LAST UPDATED: February 7, 2012
Family Educational Rights and Privacy Act
YESHIVA has a policy to comply with the Family Educational Rights and Privacy Act (aka “FERPA”). Our FERPA policy is available for your review here.
What Information is Collected on the Site?
In order to make your use of the Site as worthwhile as possible, we may gather three basic types of information through the Site: Personal Information, Non-Personal Information and Internet Protocol Addresses.
Personal information is any information that identifies you as an individual and includes, for example, name; address; photos; e-mail address; telephone, wireless and/or fax number; short message service or text message address or other wireless device address; instant messaging address; or credit card number.
You do not have to provide Personal Information to access and use the public areas of the Site. However, in order for you to have access and use of certain restricted areas and features of the Site, we may require that you provide Personal Information.
We collect Personal Information from users of the Site, through users’ activities, transactions and completion of online forms such as when users register or subscribe for accounts or features on the Site, make online donations, order event tickets, complete surveys, join online communities, create profile pages, upload photographs, contribute to open forums that we may make available on or through the Site, submit a comment or question to us using a “contact us” or similar feature on the Site, send us an e-mail, or in any other way submit Personal Information to us via the Site.
When you visit and interact with the Site, YESHIVA and its third-party service providers may collect Non-Personal Information (for example, a catalog of Site pages you visit). Non-Personal Information is generally collected through the Site from different sources: (i) cookies; (ii) clear GIFs and similar technologies; (iii) environmental variables; and (iv) information that you voluntarily provide.
We and our service providers may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Site and/or in our communications with you to enable us to know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is used to, among other things, track the actions of Site users and e-mail recipients, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.
We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most websites, and can be used to optimize your experience on the Site.
Information That You Voluntarily Provide
YESHIVA also collects Non-Personal Information (e.g., demographic information, your interests, your geographic location) when you voluntarily provide such information to us. This information is Non-Personal Information because, unless combined with Personal Information, it does not personally identify you or any other user. Additionally, we may aggregate Personal Information in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using Personal Information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-Personal Information for purposes of this Policy.
Our servers automatically collect data about your server’s Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that’s automatically assigned to your computer by your Internet service provider whenever you’re on the Internet. When you request pages from the Site, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on the Site; the website you visit after the Site; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on the Site or a referral site; and other Web usage activity and data logged by our Web servers.
We and our service providers use this information for internal system administration, to help diagnose problems with our server, and to administer the Site. Such information may also be used to gather broad demographic information, such as country of origin and Internet Service Provider.
How do we use information collected?
We will use the Personal Information you provide to the Site, for example, to fulfill your requests for our programs and services, to respond to your inquiries about our offerings, and to offer you other programs or services that we believe may be of interest to you. We sometimes use this information to communicate with you, such as to notify you when we make changes to our services, to fulfill a request by you, to process transactions or to contact you about your relationship with us. We may also use your Personal Information for internal business and record keeping purposes. We may send you notices (e.g. in the form of e-mails, mailings), and otherwise correspond with you, about programs and events, sponsored by us and others, that we think might interest you. You may opt out of receiving certain notices from us by following the instructions in the Choices section below.
Because Non-Personal Information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share Non-Personal Information with third parties for any purpose.
In some instances, we may combine Non-Personal Information or IP Addresses with Personal Information (such as combining your name with your geographic location). If we do combine any Non-Personal Information or IP Addresses with Personal Information, we will treat the combined information as Personal Information as long as it is combined.
How do we share Personal Information collected?
When you contribute to a public area or feature of the Site, such as a chat room, community, bulletin board, list serve, personal Web page, calendar, news group, blog, wiki or other open forum that we may make available on or through the Site, the information that you submit may be made available to the general public. For this reason, we recommend that you exercise caution when submitting any sensitive information, including your full name, home address, phone number, other information that would enable other users to locate you, or financial information on these areas of the Site. Within many of these public forums, YESHIVA provides you privacy options that allow you to restrict the use and viewability of your Personal Information to others.
We may provide visitors an opportunity to receive offers from other third-party entities that have services, products and offers that we think might be of interest to you. Unless you elect not to receive such offers by following the instructions in the Choices section above, we may from time to time provide your Personal Information to these entities so that they may send you these offers.
We may use third-party service providers to help operate the Site and provide services including but not limited to data analysis, payment processing, order fulfillment and other services of an administrative nature. We may share Personal Information about you with these third parties for the purpose of enabling them to provide services to you or to us (for example, if you choose to make a purchase through the Site, we may share your Payment Information or other Personal Information with our third party service providers to fulfill your purchase, including, to process your credit card or payment account number or to ship products to you).
Legally Compelled Disclosures; Emergencies
We reserve the right to transfer any and all information that we collect from Site users 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 YESHIVA’s operation or assets (including without limitation in connection with any bankruptcy or similar proceedings).
Processing of Transactions
When you make a purchase or donation through the Site, we may collect your credit card number or other payment account number (for example, your wireless account number), billing address and other information related to such purchase (collectively, "Payment Information") from you, and may use Payment Information in order to fulfill your purchase or donation. We may also provide Payment Information, or other Personal Information provided by you, to third parties as necessary to complete your transaction (for example, to process your credit card or payment account number). To the extent that Payment Information includes Non- Personal Information, use of Non- Personal Information is governed by the section on Non-Personal Information below.
You may have the right to make choices (“opt in” and “opt out”) of certain of our uses of your Personal Information. For example, at the time you are requested to provide Personal Information on the Site, you may have the opportunity to elect whether to receive certain types of correspondence from us, or to whether your information will be shared with third parties for marketing purposes. You may also make a request regarding how your information is used by sending an e-mail to firstname.lastname@example.org or by clicking on an opt-out link within an e-mail you receive. Clearly indicate what choices you are making (electing not to receive promotional communications message from YESHIVA or requesting that we not share information with third parties for the third parties’ marketing purposes). Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, donations and communications with us.
Please note that if you opt-out as described above, we will not be able to remove Personal Information about you from the databases of third parties with which we have already shared Personal Information as of the date on which we implement your opt-out request. If you wish to cease receiving marketing-related e-mails from third parties, please contact the third parties directly or use any opt-out mechanisms set forth in their respective privacy policies or marketing-related e-mails.
If the e-mail address you provide to us is a wireless e-mail address, you agree to receive messages at such address from YESHIVA (unless and until you have elected not to receive such messages by following the instructions in the Choices section above). You understand that your wireless carrier’s standard rates apply to these messages, and that you may change your mind at any time by following the instructions in the Choices section above. You represent that you are the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.
Access and Correction
If you would like to access Personal Information we have collected about you through the Site or if you would like to update, correct or limit the use of any Personal Information you have provided to us via the Site, please email us at email@example.com.
For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request and consistent with applicable law. You must clearly indicate the Personal Information that you wish to have changed, clearly indicate that you wish to have your Personal Information or clearly indicate the limitations you wish to put on our use of your Personal Information. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.
While YESHIVA will use reasonable organizational, technical and administrative measures to protect the security and integrity of sensitive Personal Information provided to the Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. Please do not send us sensitive information through email.
You may be able to create an account on the Site with a username and password. You are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Site by you or any person or entity using your password, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee or agent. You agree to (a) immediately notify YESHIVA by contacting us in accordance with the "Contacting Us" section below of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use another method to notify you in this situation, please e-mail us at firstname.lastname@example.org with the alternative contact information you wish to be used.
Consent to Processing
By providing Personal Information to the Site, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories.
Third-Party “Linked-To” Sites
Note Regarding the Use of the Site by Children
The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through the Site.
If you have any
questions or comments
regarding our privacy practices, you may contact us at Andrew J. Lauer, Esq.
2495 Amsterdam Avenue
New York, NY 10033-3201