:
suppliers and sub-contractors for the performance of any contract we enter into with them, for example email service providers, such as MailChimp, or IT service providers such as software developers, website hosts or cloud storage providers; insurers and banks; third parties who help us organize and administer our events; financial companies that process payments on our behalf; professional advisors such as accountants, auditors and lawyers; parties assisting us with research to monitor the impact/ effectiveness of our work and services; and/ or regulatory authorities, such as tax authorities.
TFAS engages third parties to mail or email information to you, including items you may have purchased. TFAS does not reveal your personal data to third parties for their independent use unless: (1) you request or authorize it; (2) it is in connection with TFAS-hosted or TFAS co-sponsored events. TFAS reserves the right to disclose information, including personal information obtained through the Sites, when disclosure is required by law or in a good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on TFAS; (b) protect, establish or defend the rights or property of TFAS including in connection with any (prospective) legal proceedings; (c) protect the personal safety of TFAS officers, personnel, members, volunteers, or members of the public in appropriate circumstances; (d) buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets; (e) assist with auditing purposes; or (f) permit us to pursue available remedies or limit the damages that we may sustain.
OPT IN/OPT OUT
TFAS reserves the right to offer either an opt in or opt out option depending on the situation and the type of information being collected. Any individual may decline to provide personal information requested by TFAS. In this case, TFAS may be unable to provide services for which such information is needed for security and/or identification purposes. Subscribers to any TFAS online service can stop the service by sending an email message to info@TFAS.org or by telephoning 202.986.0384, or by writing to TFAS, 1706 New Hampshire Ave, NW, Washington, DC 20009.
LAWFUL BASES
Under certain laws, we are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
a. Legal obligation
Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject e.g. because we have to provide information to tax authorities.
b. Contractual relationship
Where it is necessary for us to use your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract).
c. Legitimate interests
We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information about our members to provide membership services.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
d. Consent
We may obtain your consent to use your personal information in certain circumstances e.g. to send you email marketing. We will ensure that when we obtain your consent you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.
RIGHTS TO PERSONAL INFORMATION
Upon request via postal mail, email, or telephone, TFAS will provide data subjects (as defined in the General Data Protection Regulation) with a summary of any personal information retained by TFAS regarding the data subject. Individuals may modify, correct, change, or update personal information that TFAS has collected through the Sites or may initiate the removal of their personal record from TFAS’s database by contacting TFAS through a form on the TFAS website or by contacting our Database Manager by phone at: 202.986.0384 or by email at info@TFAS.org.
Please note that we will honor your requests to exercise your rights to the extent possible and required under applicable law. Certain of these rights may only be available to you if you are located in the UK, the EEA or the EU when you access our website.
You have the right to:
a. Ask us for confirmation of what personal information we hold about you, and to request a copy of that information. If we are satisfied that you have a legal entitlement to see this personal information, and we are able to confirm your identity, we will provide you with this personal information.
b. Withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information.
c. Request that we delete the personal information we hold about you, as far as we are legally required to do so.
d. Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes.
f. Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.
g. Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
Please note that you also have the right to lodge a complaint with your local data protection authority (if applicable) about how we use your personal information. Please always consider raising your concern with us first by contacting us using the contact details below.
SUPPORTER/DONOR RESEARCH
Fundraising is an important element of our charitable work so we may undertake research or analysis to assess your ability to support us financially. This may include an assessment of your income and/ or wealth and our assessment of your willingness to make donations to particular projects or to us more generally. We may use analysis to help us identify your likely support for particular projects. All of these activities are undertaken to ensure that we are working in a cost-effective manner and allow us to raise more funds in support of our mission.
If you are an EU data subject and would prefer us not to use your personal data for supporter research please let us know by using the contact details included below.
KEEPING PERSONAL INFORMATION SECURE
Credit card information provided to TFAS via its Websites is transmitted via a secure server with commercial encryption software. Those not able to use a secure server may opt to donate or place the order another way, via phone, fax, or postal mail. To comply with credit card company requirements, TFAS stores certain information for 3 years from the date of the transaction. When requested by the card holder, TFAS will retain credit card information for future specified uses.
We maintain physical, technical and administrative safeguards and procedures to safeguard the security and integrity of your personal information. Although TFAS takes these measures to safeguard against unauthorized disclosure of a user’s personal information, TFAS cannot control Internet transmissions and cannot guarantee or warrant that personal information transmitted to TFAS will be uncompromised in all circumstances.
DATA RETENTION
Your personal data is stored by TFAS on its servers, and on the servers of the cloud-based database management services the TFAS engages, located in the United States. TFAS retains data for the duration of the donor’s, attendee’s or student’s relationship with TFAS and for a period of time thereafter to allow individuals to recover accounts, to analyze the data for TFAS’s own operations, and for historical and archiving purposes associated with TFAS’s history as an association. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact TFAS using the methods below.
Individuals may also ask TFAS to anonymize their record by contacting our Database Manager by phone at: 202.986.0384 or by email at info@TFAS.org. If there is no legitimate purpose for TFAS to keep such personal information, TFAS will anonymize the individual’s record.
INTERNATIONAL DATA TRANSFERS
Where we collect personal information within the EEA, we have taken steps to ensure that the personal information is handled in compliance with European data protection and privacy legislation.
If you are located in the EEA, you should be aware that your personal information will be transferred to the US. In such cases, where your personal information is transferred from the EEA to the US, we will take all reasonable steps necessary to ensure that appropriate safeguards designed to protect your personal information are implemented.
COOKIES AND OTHER TECHNOLOGIES
A “cookie” is a file that a website stores in a user’s computer for future reference. Individuals may set their browsers to reject cookies; however, there are TFAS services that will not function unless the user accepts the TFAS cookie. For example, when a user returns to that TFAS service, the cookie will identify the user as a previous visitor. Information supplied through a TFAS cookie is used only by TFAS to help enhance services provided and is not shared with others.
Web “beacons” are transparent pixel images embedded at certain points on websites that are used to collect information about how users navigate and use the website for the purpose of understanding and improving the function of the website and the value of the content. TFAS uses cookies or other trackers to improve some of its services, provide enhanced functionality on the website, and to aggregate traffic data (i.e., what pages are most popular).
“Cookies” and “beacons” may also be utilized by the third parties that we contract with to provide certain functions. You may block or disable cookies or other trackers by changing the settings on your browser, but doing so may prevent you from accessing certain functionalities on the Sites.
THIRD PARTY WEBSITES AND SERVICES
TFAS provides links to other websites, including social media websites that are not controlled by or contracted to TFAS. A link from the TFAS website is not an endorsement of any company, organization, individual, or viewpoint. TFAS is not responsible for the privacy practices or the content of those sites. You should review third party privacy policies in connection with visiting other sites. TFAS also contracts with 3rd party service providers for web or program transactional services.