Commitment to STEPS TO JOURNEYS’ Donors
STEPS TO JOURNEYS, INC. will not sell, share, or trade donors’
names or personal information with any third party other than STEPS TO
JOURNEYS, INC. service providers, nor send mailings to STEPS TO JOURNEYS’ donors
on behalf of other organizations.
PRIVACY POLICY
This Privacy Policy applies to all personal information received
by STEPS TO JOURNEYS, INC., both online and offline, on any Platform (“Platform”
includes the STEPS TO JOURNEYS, INC. website), as well as any electronic, written,
or oral communications.
Introduction
Your privacy is a priority for STEPS TO JOURNEYS, INC. (
www.stepstojourneys.org) (sometimes
referred to as “STEPS TO JOURNEYS”) and STEPS TO JOURNEYS wants you to be familiar
with how information relating to you, your computer, or your device and that
enables your identification (the “Personal Information”) is collected, used, and
disclosed. This Privacy Policy describes STEPS TO JOURNEYS’ practices with information
that STEPS TO JOURNEYS (or STEPS TO JOURNEYS’ service providers, affiliates, or
subsidiaries) collects from a user (sometimes referred to as “you” or “your”) through
STEPS TO JOURNEYS’ websites, applications, and other network-connected products
and services that link to this Privacy Policy (collectively, the “Site”). This Privacy
Policy only addresses information collected directly through or from STEPS TO
JOURNEYS’ Site – it does not address or govern any information-gathering, use, or
dissemination practices related to information collected from you other than directly
through or from the Site, such as from telephone, facsimile, postal mail, personal
delivery, or other or additional offline means or media.
STEPS TO JOURNEYS can be contacted by email at privacy@stepstojourneys.org.
1. Collection of Personal Information from Users
When you interact with STEPS TO JOURNEYS through the Site, the
following information may be collected from you.
1-a. Information You Provide
Some elements of the Site may ask you
to submit Personal Information for you to benefit from the specified features or
participate in a certain activity, such as newsletter subscriptions or donation
processing. For example, if you register for an account on the Site, STEPS TO
JOURNEYS may request Personal Information such as your name and contact information.
If you donate using the Site, STEPS TO JOURNEYS may collect your credit or debit
card or other financial account information. When you perform a search within the
Site, STEPS TO JOURNEYS may record information identifying you or linking you to
the search performed and recording information related to the search request.
STEPS TO JOURNEYS may combine information you submit through the Site with other
information collected from you, whether online or off-line. All combined information
will be treated in accordance with this Privacy Policy.
1-b. Sensitive Information
In cases where STEPS TO JOURNEYS may
request or invite you to provide information regarding your racial or ethnic origin,
political opinions, religion or other beliefs, health, criminal background, or trade
union membership, STEPS TO JOURNEYS will only do so with your express consent, in
accordance with applicable data protection law requirements. Where you provide
STEPS TO JOURNEYS with such information without request from STEPS TO JOURNEYS,
the right (but not obligation) to erase any such information is at STEPS TO
JOURNEYS’ discretion.
1-c. Information About Minors
STEPS TO JOURNEYS reserves the right
to delete any information identified as having been provided by minors or their
authorized guardians at STEPS TO JOURNEYS’ discretion.
1-d. Location Information
Any comment system on the Site may utilize
an opt-in Geolocation service in accordance with a prevailing community standard
such as HTML 5. Such Geolocation opt-in ability is managed by the user’s browser
settings. If a user chooses to opt-in to the Geolocation service, the user’s comments
may be associated with the user’s location, both internally within STEPS TO
JOURNEYS and publicly on the Site.
1-e. Passive Information Collection,
Use, and Choices
As you navigate the Site, certain Personal
Information may be passively collected, meaning it is gathered automatically without
your actively providing it. This is done using the following techniques in the following
ways:
1-e-i. IP Addresses: An IP address
is a unique identifier that certain electronic devices use to identify and communicate
with each other on the Internet. When you visit STEPS TO JOURNEYS’ Site, the IP
address of the device you use to connect to the Internet may be viewed by STEPS
TO JOURNEYS. This information is used to determine the general physical location
of the device and understand from what geographic regions the Site’s visitors come.
This information may also be used to enhance STEPS TO JOURNEYS’ Site.
1-e-ii. Through your browser: Certain
information is collected by most browsers, such as your Media Access Control (MAC)
address, computer type and operating system type and version screen resolution,
and Internet browser type and version.
1-e-iii. Social Media Widgets: STEPS TO JOURNEYS’ Site may include social media tools, including social media widgets
or plug-ins, to connect you to your social media accounts. These features may set
a cookie or use other automatic collection and tracking technologies to collect
information about you and your use of the social media features through and in connection
with the Site. A third party may host these social media tools. Your interactions
with these tools and the corresponding social media platforms are governed by the
privacy policies of the companies that provide such platforms.
1-e-iv. Cookies: Like many organizations,
STEPS TO JOURNEYS’ Site uses “cookies” to help make sure the Site is meeting the
needs of its users and to help STEPS TO JOURNEYS make improvements. Cookies are
bits of text that are placed on your device when you visit certain websites.
Cookies set by STEPS TO JOURNEYS on the Site may be used to tell, for example, whether
you have visited the Site before or if you are a new visitor. We use third-party
cookies set by STEPS TO JOURNEYS’ service provider, Google Analytics, to collect
information about how visitors use the Site, including how long you spend on each
page and how you got to the Site. We do not use data collected by cookies to identify
who you are. We do not allow Google to use or share STEPS TO JOURNEYS’ analytics
data.
You can refuse STEPS TO JOURNEYS’ use
of some or all cookies by turning off the use of cookies in your web browser. If
you use your browser settings to block all types of cookies you may not be able
to access all or parts of STEPS TO JOURNEYS’ Site or functionality may be limited.
You can set your browser to notify you before you receive a cookie, giving you the
chance to decide whether to accept it. You can also set your browser to turn off
cookies.
Changing your internet browser settings
can prevent the use of cookies. Each browser has a different procedure for disabling
the use of cookies. The Help function within your browser should tell you how. Alternatively,
you may visit www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.
You will also find details of how to delete cookies from your computer and other
general information about cookies. You can visit tools.google.com/dlpage/gaoptout
for information on how to opt out of Google Analytics cookies.
1-e-v. Google Analytics: STEPS
TO JOURNEYS uses Google Analytics, which is provided by Google Inc. It uses cookies
to collect, for example, information about the operating system and the browser
that you use, your IP address, the website you previously accessed (referrer URL)
and the date and time of your visit to the Websites. On subsequent repeated visits
to the Websites, frequently used information is automatically displayed for you.
STEPS TO JOURNEYS can track your usage patterns with the help of the cookies. The
information generated by cookies about the use of the Websites is transmitted to
a Google server, which may be located within or outside of, the United States, and
stored there. Google will use this information to evaluate your use of the Websites. Google
may transfer these rights to third parties insofar as it is required to do so by
law or in order that data may be processed on Google’s behalf. You can visit Google’s
website to learn more about Google Analytics’ use of cookies.
Our site currently does not respond
to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy
whether or not a DNT signal is received, as there is no consistent industry standard
for compliance.
2. How the Information is Used
STEPS TO JOURNEYS collects and uses Personal Information submitted
by you or otherwise collected through the Site and through other sources for the
purposes described in this Privacy Policy and as otherwise described to you at the
point of collection. Generally, STEPS TO JOURNEYS uses the information you provide
for the reason for which it was provided. For example, if you sign up to receive
email notifications, STEPS TO JOURNEYS will contact you by email. If you provide
information to make a donation, STEPS TO JOURNEYS will use the information to process
your donation. Specifically, STEPS TO JOURNEYS may use Personal Information from
or about you:
2-i. To respond to your inquiries and to
send you information that you request and to process your donations;
2-ii. To send you important information
regarding STEPS TO JOURNEYS’ relationship with you or regarding the Site, changes
to STEPS TO JOURNEYS’ terms, conditions, and policies, and other administrative
information;
2-iii. To notify you about upcoming events
and donations;
2-iv. To promote STEPS TO JOURNEYS’ mission
and initiatives, and the missions and initiatives of STEPS TO JOURNEYS’ affiliates
and subsidiaries;
2-v. For STEPS TO JOURNEYS’ business purposes,
such as data analysis, audits, recordkeeping, developing new products or services,
enhancing the Site, improving STEPS TO JOURNEYS’ services, identifying Site usage
trends, optimizing your experience on the Site, and determining the effectiveness
of STEPS TO JOURNEYS’ fundraising campaigns;
2-vi. If you choose to complete a survey,
STEPS TO JOURNEYS may use the information for purposes of evaluating your feedback
from the survey; and
2-vii. If STEPS TO JOURNEYS intends to
collect and use Personal Information for another purpose, STEPS TO JOURNEYS may
seek your permission at the time the information is collected. STEPS TO
JOURNEYS may use any information that does not personally identify you, your computer,
or your device for any purpose.
3. Disclosure of Your Information
STEPS TO JOURNEYS does not sell your Personal Information.
Your Personal Information may be shared with third parties only as described in
this Privacy Policy or as otherwise described at the point where STEPS TO
JOURNEYS collects the information from you, including:
3-i. To STEPS TO JOURNEYS’ affiliates,
subsidiaries, and other STEPS TO JOURNEYS, INC. organizations, for the purposes
described in this Privacy Policy;
3-ii. To the companies or individuals
that STEPS TO JOURNEYS hires to provide services, such as website hosting services,
relationship management services, and payment processing; and
3-iii. To a third party in the event of
any reorganization, merger, sale, joint venture, assignment, transfer, or other
disposition of all or any portion of STEPS TO JOURNEYS’ business or assets (including
in connection with any bankruptcy or similar proceedings).
4. Uses and Disclosures to Comply with Laws
In addition, STEPS TO JOURNEYS uses and discloses Personal Information
collected through the Site as believed to be necessary or appropriate:
4-i. Under applicable law, including laws
outside your country of residence;
4-ii. To comply with legal process;
4-iii. To respond to requests from public
and government authorities, including public and government authorities outside
your country of residence;
4-iv. To enforce STEPS TO JOURNEYS’ Terms and Conditions;
4-v. To protect STEPS TO JOURNEYS’ operations
or those of any of STEPS TO JOURNEYS’ affiliates or subsidiaries;
4-vi. To protect STEPS TO JOURNEYS’ rights,
privacy, safety, or property, and/or that of STEPS TO JOURNEYS’ affiliates,
subsidiaries, you, or others; and
4-vii. To allow STEPS TO JOURNEYS to pursue
available remedies or limit the damages that STEPS TO JOURNEYS may sustain.
5. Links to Third Party Sites
The Site may contain links to other websites for the convenience
of users in locating information, products, or services that may be of interest.
If you access a third-party website from a link on this Site, any information you
disclose on that website is not subject to this Privacy Policy. It is possible that
these links may be used by third parties or others to collect personal or other
information about you. STEPS TO JOURNEYS is not responsible for the privacy practices
of such websites, advertisers, or third parties or the content of such websites
and it is your sole obligation to review and understand the privacy practices and
policies of these other websites. STEPS TO JOURNEYS does not control these third
parties’ use of cookies, collection of information, or how they manage such information.
It is solely your obligation to review and understand the privacy practices and
policies of these other websites, advertisers and any third parties.
6. Where Your Information is Processed
STEPS TO JOURNEYS is based in the United States. No matter where
you are located, your Personal Information will be collected and processed in the
United States. The laws of the United States and other countries governing data
protection may not be as comprehensive or as protective as the laws in the country
where you live.
7. Security
STEPS TO JOURNEYS will take reasonable steps to protect the information
collected and provided via the Site from loss, misuse, and unauthorized access,
disclosure, alteration, or destruction. However, you should understand that no transmission
over the Internet is ever fully secure. Also, STEPS TO JOURNEYS uses reasonable
efforts to ensure that the Site is generally available. However, there will be occasions
when access to the Site will be interrupted or unavailable. STEPS TO JOURNEYS will
use reasonable efforts to minimize such disruption where it is within its reasonable
control. You agree that STEPS TO JOURNEYS shall not be liable to you for any modification,
suspension, or discontinuance of the Site.
8. Data Retention
STEPS TO JOURNEYS generally retains Personal Information for
so long as it may be relevant for the purposes identified in this Privacy Policy,
unless a longer period of time is required by law.
9. Lawful Basis for Processing Your Personal Information
The laws in some countries require STEPS TO JOURNEYS to tell
you about the lawful grounds STEPS TO JOURNEYS relies on to collect, use, disclose,
and otherwise process your Personal Information. To the extent those laws apply,
STEPS TO JOURNEYS’ lawful basis for processing your Personal Information is in support
of legitimate interests, where those interests are not overridden by your fundamental
rights and freedoms. This includes:
9-i. Providing a safe user experience
on STEPS TO JOURNEYS’ Site;
9-ii. Customer service;
9-iii. Sending communications to you to
let you know about what STEPS TO JOURNEYS is doing with your donations and to solicit
additional donations;
9-iv. Protecting users, STEPS TO
JOURNEYS’ workers, and STEPS TO JOURNEYS’ property;
9-v. Analyzing and improving STEPS TO
JOURNEYS’ operations (e.g., optimizing the design and operation of STEPS TO
JOURNEYS’ Site); and
9-vi. Managing legal issues.
This Privacy Policy is issued on behalf of STEPS TO JOURNEYS,
INC. as controller of your Personal Information under applicable data protection
laws. A “controller” is the person or organization who alone or jointly determines
the purposes for which, and the manner in which, any Personal Information is, or
is likely to be, processed.
10. Automated Processing of Personal Information
STEPS TO JOURNEYS may use automated processing of your Personal
Information to tailor communications with you and manage relationships with STEPS
TO JOURNEYS’ donors and contacts. This automated processing may impact the type
of communications you receive.
11. Your Data Rights and Choices
You can opt-out of the use of certain cookie-related processing
by following the instructions in Section 1-e above (Passive Information Collection,
Use, and Choices).
If you are within the European Union, you have the following
rights:
11-i. You have the right to request access
to your Personal Information, and the rectification of inaccurate Personal Information
concerning you.
11-ii. You have the right to request that
STEPS TO JOURNEYS not subject your Personal Information to automated processing.
11-iii. You have the right to obtain the
erasure or the restriction of processing of your Personal Information in certain
circumstances, including when the data are no longer necessary in relation to the
purposes for which they were collected or otherwise processed, except when
STEPS TO JOURNEYS is required by law to maintain or otherwise process your Personal
Information, for the establishment, exercise, or defense of legal claims, or for
the protection of the rights of another person.
You may exercise these rights by contacting STEPS TO
JOURNEYS.
If you are within the European Union, you also have the right
to lodge a complaint with a supervisory authority, in particular in the EU Member
State of your habitual residence, place of work, or place of an alleged infringement
of the applicable data protection law. However, STEPS TO JOURNEYS encourages you
to contact privacy@stepstojourneys.org
to resolve your concerns.
If you would like to submit a data access, correction, restriction,
or deletion request, you can do so by emailing privacy@stepstojourneys.org
to process
such request with respect to any Personal Information that STEPS TO JOURNEYS is
able to link to you individually based on the information that you can provide. These
rights and options that you have with respect to Personal Information are subject
to limitations and exceptions under applicable law.
12. Right to Change Privacy Policy
STEPS TO JOURNEYS reserves the right at any time to modify, alter,
or update this Privacy Policy. Your use of the Site following any changes means
that you agree to follow and be bound by the Privacy Policy as changed, subject
to limitations under applicable law. Any change to this Privacy Policy shall be
effective as to any user who has visited the Site before the change was made. Please
review this policy periodically, and especially before you provide any Personal
Information to STEPS TO JOURNEYS.
13. Contacting Us
For questions about this Site, please contact STEPS TO
JOURNEYS at webmaster@stepstojourneys.org.
For questions about privacy or handling of your Personal Information,
please contact STEPS TO JOURNEYS via email at privacy@stepstojourneys.org.
To contact STEPS TO JOURNEYS via mail:
STEPS TO JOURNEYS, INC.
STREET ADDRESS
Orlando, Florida 32822
Attn: General Counsel
EFFECTIVE AS OF AND LAST UPDATED: July 4, 2022
