This Privacy Policy was last updated June 7, 2019.

By visiting our Website (as hereinafter defined), you are accepting the practices described in this Privacy Policy (“Privacy Policy”). If you do not agree to the terms of this Privacy Policy, please do not use the Website.

1. Introduction

   The Peter and Carmen Lucia Buck Foundation, Inc. (“PCLB”, “we” or “us”) is committed to the lawful, fair and transparent collection and use of your data. This Privacy Policy explains how we collect and process your data, as well as how we share, store and protect it.

   This Privacy Policy is only applicable to the data gathered online at https://pclbfoundation.org/ and any other websites under the control of PCLB (the “Website”), however the Website is accessed and/or used, whether via personal computers, mobile devices, or otherwise, and other interactive features, applications (including mobile applications), or downloads that are operated by PCLB and that are made available by us. This Privacy Policy also applies to any communication where we provide a link to this Privacy Policy, such as when we email surveys. This Privacy Policy does not apply to data that you may submit to us offline or to websites maintained by other companies or organizations to which we may link.

   Each time you use our Website, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Website, you should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version. This Privacy Policy is applicable to all Website visitors and all other users of our Website.

   We reserve the right to modify or amend the terms of this Privacy Policy from time to time without notice. Your continued use of our Website following the posting of changes to this Privacy Policy will mean you accept those changes.

2. How we collect personal data

   We consider that PCLB has a legitimate interest in collecting and processing your personal data. PCLB is committed to investing in charitable endeavors that further PCLB’s mission. This provides our lawful basis to use your personal data, within the limitations set forth herein.

   “Personal data” as used herein is any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location information, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

   If you are in the European Union, we will collect and use your personal data only if we have one or more legal bases for doing so under the EU General Data Protection Regulation (GDPR). The legal bases depend on your interaction with us and the Website. This means we will collect and use your personal data only where: you have given your consent for one or more specific purposes; it is necessary to perform a contract we are about to enter into or have entered into with you; it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; it is necessary to protect the vital interests of you or another natural person; or it is necessary to comply with a legal obligation.

   As a general matter, you can browse the Website without submitting your personal data to us. However, there are a number of circumstances in which you may need to provide us with your personal data. The following lists the most common ways in which we may collect your personal data:

   • When you register for and access an account on our Website;
   • When you register to reserve an Event Space;
   • When you participate in surveys, panels, or research;
   • When you register for our programs, activities, initiatives, and events;
   • When you request information or assistance;
   • In conjunction with processing your grant or scholarship applications;
   • In conjunction with any verification of your account information;
   • In conjunction with investigations into any activity that may violate the law or the Website’s terms and conditions;
   • When you communicate with us through the Website; and
   • In conjunction with any other place on the Website where you knowingly volunteer personal data.

   When you interact with any PCLB representative through email or through any of our third party platforms, we may also collect personal data that you make available to us in that email or through our third party platforms, including your account ID or email address.

   PCLB may collect personal data via the Website from users who voluntarily provide such data. Personal data will not be collected by any method that does not involve an affirmative action on the part of the user to submit such data to PCLB, for example, entering your email address, reserving PCLB event space or applying for a grant or scholarship.

   Users acknowledge and agree that PCLB may use personal data in any manner reasonably related to its charitable purposes. Such charitable purposes may include disclosure of personal data to PCLB’s employees and third party contractors working on behalf of PCLB in support of PCLB’s administrative functions.

   Please remember that any personal data you share in public areas, such as message boards or feedback sections, becomes public, and therefore this Privacy Policy does not apply to any such data you choose to make public. Please be careful about what you disclose, and do not post any personal data that you expect to keep private.

   Children and privacy
   Our Website is not intended for children under the age of 13. If you are not 13 years of age or older, do not use our Website. We do not knowingly collect personal data from children under the age of 13. If we learn that personal data of persons less than 13 years of age has been collected through our Website, we will take the appropriate steps to delete this data without notice as soon as possible.

   Special categories of personal data
   We will not intentionally collect any “special categories of personal data” under the GDPR without your explicit consent for one or more specified purposes or as otherwise permitted or required by applicable law. Special categories of personal data include personal data: (a) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or (b) concerning health or data concerning a natural person’s sex life or sexual orientation.

3. Non-personal data

   When you interact with the Website, our servers may keep an activity log that does not identify you individually (“non-personal data”). Generally, we may collect and store the following categories of non-personal data:

   • Demographic data such as age, gender, and five-digit zip code;
   • Device information about your computer, mobile device, or other device that you use to access the Website. This data may include Internet Protocol (IP) address, geolocation data, unique device identifiers, browser type, browser language, and other transactional data;
   • Usage data about your use of the Website. This data includes a reading history of the pages you view. We use this data to provide you with a more customized experience on the Website;
   • Additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses; and
   • Your search terms and search results.

   We also collect and store certain other non-personal data regarding our users’ use of the Website so that third parties may provide us with reports and analysis regarding usage and browsing patterns of the Website.

   For example, Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes certain non-personal data collected to track and examine the use of the Website, to prepare reports on its activities and share them with other Google services. Google may use the non-personal data collected to contextualize and personalize the ads of its own advertising network.

   We collect this non-personal data in order to help diagnose problems with our server and to administer the site. We also may use it to gather broad demographic data.

4. Managing cookies and similar technologies

   We may automatically collect data using the following mechanisms:

   • Cookies – Like many websites, we use “cookies,” which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. We use cookies to track use of our Website. We may also use cookies to monitor traffic, improve the Website, and make it easier and/or customized for your use. Our third-party analytics providers use cookies to record data about your activities on the site and to “remember” you when you return to the site.

     Some cookies remain on your computer until you delete them. Others, like session ID cookies, expire when you close your browser.

     When you first access the Website, you will receive a message advising you that cookies are in use. By continuing to browse the Website, you agree to our use of cookies as described in this Privacy Policy.

     The Website is generally functional without the retention of cookies. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. You may also delete them after they have been placed on your hard drive. If you do not accept or delete our cookies, some areas of the Website that you access may take more time to work, or may not function properly. See the section “Do Not Track Settings” below for more information on how the Website may respond to your browser settings. We do not control the use of cookies by third parties. For more information on cookies and how to disable them, you can consult the information on www.aboutcookies.org.

   • Pixels (aka web beacons/web bugs/java script) – Like some websites, we may use pixels. Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails that are programmed to collect non-personally identifiable data about your use of a given website or newsletter, e.g., whether you opened the e-mail. Like cookies, web beacons allow PCLB and its technology providers to summarize overall usage patterns for analysis and provide personalized services to you. It is possible that PCLB may collect personal data from you through pixels, such as names or e-mail addresses, however such information will not be shared without your express permission. Our third-party analytics providers use data obtained from pixels to help us improve our Website. We do not control the use of pixels by third parties.
   • “Do Not Track” Settings – Because we track website usage data through the use of cookies, pixels and other tracking mechanisms, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie or other tracking technology data. The only way to completely “opt out” of the collection of data through cookies or other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website may not be able to control other websites.

5. How we combine your data

   We may combine personal data gathered from the Website and personal data that we have received, gathered, acquired, or stored from other sources, both personal data collected offline by PCLB and personal data received from third parties—including personal data that currently exists in our files—into a single customer record. We also use and/or combine personal data that we collect offline or receive from third-party sources to edit, enhance, and/or check the accuracy of your customer record.

6. How we use your data

   Among other reasons, we use the data we collect from you in furtherance of our charitable purposes and to help us personalize and continually improve your experience on the Website.

   In addition, we may use your personal data and non-personal data in the following ways:

   • For editorial purposes;
   • Responding to your inquiries;
   • Communicating with you about your account or transactions with us and sending you information about features on our Website or about PCLB;
   • Personalizing content and experiences on our Website, including providing you with recommendations based on your preferences;
   • Sending you mailings, and information about our policies, programs, initiatives, activities, and events by e-mail or another medium;
   • Processing your grant, scholarship or employment application;
   • Event or program registration;
   • Optimizing or improving our Website, programs, services, and operations;
   • Research and development;
   • Verifying your account and account activities;
   • Detecting, investigating, and preventing activities that may violate our policies or be illegal;
   • Performing statistical, demographic, and marketing analyses of users of the Website and their usage patterns; and
   • Managing our organization.

7. How we share your personal data

   PCLB adheres to the highest standards of ethical practices in all our operations and is dedicated to protecting the privacy of all visitors to our Website. Except as disclosed below, we will never sell, share or permit access to your personal data to anyone outside of PCLB, and, in all cases we only share your personal data where it is in the legitimate interest of furthering PCLB’s charitable purposes.

   We occasionally use independent contractors and third-party agents, affiliates, and partners to perform functions such as marketing, analytics, etc., on our behalf. These entities have access to the personal data needed to perform their functions and are contractually obligated to maintain the confidentiality of PCLB’s confidential information. They are restricted from disclosing or using such information in any way other than to provide the requested services to PCLB. PCLB uses reasonable measures to ensure that your personal data is only transferred to such independent contractors and third-party agents, affiliates or partners who also maintain adequate privacy policies. If you believe personal data you provided to us is being misused by a third party, please contact us.

   We may also occasionally share your personal data with our grantees and co-sponsors of our programs, activities, initiatives, and events from time to time. We endeavor to share your personal data only with grantees and co-sponsors who will respect your personal data. Although our treatment of your personal data is governed by this Privacy Policy, our grantee or co-sponsor’s treatment of your personal data will be governed by the grantee or co-sponsor’s privacy policy. You may withdraw your consent to our sharing of your personal data with grantees and co-sponsors at any time by following the opt-out process described below.

   We may also use or disclose your personal data if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with legal process served on us or the Website; (b) protect and defend our rights or property, the Website, or our users; or (c) act under emergency circumstances to protect the personal safety of us, our affiliates, our agents, or the users of the Website or the public.

8. Access to and control of your personal data

   We will use reasonable efforts to securely process all personal data and, upon written request, provide:

   • Access to your personal data;
   • Correction and removal of your personal data. If any of the personal data that we have about you is incorrect, or you wish to have your personal data removed from our records, please send an e-mail to info@pclbdev.wpengine.com or mail a request to PCLB at Attention: Privacy Policy Request, 633 Third Avenue, 16^th, New York, NY 10017 to correct such data. We will use our best efforts to correct and remove such data;
   • Opting out of messages/notifications or withdrawal of consent. Additionally, if you prefer not to receive messages from us, please let us know by sending a message to us at info@pclbdev.wpengine.com; and
   • Restricted use of your personal data. A restriction on processing your personal data and/or transferring your personal data to another party.

   If you have any questions or requests regarding this Privacy Policy, if you would like to change your preferences, if you no longer wish to receive e-mail updates from PCLB, or if you believe PCLB has erroneous or incomplete data about you, please send an e-mail to info@pclbdev.wpengine.com.

9. Security and storage

   PCLB strives to protect the transmission and storage of any personal data submitted through our Website, through email to PCLB’s representatives or through one of our third party platforms. All personal data you provide to us is stored on our secure servers. Although we use appropriate security measures to help protect your personal data against loss, misuse or unauthorized access or disclosure, we cannot guarantee the security of personal data transmitted to us over the internet and submissions are at your sole risk.

   We will store your personal data, in a form which permits us to identify you, for as long as is necessary for the purpose for which the personal data is processed. We may retain and use your personal data as necessary to further our charitable purposes, comply with our legal obligations, resolve disputes, perform our contracts, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will use our best efforts to delete your personal data within a reasonable time of your request. If this is not possible, we will securely store your personal data and isolate it from any further use until deletion is possible.

10. Miscellaneous

    The Website may contain links to sites operated by third parties and PCLB representatives may provide you with links to sites operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to data gathered through these other websites. Your interactions with these sites are governed by the third parties’ applicable privacy notices, statements or policies. We encourage you to read them.

    The Website is published in the United States and is subject to laws of the United States. If you are located in a country outside the United States and voluntarily submit personal data to us, you thereby consent to the general use of such data as provided in this Privacy Policy and to the transfer of that data to, and/or storage of that data in, the United States. All personal data collected from visitors to the Website is processed in PCLB’s operating offices and in any other places where the parties involved in the processing (including third party service providers) are located. PCLB shall not be liable under any circumstances for damages resulting from use of data collected from visitors to the Website.