PRIVACY POLICY
The Statue of Liberty & Ellis Island Foundation (“SOLEIF,” “we” or “us” or “our”),
understands your concerns about privacy and how your information is used and safeguarded,
and we want to provide you with more information on these topics. This Privacy Policy (the
“Privacy Policy”) describes the practices, policies and procedures related to the website located
at www.statueofliberty.org, all other websites to which this Privacy Policy is linked, and our
Kiosks and systems located on both Liberty and Ellis Islands (collectively, the “Platform”),
including the types of personal information we collect on the Platform, how we may use that
information, and with whom we share it. Please note that this Privacy Policy applies only to our
online information-gathering and dissemination practices via the Platform and does not apply to
any of our practices conducted offline.
By visiting the platform, you consent to our using any personally identifiable information that
you provide to us or that we collect in accordance with the terms of this privacy policy. If you
do not agree to this policy,
please do not visit or use the platform. We may update this privacy
policy from time to time, so please check this privacy policy periodically for changes.
Summary
The notifications provided by this Privacy Policy include:
What personally identifiable information we collect through the Platform.
How we use the information we collect.
With whom the information may be shared.
The kind of procedures we employ in an effort to hinder the unauthorized access, use
or disclosure of information you provide to us.
Information related to third-party websites.
The laws that apply to those accessing the Platform
How you can learn about changes to the Privacy Policy
How you can amend the information we collect on you
Rights related to the European Union’s General Data Protection Regulation
Personal Information You Provide and How It Is Used
You are not required to provide any personally identifiable information in order to gain access to
the public, non-password protected portion of the Platform. You are free to visit the Platform to
learn more about us and what we do without entering any personally identifiable information.
However, to obtain access to the password protected portion of the Platform and to use certain
features provided by SOLEIF (“Services”), you will be required to register as a user and create a
user profile, and other features; other features also require that you provide us with some
personally identifying information (such as name, address, email address, telephone number,
and/or credit/debit card information) and other information (including general demographic
information) that you voluntarily provide to us, as more particularly described below. Except for
the forms we provide to transmit such information, please do not send sensitive, personal or
confidential information to us directly through the Platform, or by email to any of the contact
email addresses listed on the Platform. Please note that for United States residents, we only
collect personal information directly from you when you provide it to us (please see the GDPR
caveats below).
Examples of instances in which we may collect personal information include:
User Profile: During registration, you will be prompted to provide information including your
name, address, email address, and phone number. When establishing membership status, you
may be prompted to provide additional information such as credit card information and billing
address.
User Submissions: Certain interactive elements (“Interactive Pages”) on the Platform permit the
submission of information and content by users, and the hosting, sharing and publishing of such
user content, including, but not limited to, posting annotations, posting photos for The American
Flag of Faces® exhibit, The American Immigrant Wall of Honor® information and creating
your own Family History. Such content, including any information, text, graphics, audio,
images, and links you submit is referred to as “Submissions”. We urge you to be cautious when
making Submissions as information, statements, data, and content such as images or videos that
you include in your Submissions might, or are likely to, reveal your gender, ethnic origin,
nationality, age, and/or other personal information about you. You acknowledge that all
Submissions to the Platform are voluntary on your part. You agree and acknowledge that upon
uploading, posting or submitting your Submissions on the Platform, such Submissions shall be
considered non-confidential information and users may use any ideas or information included
therein. Please note that “removal” of Submissions means only that it will not be visible to other
users via the Platform, except for those Submissions that have already been viewed by other
users and retained by them on their respective devices.
User Interaction: Certain features on the Platform provide you an opportunity to share content
and information with others, including through email notifications or invitations to the Platform.
We are not responsible for any of your communications using such features and for any
information you choose to include therein.
Kiosks: If you opt to use our Kiosks, you may be asked to provide certain personally identifying
information in order for us to provide you with the information you are seeking.
Donate; If you make a donation through the Platform via “donate” button, you will be asked to
provide certain personally identifying information, such as your phone number, name and
home address, as well as your credit card billing information, in order to process the donation.
Unless you opt to donate to us on a monthly basis, the credit card information that you provide
at the
time of donation is used only to process your donation and will not be stored or used for any
other purpose. Please note that we work with third parties to host and administer the shop, and to
process your payment transactions, and any information you share may also be shared with such
third parties.
Online Store: If you opt to buy an item from our online store, we will ask you to provide certain
personally identifying information, such as your name and home address, as well as your credit
card billing information, in order to process the transaction. The credit card information that you
provide will only be used only to process your online-purchase transaction and will not be
stored or used for any other purpose. Please note that this store is hosted and managed by a third
party on our behalf, and therefore such third party will have access to any information that you
provide.
Polls; Surveys: We may conduct polls and surveys either directly or through third parties. Your
selection may be random, or it may be based on your non-personally identifiable information,
such as geographic location, etc. You participation in a poll or survey is voluntary. SOLEIF or
its third-party contractors may target some advertisements or incentives to you based on the
polls or surveys results. If the delivery of incentives requires your contact information, you may
be asked to provide personally identifiable information to the third-party provider fulfilling the
incentive offer, which will only be used for the purpose of delivering incentives and/or verifying
your contact information. Taking advantage of such incentive and providing such information is
voluntary and at your sole discretion.
Career Opportunities: If you opt to learn more and/or apply to any of our career opportunities,
you will need to submit certain personally identifying information about yourself.
Contact Us: If you contact us through the contact form option on the Platform, we will ask that
you provide your name and email address, and you will have the option to provide additional
information in your communication with us. We will use the information you provide to contact
you back and to respond to your inquiries.
Information You Share: Certain interactive pages on the Platform provide you with an
opportunity to make Submissions and share your information with others. When you use such
interactive pages you should be aware that any information you include is made publicly
available to others and can be read, collected or used by them.
Email List: Please note that whenever you communicate with us, whether via your
registration, “contact us” forms or other methods, the information we collect from you (e.g.,
name, address, email address) will be added to our electronic mailing lists.
Non-Personal Information We Collect by Automated Means And How We Use It
We collect certain information by automated means when you visit the Platform. Much of this
information is collected through the use of third-party tracking services, which includes Google
Analytics. The information collected may include usage information, such as the numbers and
frequency of users to the Platform, pages visited, web browsing histories, social networking
activities and similar data. For example, we automatically gather the number and frequency of
visitors to this site. This collective, aggregated data helps us determine how much our visitors
use parts of the Platform, and do internal research on our users’ demographics, interests, and
behavior to better understand and serve you. When gathered, this this data is used in the
aggregate, and not in a manner that is intended to identify you personally. This type of aggregate
information may be shared with third parties at any time. In addition to the third-party tracking
services mentioned above, we also collect this information through various other means,
including "cookies," "web beacons", IP addresses and other means, as further explained below.
Cookies and Web Beacons: Like most websites, we utilize “cookies” and “web beacons” to,
among other things, track usage and trends, allow you to navigate quickly through our Platform,
facilitate the login processes, allow you to personalize your experience, store your settings and
improve the quality of our Platform. We also use cookies to collect Platform usage information,
which helps us improve our Platform experiences by measuring which areas are of greatest
interest to users. Further, we may use cookies and cookie-equivalent technologies to increase the
security of the Platform. We do not store unencrypted personally identifiable information in the
cookies.
Cookies are small strings of data that are sent by the Platform to your browser and then stored
by your browser on your computer, mobile phone, or other device, and allow us to recognize
you as a user when you return to the Platform using the same device and web browser. Most
web browsers automatically accept cookies, but it is possible to change your browser setup or
apply other means so that it does not accept cookies. However, rejecting cookies may prevent
you from taking advantage of certain portions of the Platform.
We use both “persistent” and “session” cookies. Persistent cookies are set once you have logged
into the Platform and will allow us to recognize you as an existing user the next time you access
such that you will not need to log-in before you use the features and services. However,
regardless of the placement of a persistent cookie on your computer, in order to access or change
any private information in your account or to use certain Interactive Pages of the Platform, you
may be required to use your log-in credentials. Session cookies are used to identify a particular
visit to the Platform and expire after the elapse of a set period or when you close your web
browser. We may use different technologies to place such cookies.
Web beacons are very small images or small pieces of data embedded in images, also known as
“pixel tags,” “GIFs,” or “clear GIFs,” that can recognize cookies, the time and date a page is
viewed, a description of the page where the pixel tag is placed, and similar information from a
computer or device.
Cookies, web beacons and other technical methods may involve the transmission of information
either directly to us or to another party authorized by us to collect information on our behalf.
Cookies and web beacons do not personally identify SOLEIF users.
We may authorize third parties to place or recognize a unique cookie on your browser to serve
you with advertisements or to optimize the Platform. Any information provided to third parties
through such cookies will not include personally identifiable information but rather only
aggregated anonymous information (e.g. your geographic location) to enhance your user
experience by providing you with more relevant advertising.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you
receive a new cookie, and how to disable existing cookies. Please note, however, that without
cookies you may not be able to take full advantage of all the features on our Platform. Our
cookies do not gather personally identifiable information.
Log files, IP Addresses, Java Script, Analytics and other Tracking Information: Adoption of
communications standards on the internet and our use of standard analytical tools such as
Google Analytics result in or may lead to the automatic receipt and tracking of (i) the URL of
the website from which you came and the website to which you are going when you leave the
Platform; (ii) the internet protocol (“IP”) address of your computer (or the proxy server you use
to access the World Wide Web); (iii) your computer operating system and type of web browser
you are using; (iv) email patterns; (v) your mobile device (including your UDID) and mobile
operating system (if you are accessing the Platform using a mobile device), (vi) your ISP or
your mobile carriers name.
Additionally, advertisers may receive the URL of the page you were on when you click on an
ad on the Platform. The link between your IP address and your personally identifiable
information is not shared with third parties without your permission.
Do Not Track Notice
Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit
that you do not want to have your online activity tracked. How browsers communicate and
respond to the Do Not Track signal is not yet uniform. For this reason, like many web websites,
the Platform does not currently respond to or alter its practices when it receives a Do Not Track
signal. Please note that third parties may collect personal information about your online activities
over time and across different websites when you visit our Platform or other online websites and
services. To find out more about “Do Not Track,” you may wish to visit
http://www.allaboutdnt.com.
Your Use of Personal Information
Certain Services available on the Platform are designed specifically to collect data that is linked
to the personally identifiable information such as creating a Family History, The American
Immigrant Wall of Honor® and The American Flag of Faces®. SOLEIF’s users may use this
information in any manner they choose to accomplish their own goals and missions.
Use of Your Personal Information
We collect, retain and use personally identifiable information or other information you provide
to us via the Platform for business purposes only, including without limitation in the following
ways: (a) to qualify you as a registered user with access to the password-protected portion of the
Platform; (b) to provide Services to registered users and to otherwise operate the Platform; (c) to
respond to an inquiry from you or address a request submitted by you (including contacting you
directly to request additional information to process your inquiry or request; (d) to contact you
and provide you with information regarding SOLIEF; (e) to notify you about your accounts or
transactions with us and to otherwise contact you with information we believe is of interest to
you; (f) to correspond with you about our features or services or special offers related thereto;
(g) to facilitate the payment of any fees necessary to access the Services; (h) to enhance or
develop the Platform, and the features and services; (i) to monitor the usage of the Platform and
any services and features offered; (j) to provide third parties with aggregate anonymous
non-personal information about our user base and usage patterns; (k) to personalize the features
and services and, if relevant, to provide advertising that you and others see based on your
characteristics or preferences; (l) to comply with applicable laws, regulations and rules, and
requests of relevant regulatory and law enforcement and/or other governmental agencies; (m) to
enforce our TOU; and/or (n) to protect the rights, property, or safety of SOLEIF, our personnel,
users, and others.
We may use the email address you provide to us to send you notifications, updates, newsletters
or information regarding our Platform and any features or services.
Sharing of Personal Information by SOLEIF
Except as otherwise stated herein, we do not sell or rent your personally identifiable information
to third parties. We may share your personally identifiable information only with our third-party
service providers to provide you with the features and services on the Platform. For example, we
may hire or collaborate with third party contractors to help manage emails, and for that purpose
we may provide them with your email address and certain other information in order for them to
send you email messages on our behalf. Similarly, we may hire contractors to host or operate
some of our websites and related computers and software applications. Access to your personally
identifiable information by these contractors is limited to the information reasonably necessary to
perform their limited function for us. We also require that these contractors protect the privacy of
your personally identifiable information in a manner consistent with this Privacy Policy, and not
use or disclose your personally identifiable information for any purpose other than providing us
with products or services for which we contracted them. We may also allow third parties to place
advertisements on the Platform.
We may share aggregate anonymous statistical non-personal information regarding the users of
the Platform, traffic patterns, and Platform usage with our sponsors, patrons, or advertisers.
Additionally, we may periodically exchange member and/or supporter postal mailing lists with
other organizations, who similarly provide us with their mailing lists. Mailing list exchanges
provides the SOLEIF with a cost effective way to potentially expand our membership base by
obtaining the names and addresses of other likely donors. Please note that we do not exchange or
rent email addresses. If you prefer that we do not exchange your name and postal address, please
email us at ContactUs@libertyellisfoundation.org with “do not exchange” in the subject line of
the email, or call us at (212) 561-4500 and let us know that you do not want your name and
address shared. In every case we will do our best to promptly respond to your request.
Storage Personal Information
Your personally identifiable information is stored and processed in the United States. By using
the Platform or any of our features and services, you consent to the transfer of your personally
identifiable information outside of your country of residence.
How We Attempt to Safeguard Your Information
We maintain – and ask that any third-party partners who may store information on our behalf to
maintain – administrative, technical and physical safeguards for the Platform designed to protect
your personal information against theft, loss, misuse or unauthorized access, disclosure,
alteration or destruction of the personal information that we collect from you. However, no
website, application or transmission can guarantee security. Thus, while we have established and
maintain what we believe to be reasonable procedures to protect the confidentiality, security,
and integrity of personally identifying information obtained through the Platform and we strive
to protect your personal information, we cannot ensure or warrant the security of any
information you transmit to us.
Children’s Privacy
The public portion of the Platform is open to non-registered users. The non-public, password
protected portion of the Platform and the Services are open only to registered users who must be
13 years of age or older. We do not knowingly collect personal information from or allow any
Submissions or purchases by children under 13 years of age. If you are under the age of 13 (or
otherwise under the applicable age limit of your country), please do not submit any personally
identifiable information to us. You may rely on your parent or guardian to assist you.
Parents or legal guardians may contact us to ask if we have collected their child’s personal
information, to review such information, if any, and request that we stop collecting this
information and have it deleted. Such requests should be made in writing to
ContactUs@LibertyEllisFoundation.org and are subject to SOLEIF’s right to verify to our
satisfaction that the request has in fact been made by the child’s parent or legal guardian. If we
learn that we have collected personally identifiable information from a child without the consent
of a parent or guardian, we will take all reasonable steps to delete the personally identifiable
information in the absence of contrary written instruction from such parent or guardian.
Third Party Platform; Advertisements
The Platform may contain links to third party websites that allow users the ability to download
or access software or content. Please note that we have no affiliation with any of these other
parties and/or websites, and cannot control and are not responsible for the information
collection, use, and disclosure practices of such third parties; we encourage you to review and
understand their privacy practices and policies, if any, before using providing any personally
identifying information to them or initiating any financial transactions. You should be aware that
if you voluntarily disclose personally identifiable information in your communications with
third parties linked from on the SOLEIF Platform or in other materials, that information, along
with any other information disclosed in your communication, can be collected and used by such
third parties and may result in your receiving unsolicited messages from other persons. We are
not responsible for the content or information of these websites, or any other use of the linked
website.
California Privacy Rights
California Law permits our users who are California residents to request certain information
regarding our disclosure of personal information to third parties for their own direct marketing
purposes. SOLEIF does not share your information with third parties for the third parties’ own
and independent direct marketing purposes, and will not do that unless we receive your
permission. To make inquiries about our sharing practices or your rights under California law,
please write to us at:
Statue of Liberty & Ellis Island Foundation, 39 Broadway, Suite 2030, New York, NY 10006
Questions and Contact Information
If you have any questions or concerns about this Privacy Policy or your rights, please email
ContactUs@LibertyEllisFoundation.org, call 212-561-4500 or send your questions or
concerns in writing to:
Statue of Liberty & Ellis Island Foundation, 39 Broadway, Suite 2030, New York, NY 10006.
Privacy Policy Revisions
We reserve the right to revise this Privacy Policy at any time by updating this posting. Please
check back regularly and to see if there have been any changes to this policy, which you can
determine by reviewing the Effective Date listed below. By continuing to use the Platform after
those changes become effective, you agree to be bound by the revised Privacy Policy.
SPECIAL NOTICE TO EUROPEAN UNION AREA,
SWITZERLAND AND UNITED KINGDOM USERS
The following provisions applies only to users residing in the European Union Area, Switzerland
and the United Kingdom.
Please note, pursuant to the European Union General Data Protection Regulation (“GDPR”), we
are required to provide those residing in the European Union, Switzerland and the United
Kingdom (hereinafter, the “EU Users”) additional information and rights related to the Personal
Data we collect about them. We summarize such information and rights below.
For the purposes of this GDPR Privacy Notice section, “Personal Data” means any information
relating to an identified or identifiable person.
Purpose For Information Collection
As noted in this Privacy Policy, you may visit our Platform without being required to provide us
with any Personal Data. However, should you decide to provide such information, the
information we collect will be used to meet your requests, or to provide you with the applicable
information or service requested, and as further described herein.
Legal Grounds For Processing Personal Data
SOLEIF will process personal data that we receive from EU Users on the ground that it is in
our legitimate interest for the effective administration of the Platform, to fulfill and/or address
your requests, or to provide certain services.
Sharing Your Personal Data
We may share your Personal Data as further described in this Privacy Policy.
Your Information and Your Choices; Withdrawal of Consent
GDPR provides EU Users with additional rights in respect to the Personal Data we hold about
you, including:
o The right of access
If you ask us, we will confirm whether we are processing your Personal Data and, if
necessary, provide you with a copy of that Personal Data (along with certain other
details).
o Your right to correction (rectification)
If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to
request to have it corrected.
o Your right to erasure
You can ask us to delete or remove your Personal Data in some circumstances, such as
where we no longer need it or if you withdraw your consent (where applicable).
o Your right to data portability
You have the right, in certain circumstances, to receive a copy of Personal Data we have
obtained from you or otherwise collected.
o Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your
Personal Data, you have the right to withdraw that consent at any time.
o Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we
have handled your Personal Data, you can report it to the relevant supervisory authority.
Upon appropriate written request we will update or amend your Personal Data, but we reserve
the right to use any information previously obtained to verify your identity or take other
actions that we believe are appropriate and lawful. You may access, correct, or request
deletion of your Personal Data – or request that we stop any processing of your Personal Data
- by contacting us at the address listed above. We will respond to your request
within a reasonable timeframe. Certain requests – like being removed from our
e-newsletter mailing list – can also be accomplished via our unsubscribe links.
We may need to retain certain information for record keeping purposes, and there may also be
residual information that will remain within our databases and other records, which will not
be removed from such locations. Additionally, there may be circumstances in which we are
not legally required to comply with your request because of the laws in your
jurisdiction or because of exemptions provided in data protection legislation in general, and
GDPR in particular. Finally, we are not responsible for removing or deleting information from
the databases of third parties (such as service providers) with whom we have shared
information about you, but we will make the request on your behalf for such
removal/deletion.
Data Retention
We will retain your information for as long as needed to provide you services, or otherwise as is
reasonable and customary given the nature of the relationship you have with SOLEIF. We may
need to retain certain information for record keeping purposes, and there may also be residual
information that will remain within our databases and other records, which will not be removed
from such locations. Otherwise, we will retain and use your information as necessary to comply
with our legal obligations, operate/promote our Platform, and to foster our relationship with our
users. We have a data retention and destruction plan that dictates the policies and procedures
related to deletion and/or destruction of all information/data.
Children’s Privacy/Note To Parents Of Children Residing In The European Union,
Switzerland and the United Kingdom
We do not intentionally or knowingly collect, use, or disclose personally identifiable information
about EU Visitors to our Platform that are less than 16 years of age. If a child under the age of
16 submits information to us through any part of the Platform and SOLEIF becomes aware that
the user submitting the information is under the age of 16, the information provided will be
deleted as soon as it is discovered and not used for any purpose. If you are the parent or guardian
of a child under 16 years of age and believe that they have disclosed personally identifiable
information to us, please contact us, and please include in your message the same name and
email address that you believe your child submitted, if applicable.
How To Contact Us
SOLEIF, Inc., (the Data Controller) is the owner and operator of the Platform. If you need to
contact us for any reason related to this Privacy Policy or your use of the Platform, please
contact us at the following address:
Statue of Liberty & Ellis Island Foundation
39 Broadway, Suite 2030
New York, NY 10006
PRIVACY POLICY EFFECTIVE DATE
This Privacy Policy is effective as of August 1, 2022.
DONOR PRIVACY POLICY
The Statue of Liberty-Ellis Island Foundation, Inc. (“SOLEIF” or “we” or “our”) respects the
privacy of every individual and is committed to protecting your privacy. We
understand your
concerns about privacy and your interest in knowing how your information is used and
safeguarded when you make a donation to us, and we want to provide you with more
information on these topics. We have created this Donor Privacy Policy (the “Donor Policy”) in
order to provide our donors with complete information related to our
practices, policies and
procedures in relation to all of the information that we collect from them. Please note that this
Donor Policy applies to all information collected both online – including from our website
located at www.statueofliberty.org (the “Website”) - and offline, from all venues and means, as
well as any electronic, written, or oral communications. We may update this Donor Policy from
time to time, so please check this Donor Policy periodically for changes. The date this Donor
Policy was last updated is stated at the end of this document. If we make any substantive
changes to this Donor Policy, we will use best efforts to contact you via the email address and/or
postal address that you may have provided to us. If you have any questions about this Donor
Policy, please do not hesitate to contact us at ContactUs@LibertyEllisFoundation.org.
The Information We Collect From Donors
The only personal information that we collect from donors is the information that you
voluntarily provide to us. For example, if you opt to make a donation by “clicking” the “donate”
button on our Website, or if you donate to us via another website or venue with which we may
partner, we will collect (or such other website or venue will collect on our behalf) certain
personally identifiable information, which may include your name, email address, postal address
and payment information. In regard to processing your donations – whether or not processed
through a third-party payment processor - the payment information you provide to us will only
be used to process your donation. If you opt to make a recurring donation, your payment
information will be stored to facilitate future donations; otherwise your payment information
will not be stored or used for any other purpose. Please note, that except as specified below
under the heading “How We May Share your Information,” we do not sell, rent, share, trade or
otherwise make available the names and personal information of our donors with any other
organization or entity. Additionally, we do not send emails to our donors on behalf of other
organizations or entities.
How We May Share Your Information
SOLEIF works with a variety of third-party partners who help us collect and process your
donations. As an example, to process payment/donation transactions we work with third party
payment processors, and therefore if you donate to us via our Website, they will have access to
the payment-related information that you provide. We may also send periodic third-party email
solicitations that may be of interest. Except as stated in this Donor Policy, we do not reveal
personally identifiable information about you to third parties for their independent use unless:
(1) it is necessary to allow SOLEIF and its service providers or agents to provide services on
SOLEIF’s behalf, or (2) it is necessary in connection with a sale of all or substantially all of the
assets of SOLEIF or the merger of SOLEIF into another entity or any consolidation, share
exchange, combination, reorganization, or like transaction in which SOLEIF is not the survivor,
or (3) otherwise as SOLEIF is required or permitted to do so for any or all of the following
reasons: (i) to comply with a subpoena, legal process, government request or any other legal
obligation, or (ii) to investigate or prosecute criminal offenses.
Additionally, we may periodically exchange donors postal mailing lists with other
organizations, who similarly provide us with their mailing lists. Mailing list e
xchanges provides
the SOLEIF with a cost effective way to potentially expand our donor base by obtaining the
names and addresses of other likely donors.
Please note that we do not exchange or rent email
addresses. If you prefer that we do not exchange your name and postal address, please email us
at ContactUs@LibertyEllisFoundation.org with “do not exchange” in the subject line of the
email, or call us at (212) 561-4500 and let us know that you do not want your name and address
shared. In every case we will do our best to promptly respond to your request.
Changes To Our Donor Privacy Policy
We reserve the right to revise this Donor Policy at any time by updating this posting. Please
check back regularly and to see if there have been any changes to this policy, which you can
determine by reviewing the Effective Date listed below. By continuing to donate to us after
those changes become effective, you agree to be bound by the revised Donor Policy.
DONOR PRIVACY POLICY EFFECTIVE DATE
This Donor Policy is effective as of September 1, 2022.