PRIVACY POLICY

TABLE OF CONTENTS
I. INFORMATION WE COLLECT ABOUT YOU
II. HOW WE USE YOUR INFORMATION
III. LINKS TO OTHER WEBSITES
IV. INFORMATION SECURITY
V. DATA RETENTION
VI. YOUR CHOICES
VII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS
VIII. CHILDREN’S INFROMATION
IX. EXERCISING YOUR DATA SUBJECT RIGHTS
X. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING
XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY
XII. “DO NOT TRACK” SIGNALS
XIII. CHANGES TO THIS PRIVACY POLICY
XIV. HOW TO CONTACT US

The Leon D. Black Foundation (hereinafter referred to as “the Foundation,” “us,” “we,” or “our”) created this Privacy Policy to apply to information collected through this website (JewishLives.org) and all digital assets contained or offered therein (“Website”), and through any offline activities (collectively, our “Services”), except as described below. This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.

This Privacy Policy is integrated into and supplements our Terms of Use (“Terms”).

By using the Services and providing us with your Information (defined below in Section I), you acknowledge and agree to the practices described in this Privacy Policy and Terms referenced above and to any updates to these policies posted here from time to time.

In certain U.S. States, you may be entitled to certain individual rights under applicable Data Protection Laws. Please see the Notice to Certain Residents of Data Subject Rights for more information. While this Website may be available to you in another jurisdiction, the Website is directed to those individuals and entities located in the United States, and not to any other jurisdiction.

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties.  The information covered herein is referred to collectively as “Information,” and may include “Personal Information” or “Personal Data” as those terms are defined under applicable law. Specifically, Information includes any information relating to an identified or identifiable natural person, who could be identified either directly or indirectly by reference to an identifier such as name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

A. Information You Provide to Us

In using our Services, you may provide us with Information, including, without limitation:

• Individual identifiers such as name, username, date of birth;

• Contact information such as mailing address, email address, postal address, and telephone number(s);

• Commercial information such as products or services purchased, obtained, or considered;

• Communications with us, preferences, or other Information you provide to us such as any messages (including via online chat features), opinions, and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other Information that you share with us when you contact us directly (such as for customer support services);

• Responses when you voluntarily participate in a survey or interview regarding our services; and

• Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Sensitive Information. We may need to collect or process Information that is deemed “sensitive information” or “sensitive data” under certain laws. We may process the following categories of sensitive information when you use our Services:

• Geolocation information, such as your physical location if you have enabled location services on your device; and

• Payment and transaction information including credit or bank card information in combination with any required security or access code collected for the purpose of processing payment for our products or Services by our third-party payment processor.

When required by applicable law, the Foundation will collect consent prior to processing certain categories of sensitive Information.

B. Information we may automatically collect about you

Our Services may automatically collect certain Information about you.  This Information may be used by the Foundation for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services.  This Information may include:

• IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);

• Location from which you visit or use our Services;

• Date and time of your visit or use of our Services;

• Domain server from which you are using our Services;

• Type of computer, web browsers, search engine used, operating system, or platform you use;

• Data identifying the web pages you visited prior to and after visiting our website or use of our Services;

• Your movement and activity within the Services, which is aggregated with other information; and

• Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).

C. Cookies & Technologies Use to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, and other technologies.  Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Services.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

• Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).  We may also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services.  These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf.  Our Services may use retargeting pixels from Google, Facebook, and other ad networks.  We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

• Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.  You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.

• Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

• Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  We are committed to providing you with meaningful choices about the Information collected on our Services for online advertising and analytics purposes, and that is why we provide the variety of opt-out mechanisms listed herein.  However, we do not currently recognize or respond to browser-initiated DNT signals.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that disclosing information to these online tracking technologies is deemed to be a “sale” or “sharing” under certain laws, you can opt out of these online tracking technologies by submitting a request via contact@jewishlives.org or by broadcasting an opt-out preference signal, such as the Global Privacy Controls (GPC). Please note that some features of our website may not be available to you as a result of these choices.

D. Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook and Instagram (“Social Media Platforms”), and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes. Information we may access about you, with your consent, may include, but is not limited to, your basic Social Media Platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Media Platform.  Please keep in mind that when you provide Information to us on a third-party website or platform (for example, via our applications), the Information you provide may be separately collected by the third-party website or the Social Media Platform.

The Information we collect is covered by this Privacy Policy, and the Information the third-party website or Social Media Platform collects is subject to the third-party website or platform’s privacy practices.  We encourage you to be aware when you leave our Services and to read the privacy policies of other sites that may collect your Information. You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

• To provide you with the Services and information you request;

• To respond to your comments, inquiries, and questions and provide customer service;

• To tailor promotions or other offerings for you and to reach new customers;

• For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;

• To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;

• To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;

• To comply with our Terms of Service or comply with other contracts we have with you;

• Analytics for business purposes and business intelligence;

• To comply with any applicable laws and regulations and respond to lawful requests; and/or

• For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing Your Information

We may share your Information as set forth in this Privacy Policy and in the following circumstances:

• Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, to process payments, to assist with fraud and cybersecurity, manage databases, perform analyses, provide customer service, or send communications for us).  These third-party service providers are authorized to use your Information only as necessary to provide these services to us.  In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.

• Disclosure of Information for Legal, Administrative and Regulatory Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate with or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates, and any of our or their officers, directors, employees, attorneys, agents, contractors and partners, and the Services users; (v) to enforce or apply our Terms of Service; and (vi) to verify the identity of the user of our Services.

• Business Transfers. Your Information may be shared, transferred, sold, or otherwise conveyed (“Conveyed”) to a third party in connection with, or during the negotiation of: (i) a merger with or acquisition by another business entity; (ii) a financing; (iii) a sale of all or substantially all our assets; (iv) an adjudication of bankruptcy; or (v) a liquidation or other  You agree to any and all such Conveyances of your Information.

• Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates, including but not limited to entities and brands within the Foundation.

• De-Identified or Aggregated Data. We may aggregate, anonymize, and/or de-identify any Information collected from you so that such Information can no longer be linked to you or your device.  We may use aggregated, de-identified or anonymized Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

• With Your Consent. We may share Information consistent with this Privacy Policy with your consent.

C. Sale or Sharing of Your Information

For purposes of this Privacy Policy, “sell,” “sold,” or “sale” means the disclosure of Information for monetary or other valuable consideration but does not include, for example, the transfer of Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. “Sharing” means disclosing or making available Information to a third-party for purposes of cross-contextual behavioral or targeted advertising. While we do not disclose information to third parties in exchange for monetary compensation, we disclose identifiers and Internet and network activity information to third-party advertising networks and analytics providers for purposes of marketing and advertising, and to improve and measure our ad campaigns. Such disclosures may be considered “sales” or “sharing” of Information under applicable laws. We do not sell or share sensitive Information, nor do we sell or share Information about individuals we know are under age sixteen (16).

D. Use and Disclosure of Sensitive Information

We do not collect, use, or disclose sensitive Information beyond the purposes authorized by applicable law. Accordingly, we only use and disclose sensitive Information as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) with our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

III. LINKS TO OTHER WEBSITES

Our Services may contain links to third-party websites that are subject to their own terms of service and privacy policy.  If you submit personal Information to any of those websites, applications or Social Media Platforms, your Information is governed by their privacy policies.  We have no control over, do not necessarily endorse, and are not responsible for, the content, advertising, products, services, or other materials on or available from these websites or for any information that you may submit on that site. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of th linked website, Social Media Platform, and/or content.

IV. INFORMATION SECURITY

We use commercially reasonable measures to provide our Services.  However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure.  Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure.  We do not guarantee that your Information will not be misused by third parties.  We are not responsible for the circumvention of any privacy settings or security features.  You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information. If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly How to Contact Us so that necessary measures can quickly be taken.

V. DATA RETENTION

We will retain your Information for as long as needed to provide you Services.  We will retain and may continue to process your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us.  We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

VI. YOUR CHOICES

1. Marketing Communications. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see How to Contact Us below for more information.

2. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:

1. You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at aboutads.info/appchoices.

2. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

3. You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

VII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

Residents of certain U.S. states may have rights and choices regarding their personal information. To the extent any data protection law applies to our collection of your personal information, this supplemental section of our Privacy Policy outlines the individual rights you may be entitled to and how to exercise those rights.

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.

• Right to Know and Access. You may have the right to request that we confirm whether we process your personal information, and to request information about our collection and use of your personal information, including whether we sell or share your personal information. You also have the right to request access to personal information we may process about you.

• Right to Data Portability. Where the processing is carried out by automated means, and subject to certain exceptions, you may have the right to request and obtain a copy of your personal information that you previously provided to us in a portable format. In addition, to the extent technically feasible, you may have the right to obtain your personal information in a readily usable format that allows you to transmit the personal information to another data controller without hindrance.

• Right to Request Correction of Inaccurate Personal Information. To the extent that we may maintain inaccurate personal information, you may have the right to request that we correct such inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

• Right to Request Deletion. You may have the right to request that we delete certain personal information or records provided by or obtained about you, with certain exceptions and limitations as allowed under law.

• Right to Opt Out of the Sale and Sharing of Personal Information. You may have the right to opt out of the processing of your personal information for the purpose of selling or sharing your personal information for cross-context behavioral advertising. We do not sell or share your personal information.

• Right to Opt-Out of the Use of Personal Information for Targeted Advertising and Profiling. You may have the right to opt out of the processing of your personal information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not use your Information for targeted advertising or profiling purposes.

• Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to request that we limit the ways we use and disclose your sensitive personal information to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or as authorized by law.

• Right to Non-Discrimination. You may have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or Services for no fee, if you have exercised your right to opt-out.

• Right to Disclosure of Direct Marketers. You may have a right to know the categories and names/addresses of third parties that have received personal information for their direct marketing purposes upon simple request, and free of charge.

• Right to Appeal. You may have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeal request via the information in the How to Contact Us section below or using the Your Privacy Choices form. Within the certain timeframe of receipt of your appeal, as proscribed by the applicable law we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Attorney General or another authority which we will help you identify.

To learn more about whether you are guaranteed certain rights, or to submit a request to exercise your rights, please contact us using any of the methods in the How to Contact Us section.

VIII. CHILDREN’S INFORMATION

The Services are not intended for use by persons under the age of thirteen (13). We do not knowingly collect any personal information from anyone under thirteen (13) years old. In the event that we discover that a person under the age of thirteen (13) (or a higher threshold where applicable) has provided personal information to us, we will take steps to comply with any applicable legal requirement to remove such personal information.

Contact us if you believe that we have mistakenly or unintentionally collected personal information from a child under the age of thirteen (13).

IX. EXERCISING YOUR DATA SUBJECT RIGHTS

To exercise any of the rights described above, please submit a verifiable consumer request to us via the methods described below.  The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request.  In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request.

If permitted by the applicable data protection law, you may use an authorized agent to submit requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf.  If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant under applicable law.  Only you or your authorized agent may make a verifiable consumer request related to your Information.  We may deny a request from an authorized agent that does not submit proper verification proof.  You may also make a verifiable consumer request on behalf of your minor child.

X. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services are targeted to individuals located in the United States. As such, the Services collect Information and process and store that Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information you consent to the transfer of such personally identifiable Information to the United States.

XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

XIV. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Mail:  Attention: JewishLives.Org c/o The Leon D. Black Foundation
445 Park Avenue Suite 1401
New York, NY 10022
Email: Contact@jewishlives.org

Last Updated: September 1, 2024