Privacy Policy

PRIVACY POLICY
This Privacy Policy explains the collection, use, processing, transferring and disclosure of personal information by the Civic Association of Palisades (“CAP”), a Maryland non-profit organization.
This Privacy Policy is incorporated into and made part of CAP Terms.
1. Unless otherwise noted on a particular website or service hosted by CAP, this Privacy Policy applies to your use of all websites that CAP operates. This Privacy Policy also applies to all products, information, and services provided through the Websites.
2. In addition, supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to a particular Service. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that particular Service.
3. By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.
4. Our Principles
CAP has designed this policy to be consistent with the following principles:
  • CAP has designed this policy to be consistent with the following principles:

  • Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.

  • Data practices should always meet the reasonable expectations of users.

  1. Personal Information CAP Collects and How it is Used

  • As used in this policy, “personal information” means information that would allow someone to identify you, including your name, email address, IP address, or other information from which someone could deduce your identity.

  • CAP collects and uses personal information in the following ways:

  • Website and Fundraising Analytics: When you visit our Website and use our Services, CAP collects some information about your activities through tools such as Google Analytics. The type of information we collect focuses on general information such as country or city where you are located, pages visited, time spent on pages, heat-map of visitors’ activity on the site, information about the browser you are using, etc. CAP collects and uses this information pursuant to our legitimate interest in enhancing the security and utility of our Services. The information we gather and process is used in the aggregate to spot trends without deliberately identifying individuals, except in cases where you engage in a transaction with CAP by paying dues and fees, donating money, purchasing merchandise, or buying a ticket for an event or program. In those cases, CAP retains certain information about your visit to the Services, pursuant to its legitimate interest in understanding its community of supporters for fundraising purposes, and this information is stored in connection with other personal information you provide to CAP.

  • Note that you can learn about Google’s practices in connection with its analytics services and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

  • Information from Cookies: We and our service providers (for example, Google Analytics as described above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities. The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

  • Log-In Services: When you register to obtain a CAP account for any of the Services, you will be asked to provide personal information to create your account and may be asked to establish a password and profile. CAP collects and uses this personal information pursuant to its legitimate interest in establishing and maintaining your account providing you with the features we provide Registered Users. We may use your email address to contact you regarding changes to this policy or other applicable policies. The name or nickname you provide in connection with your account may be used to attribute you in connection with any content you submit to any Service. In addition, whenever you use a CAP Login Service to log into a Website or use the Services, our servers keep a plain text log of the Websites you visit and when you visit them.

  • Events: When you sign up for an event hosted or supported by CAP, you will be asked to provide some personal information, including your name, email address, and other information as needed. CAP collects and uses this personal information pursuant to its legitimate interest in organizing and running the relevant event.

  • Emails and Newsletters: When you sign up to receive updates from CAP or otherwise subscribe to one of our mailing lists, you will be asked to provide some personal information. CAP collects and uses this personal information pursuant to its legitimate interest in providing news and updates to, and collaborating with, its supporters and volunteers.

  • Email Analytics: When you receive communications from CAP after signing up for the CAP newsletter, campaign updates, or other ongoing email communications from CAP, we use analytics to track whether you open the mail, click on the links, and otherwise interact with what we send. CAP collects and uses this personal information pursuant to its legitimate interest in understanding the interests of its community of supporters and volunteers in order to provide more relevant news and updates.

  • Donations, Payments and Fees: When you donate money to CAP, purchase merchandise or services, or pay dues or fees, you will be asked to provide personal information, including payment information. CAP collects and uses this personal information pursuant to its legitimate interest in raising funds to ensure the sustainability of our nonprofit organization and, where applicable, to provide you with the merchandise, event, or service you purchased.

  • Other Voluntarily Provided Information: When you provide feedback to CAP, sign a petition distributed by CAP, or otherwise submit personal information to CAP, CAP collects and uses this personal information pursuant to its legitimate interest in better understanding our community of supporters and volunteers and in furtherance of the particular program or activity to which you provided feedback or other input.

5. Retention of Personal Information
  • The majority of the personal information collected and used as explained in Section 3 above is aggregated and stored in a central database provided by a third-party service provider. CAP aggregates this data pursuant to its legitimate interest in having information stored in a single location to minimize complexity, increase consistency in internal practices, better understand its community of supporters and volunteers, and enhance the security of the data.
6. Access to Your Personal Information
  • You are generally entitled to access and transfer to a third party any personal information that CAP holds and to have inaccurate data corrected or removed to the extent CAP still maintains it. In certain circumstances, you also may have the right to object or restrict for legitimate reasons to the processing or transfer of personal information. If you wish to exercise any of these rights, please write to CAP explaining your request. You also have the right to go directly to the relevant supervisory or legal authority, but we encourage you to contact us so that we may resolve your concerns directly as best we can.
7. Disclosure of Your Personal Information
CAP does not disclose personal information to third parties except as specified elsewhere in this policy and in the following instances:
  • CAP may share personal information with our contractors and service providers in order to undertake the specific activities or services of the Association.

  • We may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Terms and this Privacy Policy; (c) enforce our By-Laws and policies contained and incorporated therein, or (d) comply with legal process, such as a search warrant, subpoena, statute, or court order.

8. Security of Your Personal Information
  • CAP has implemented reasonable physical, technical, and organizational security measures for personal information that CAP processes against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

  • The CAP Login Services account systems have security risks in addition to those described above. Among other things, they are vulnerable to DNS attacks, and using any CAP Login Service may increase the risk of phishing.

  • The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Terms specifically prohibit anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to CAP through the Services represents that they are 13 years of age or older.

9. Third-Party Service Providers
  • CAP uses many third-party service providers in connection with the Services, including website hosting services, database management, credit card processing, and many more. Some of these service providers may place session cookies on your computer, and they may collect and store your personal information on our behalf.
10. Third-Party Sites
  • The Services may provide links to a wide variety of third-party websites. You should consult the respective privacy policies of these third-party websites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.
11. Location of Services
  • If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that when we use and share your data as specified in this policy, we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

  • The Services are currently hosted in the United States, which means your personal information may be located on servers in the United States. This may change from time to time. The majority of contractors that CAP is using as of the effective date of this Privacy Policy are located in the United States and in Canada, but this may change from time to time.
12. Changes to this Privacy Policy
  • We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services and will revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.
EFFECTIVE DATE: 1 October 2018