Sample Website Privacy Statement
JA Worldwide (“Company” or “JA”) believes you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. JA wants you to make the best decisions about the information that you share with us. This Privacy Statement describes the privacy practices of JA about users of jaworldwide.org (the “Site”) and JA’s programs and alumni program services.
Overview
JA cares deeply about your privacy, and we are fully committed to protecting your personal information and use it properly in compliance with data privacy laws. Personal information means information that can be used to directly or indirectly identify you, and may include, but is not limited to, your name, address, phone number, location, and email address. This Privacy Statement describes how JA collects and uses personal information, and the rights and choices available to you regarding such information.
JA strongly urges you to read this Privacy Statement. If you have any questions or concerns regarding this Privacy Statement, please contact JA at privacy@jaworldwide.org.
Please note that this Privacy Statement could be updated to reflect any changes in the way JA handles your personal information or any changes in applicable laws. If JA makes material changes to the Privacy Statement, JA will provide you notice so you have an opportunity to review the changes.
What Is JA’s Lawful Basis for Collecting and Using Your Personal Information?
JA will collect and use your personal information for the purposes set forth in this Privacy Statement. As discussed below, the lawful basis for processing personal information is (a) your consent; (b) JA’s legitimate interest in carrying out its business, including to grow and improve its services, provide those interests are not outweighed by your rights and interests; (c) performance of a contract with you; and (d) necessary to comply with a legal obligation.
How Does JA Collect Your Personal Information?
JA collects or may be provided personal information in its normal course of business, as follows:
Information you provide to JA: JA collects personal information when you directly provide it to JA, including when you sign up for JA’s updates, newsletters, fill out contact forms, register for JA events, sign up to volunteer with JA, donate to JA, and register for the JA alumni community and build your profile.
Information that JA receives from third parties: JA collects personal information provided to JA by its partners, service providers, vendors, consultants, JA members, regional operating centers (ROCs), and JA alumni groups.
Information that is automatically collected: JA wants you to benefit from the information and services available on the Site. Like many websites, JA uses web analytics tools that rely on cookies, web beacons, and other automated tracking technologies to help JA analyze how users interact with and use the Site, improve the Site, personalize your Site experience, provide you with information JA believes may be of interest to you, and identify others like you who may be interested in our programs and services. For more information on the Site’s automatic personal information collection see “What personal information does JA automatically collect when you visit the Site?” on this Privacy Statement.
How Does JA Use Your Personal Information?
JA collects and uses personal information only for the specific purposes explained in this Privacy Statement. Those purposes include:
To provide you with information via updates, newsletters, and publications when you request them or when JA believes they may be of interest to you. You will always have the opportunity to opt-out of receiving communications from JA. JA’s lawful basis for processing your personal information will be your consent.
To provide you with program and services information, events information, volunteer opportunities, and employment opportunities with JA, JA members, regional operating centers (ROCs), JA alumni groups, and partners that you requested or that JA believes you may be interested in. You will have the opportunity to opt-out of receiving communications from JA, JA members, ROCs, JA alumni groups, and partners. JA’s lawful basis for processing your personal information will be your consent when consent was obtained or JA’s legitimate interest in providing information about JA, JA members, ROCs, JA alumni groups, and its partners.
To process donations through service providers. JA’s lawful basis for processing your personal information will be your consent.
To improve JA’s programs, services, and operations. JA’s lawful basis for processing your personal information is that it is necessary for the purpose of a legitimate interest pursued by JA, namely to improve its programs, services, and operations. JA may also process your personal information to fulfill a contract.
To research and analyze the Site’s users’ demographics, interests, and behavior in an aggregated form, including to improve our Services and the JA-program experience for all participants, to measure the impact of participation in JA programs and events and communicate such impact measurements to donors and other stakeholders, to better understand and serve you and other users, and to improve our Site and its offerings. JA’s lawful basis for processing your personal information is that it is necessary for the purpose of a legitimate interest pursued by JA, namely to improve the Site’s user’s experience. Where applicable law requires consent to use certain cookies, we will ask for your consent.
To get your feedback and viewpoints through polls and surveys conducted by JA and others. You are not obligated to respond to polls and surveys and can choose only the information you wish to provide. You will have the opportunity to opt-out of receiving polls and surveys from JA or others. JA’s lawful basis for processing your personal information will be your consent.
To meet legal, security, processing, and regulatory requirements. JA’s lawful basis for processing your personal information is that it is necessary for the purpose of meeting a legal obligation and a legitimate interest pursued by JA, namely to improve its programs, services, and operations.
What Personal Information Does JA Automatically Collect When You Visit the Site?
JA collects information about your visit and usage of this Site. Some of the information is collected using Google Analytics, a third-party tool. The information may include your IP address, your operating system, your browser ID, and other information about how you interact with the Site. JA uses this information to improve its services and the user experience as well as network management and security.
JA and Google also use various technologies to collect and store information when you use the Site, including cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the Site, track users’ movement around the Site, and identify ways to improve the Site and determine how JA can make the Site a more positive and relevant user experience.
By using this Site, you agree that JA can place cookies on your device as explained below. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies see allaboutcookies.org/manage-cookies. Please note that current “Do Not Track” initiatives are not recognized by our Site.
Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the Site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our Site, even if you have previously deleted our cookies.
Turning off cookies will also prevent any web beacons from tracking your user activity on our Site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
JA use on the following cookies on the Site:
Strictly necessary cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for cannot be provided.
Performance cookies: These cookies collect information about how visitors use a site; for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works. Performance cookies used by the Site include Google analytics tracking cookies, used to track analytics of site use, including pages viewed and whether the individual is a new or repeat visitor.
Functionality cookies: These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information or news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of the Site’s pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. JA may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile. In most cases, JA will not be able to track individuals by name. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our Site.
How Is Your Personal Information Shared?
Service providers, vendors, and consultants: JA may share your personal information with our service providers, vendors, and consultants for the purpose of improving the Site and facilitating the services that JA offers on JA’s behalf. JA may use service providers and consultants to perform promotional marketing, data analysis, processing credit card payments, and providing customer support. These companies have access to personal information to perform their functions but may not use it for other purposes. These include, for example, Squarespace (web platform), Google Analytics (website analytics), Salesforce (CRM service provider), Mailchimp (email marketing), and others. JA will share your personal information where access to personal information is necessary or useful to perform their services.
Partners: JA may share personal information with its partners in order to provide you with information that you have requested or that JA believes may be of interest to you.
JA members, regional operating centers (ROCs), JA alumni groups: JA may share personal information with JA members, ROCs, and JA alumni groups to provide you with information programs and services that you have requested or that JA, JA members, ROCs, and JA alumni groups believe may be of interest to you.
Legal obligation: JA reserves the right to share your personal information when it believes that such disclosure is necessary to comply with a legal requirement, such as a court order, valid discovery requests, valid subpoena, or to protect the rights or property of JA, you, or third parties, and if JA is acquired in a merger or acquisition.
JA does not rent or sell your personal information to others.
What About Children and JA’s Programs and Alumni Program Services?
While we encourage children to learn about JA and its programs, we ask that children under 13 do so only with parental supervision. JA does not knowingly collect personal information from anyone under the age of 13. If we learn that a child under 13 years of age has provided JA their personal information without verifiable parental consent, JA will use its best efforts to delete this information from its files.
What About Sensitive Data?
JA does not generally collect sensitive data (also known as special categories) through the Site or otherwise. The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
In the limited circumstances where JA may collect such data, JA will do so in accordance with all applicable data privacy law requirements, which may include obtaining consent. If you choose to provide JA with unsolicited sensitive data, you are consenting to JA using the sensitive data, subject to applicable laws as described in this Privacy Statement.
How Does JA Share Your Personal Information Globally?
JA is a global organization located in the United States. Information provided to JA may be transferred to and processed in the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to the laws in your country of residence. Personal data may also be transferred to other countries.
By providing your personal information to JA, you agree to the transfer, storage, and/or processing of your personal information globally.
Personal information collected within the European Economic Area (“EEA”) may be transferred to countries outside of the EEA for the purposes described in this Privacy Statement. JA relies on derogations outlined in Article 49 of the GDPR to transfer personal information outside of the EEA. In particular, where JA collects personal information, it transfers it out of the EEA with your consent; to perform a contract with you, or pursuant to standard contractual clauses. JA applies suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with JA and the practices described in this Privacy Statement.
If you are a citizen of the EEA, and you have an unresolved privacy or data concern that JA has not addressed satisfactorily, please contact the appropriate EU Data Protection Authority (DPA) free of charge. A list of DPAs can be found here.
How Does JA Safeguard Your Personal Information?
JA understands that the security of your personal information is important. To that end, JA maintains organizational, physical, and technical security arrangements for the personal information it collects to guard your personal information against accidental loss and from unauthorized access, use, alteration, and disclosure.
JA restrict access to your personal information to those employees of JA, who need to know that information to provide services to you. JA trains those employees about the importance of confidentiality and maintaining the privacy and security of your information.
However, despite our efforts, no security controls are 100% effective, and JA cannot ensure or warrant the security of the personal information you provide to JA. There is no guarantee that the data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
The Site may, from time to time, contain links to other websites. If you follow a link to any of these websites, please note that they may have their own privacy statements and that JA does not accept any responsibility or liability for these statements or websites. Please check these privacy statements before you submit any personal information. This Privacy Statement applies only to information collected by this Site and by JA and not to other websites that you may link to from here.
JA uses SSL security on any form that requires credit-card or debit-card information. JA will never ask for information that could be used in a phishing scheme without the SSL security behind the form.
Where Does JA Store Your Personal Information and for How Long?
JA stores your personal information on the servers of the cloud-based database management services JA engages located in the United States, Ireland, and the Czech Republic.
JA will retain your personal information for as long as you allow JA to retain your data, or as otherwise necessary to provide you with information about JA and its programs and services. For more information on where and how long your personal information is stored, and for more information on your rights to be forgotten and portability, please contact JA at privacy@jaworldwide.org.
What Are Your Rights?
You are entitled to know what personal information JA collects about you and to have access to that information. You can request access to your information by emailing privacy@jaworldwide.org.
Additionally, you can choose not to receive any communications from JA about events or publications JA feels might be of interest to you. For example, you may sign up to receive newsletters or email notifications regarding particular events or services. You may opt out of receiving these optional communications at any time by clicking the “Unsubscribe” link in the footer of these emails.
You can request to have your personal information and account deleted. You may request to have your account deleted by emailing privacy@jaworldwide.org the message, “Please delete my information.”
Whom Can I Contact at JA with Questions or Concerns?
If you have a privacy question, concern, or request, please contact us at privacy@jaworldwide.org.
