Please note that the Harold Grinspoon Foundation is based in the United States and subject to investigatory and enforcement powers of the Federal Trade Commission (FTC).
This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED
4. HOW WE USE YOUR PERSONAL INFORMATION
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how the Harold Grinspoon Foundation collects and processes your personal information through your use of this website, including any data you may provide through this website when you register/enroll in the PJ Library program via the site, subscribe to our newsletter, fill out a form or donate.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice, we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices. However, where there is a conflict, the notice provided on specific occasions will govern.
Our full details are:
Full name of legal entity: The Harold Grinspoon Foundation, a 501c3 non-profit organization.
Name of Information officer: Alex Zablotsky
Email address: firstname.lastname@example.org
Postal address: 67 Hunt Street, Suite 100, Agawam, MA 10001
You have the right to make a complaint at any time to the Information Regulator, the South African supervisory authority for data protection issues (email@example.com). We would, however, appreciate the chance to deal with your concerns before you approach the Information Regulator, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Users may visit our site anonymously. We will collect such personal identification information from users only if they voluntarily submit such information to us. Users can always refuse to supply such personal identification information, except that it may prevent them from engaging in certain site related activities associated with the PJ Library program (such as enrolling in the book-supplying program).
There is no statutory requirement for you to provide us with your personal information. However, if you do not provide your personal information, we will not be able to provide you with our services.
When enrolling, renewing or donating on our site, we may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender, as well as the name, birthday and gender of the child being enrolled in the program.
- Contact Data includes delivery address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Religious Affiliation Data includes your family affiliation and membership of a synagogue.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but does not directly or indirectly reveal your identity.
We do not collect Special Personal information about you (this includes details about your race or ethnicity, health or sex life, political opinions, and biometric information). Nor do we collect any information about criminal convictions and offences. We do however collect religious affiliation data directly from you, for confirming eligibility for certain site related activities associated with the PJ Library program (such as enrolling in the book-supplying program).
We may collect personal information from you about children. We comply with the requirements of COPPA (Children’s Online Privacy Protection Act). We do not collect any information from anyone under 13 years of age. Our website functionality is directed to people who are at least 13-years-old or older. If a parent or legal guardian is not signing up for the PJ Library service, we will request that the child’s parent or legal guardian consents to such processing.
How is your personal information collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact data and religious affiliation data by filling in forms or by corresponding with us. This includes personal information you provide when you:
- enroll in the PJ Library program;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us some feedback.
How we use your personal information
We will only use the details collected from you:
- For the purposes of confirming your eligibility for our programs, and for your enrolment and the administration of the site;
- To carry out services under our contracts with you;
- To improve customer service;
- To administer and maintain our activities and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- To contact you (including sending information and updates relating to any order, questions or requests) or for the provision of customer services;
- To use data analytics to improve our website, products/services, marketing, user relationships and experiences;
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
We rely on consent as a legal basis for processing your personal information (for example in relation to sending third party direct marketing communications to you via email or text message). You have the right to withdraw consent to marketing at any time by contacting us. In certain circumstances we rely on the fact that we must process your information to perform a contract with you.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
||Type of personal information
||Lawful basis for processing including basis of legitimate interest
|For the purposes of confirming your eligibility for our programs, and your enrolment and the administration of the site
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure programs are directed at the appropriate audiences)
To carry out services under our contracts with you
(e) Marketing and Communications
|Performance of a contract with you
|To improve customer service
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and maintain our activities and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security, and to prevent fraud)
(b) Necessary to comply with a legal obligation
|To contact you (including sending information and updates relating to any order, questions or requests) or for the provision of customer services
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how users use our products/services, and to develop them)
|To use data analytics to improve our website, products/services, marketing, user relationships and experiences
|Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services)
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established the following personal information control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you have enrolled in the PJ Library program and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside the Harold Grinspoon Foundation group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of enrolling in the PJ Library program.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal information
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
We may also be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We do not sell, trade, or rent personal identification information collected from users to others. We may share generic aggregated demographic information not linked to any personal identification information regarding users with our business partners, trusted affiliates and advertisers for the purposes outlined above. For example, if you have enrolled in the PJ Library program, we use a third-party contractor as an implementation partner.
If donations are collected, then we will use a third-party service provider to process your donations and we will share your information with them for that purpose only. We may also use third party service providers to help us operate our business and the site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes unless you have asked us not to do so at registration or afterwards.
We may disclose personal information obtained from you to third parties:
- In the circumstances set out above.
- If we sell or buy any business or assets, in which case we may disclose personal information obtained from you to the prospective seller or buyer of such business or assets.
- If PJ Library or substantially all its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes, and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We may transfer your personal information to a third party in a foreign country. The personal information may also be processed by staff who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your subscription, the processing of your payment details and the provision of support services. By submitting your personal identification information, you agree to this transfer, storing or processing. Before we transfer your personal information, we implement sufficient measures and agreements to ensure that the transfer is in accordance with applicable law, and there is a level of protection afforded to the personal information consistent with principles for reasonable processing of the personal information. These principles are substantially similar to the conditions for the lawful processing of personal information in your country and include provisions that govern onward transfer of personal information.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
At any time, a parent or guardian may revoke consent and direct us to delete your child’s information from our online data storage.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information, having provided adequate proof of identity, to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
Unless a fee has been legally prescribed, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our foundation in conducting and managing our foundation and this website to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any legitimate interests you may have, the potential impact on you (both positive and negative), and your rights, before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the conclusion or performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Service providers acting as operators:
- South African Board of Jewish Education (SABJE), which provides program management and logistics implementation through schools and other organisations for the PJ Library services’ distribution in South Africa.
- Formagrid Inc., having its address at 799 Market St., Floor 8, San Francisco, doing business as Airtable, which provides subscription services and systems to store user data.
- Professional advisers acting as operators including lawyers, bankers, auditors and insurers based in the USA who provide banking, legal, insurance and accounting services.
- Regulators and other authorities based in the USA who require reporting of processing activities in certain circumstances.