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Privacy Policy Overview

Last modified: March 20th, 2020

1. Introduction

Bader Philanthropies, Inc. (“Bader” “us,” “our,” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website bader.org (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • on our Website;
  • in email and other electronic messages between you and our Website; and
  • when you interact with our promotional materials and applications on third-party websites and services, if those applications or promotional materials include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Bader or any third-party; or
  • any third party, including through any application or content that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Data Controller, Data Protection Officer, and Representative

Generally, Bader will serve as the data controller of the Personal Data you provide on the Website. At this time, Bader has not appointed a data protection officer or an EU representative. Bader will update this Privacy Policy in the event it does appoint a Data Protection Officer or an EU representative. Bader may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

3. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at baderphilanthropies@bader.org.

4. Information We Collect About You and How We Collect It

Generally

We collect several types of information from and about users of our Website (“Personal Data”):

  • by which you may be personally identified, such as name, e-mail address, and telephone number; and
  • information about your internet connection, the equipment you use to access our Website and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, and clickstream data.

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Website; and
  • from third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website is:

  • information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, using our services, or requesting further services or information. We may also ask you for information when you report a problem with our Website; and
  • records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

  • estimate our audience size and usage patterns;
  • improve and develop our Website and services; and
  • recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website through your computer or mobile device. A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. Specifically, analytics cookies provide us with information regarding what the most frequently visited pages on the Website are, help us record and debug any issues you may have with the Website, and show us how effective our promotional materials are. These analytics cookies do not allow us to see the usage of a single user, but they do allow us to see overall patterns of usage on the Website. We do not examine this information for individually identifying information, but we do use this information to understand the traffic on our Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). Please also review Google’s privacy policies (located at https://www.google.com/policies/privacy and https://policies.google.com/privacy/partners). Note that unless you set your browser to refuse these third party cookies, the Google Analytics cookies will expire after 24 months.

5. Lawful Basis for Processing Your Personal Data

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

  • Consent. By using our Website, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Website;
  • Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Bader and you; detect and correct bugs and to improve our Website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; and promote and market our services; and
  • As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. Special Categories of Information

Bader does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.

7. Automated Decision Making

Bader does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

8. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

  • to present our Website and their contents to you;
  • to provide you with information or services that you request from us;
  • to fulfill any other purpose for which you provide it;
  • to notify you about changes to our Website or any services we offer or provide though them;
  • to administer surveys;
  • to allow you to participate in interactive features on our Website;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by using us clicking the “unsubscribe” link at the bottom of any promotional email, messaging us through the “Contact Us” page of our Website, or by using the “Contact Information” set forth below. This opt out does not apply to services related communications.

9. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users and information that does not identify any individual without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services;
  • to a successor in the event of a merger or in the event of change in structure of our organization of any form, in which Personal Data held by Bader about our Website’s users is among the assets transferred;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; and
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply any contractual agreement between Bader and you; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bader, our customers, or others.

We do not control the collection and use of your information collected by third parties described above. Generally, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate and de-identify the information they collect with information from their other customers for their own purposes.

10. Your Rights Regarding Your Information and Accessing and Correcting Your Information

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

  • Access and Update. You can review and change your Personal Data notifying us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible.

We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

  • Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
  • Portability. To the extent the Personal Data you provide Bader is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
  • Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us using the information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
  • Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We will not delete your Personal Data unless we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
  • Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
  • How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below and through the “Contact Us” feature of our Website. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

11. Do Not Track Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking).

12. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

13. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area

If you are a resident of the European Economic Area (“EEA”), in order to provide our Website, and its services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by Bader to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website. To ensure your Personal Data (other than Personal Data you provide directly to us on our Website) is treated in accordance with this Privacy Policy, Bader uses Data Protection Agreements between Bader and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of

protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement, if applicable, by contacting us through the Contact Information below.

14. Data Retention Periods

Bader will retain your Personal Data for the entire time we have a lawful basis to process your data. We may also retain your Personal Data:

  • for as long as necessary to comply with any legal requirement;
  • on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
  • for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
  • for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

15. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email, if applicable, to the email address specified, or through a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

16. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may do so using the contact information below.

To Contact Bader

Bader Philanthropies, Inc.
3300 N. Dr. Martin Luther King, Jr. Drive
Milwaukee, WI 53212
(414)-224-6464
baderphilanthropies@bader.org

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