Effective Date: October 5, 2021

About Client

The Covenant Foundation is a 501(c)(3) non-profit which recognizes the diversity of strengths within the field of Jewish education in North America, across all denominations and settings.

Scope of this Policy

This privacy policy applies to our online properties, including our website www.covenantfn.org, and websites or mobile applications that link to it, and our social media pages or handles. This Policy also applies when you sign up for newsletters or interact with us through our Grant Application and Awards Process (the “Services”). It also applies anywhere it is linked.

This Policy does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may change this Policy from time to time. If we do, we will notify you by posting the updated version.

Information We Collect

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Services together and with other information we obtain from our business records.

Information You Provide To Us

You may provide the following information to us directly:

• Contact and professional information, including name, email address, telephone number, and job title, as well as employer name.
• Demographic information.
• Audiovisual information, including recordings of online events.
• Information contained in your communications to us, including Grant Applications, Statements of Nomination and Letters of Support.
• Information you make available to us via a social media platform, which we use to promote our awards nominations process and grant application process.
• Content you may include in survey responses, such as when you are a member of a selection committee.
• Any information or data you provide by interacting in our online forums and chatrooms, or by commenting on content posted on our Services. Please note that these comments are also visible to other users of our Services.
• Travel and lodging information.
• Sensitive personal information, such as age, gender, race, ethnic origin, cultural heritage, and religious denomination or affiliation.
• Any other information you submit to us.

Information We Collect Automatically

We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Services.

• Device information, including IP address, device identifiers, and details about your web browser.
• Analytical information, including details about your interaction with our website, app, and electronic newsletters.
• Diagnostic information, including web traffic logs.
• Business record information, including records of grant recipients and use of our services.

Information We Collect From Other Sources

We may collect the following information about you from third-party sources.

• Newsletter registration information.
• Contact information, demographic information, and information about your interests or employment from Statements of Nomination and Letters of Support.
• Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly.
• If you decide to make an award nomination, we will collect your and the other person’s name and email address to send a Notice of Nomination. You agree that you will obtain the other person’s consent before giving us his or her contact information. You also agree that you will not send us the contact information of a minor. We will inform any other person you invite that you gave us his or her information in the invitation email.

How We Use Your Information

We may use any of the information we collect for the following purposes.

• Service functionality: To provide you with our grants and services, including to send communications (including newsletters), and conduct general business operations, such as accounting, recordkeeping, and audits.
• Service improvement: To improve and grow our Services, including to develop new grants and services and understand how our Services are being used, our supporter base, and the effectiveness of our informational campaigns.
• Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
• Legal compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements.

How We Share Your Information

We may share any of the information we collect with the following recipients.

• Third Party Selection Committees: We share information with our selection committee so they may evaluate potential grant and award recipients.
• Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. Third-party service providers assist us in evaluating our information security controls, maintaining our site, and in interpreting our site traffic.
• Business partners: From time to time, we may share your contact information with other organizations for grant promotion purposes and to send mailings on our behalf.
• Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
• Government entities/Law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals.

Security

While we take precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Your Options and Rights Regarding Your Information

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us. Please note that any promotional email messages you receive from us will include an option to opt out of future email communications.

Do Not Track: Your browser or device may include “Do Not Track” functionality. The information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy, whether a Do Not Track signal is received.

Jurisdiction-specific rights: You may have certain rights with respect to your personal information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.

Other Important Information

Data retention

We may store information about you for as long as we have a legitimate business need for it.

Cross-border data transfer

We may collect, process, and store your information in the United States and other countries. The laws in the United States regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.

Information about children

The Services are intended for users age thirteen and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us with any concerns.

Sharing of Medical or Health Information

To the extent that we receive protected health information about you, that information is subject to electronic disclosure to the extent permitted by applicable law.

Privacy Disclosures for Specific Jurisdictions

European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”). We may use the information we collect from you for the purposes stated in the “How We Use Your Information” section. Our lawful bases of processing for each of these uses may be consent, our legitimate interests, or to comply with applicable law.

Your rights under the GDPR: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in the EEA, U.K., or Switzerland, you have the following rights.

• Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
• Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
• Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise or defense of legal claims; or if your request to object to processing is pending evaluation.
• Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
• Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.

Please contact us to exercise these rights.

Contact information, submitting requests, and our response procedures

Contact

Please contact us if you have questions or wish to take any action with respect to information to which this privacy policy applies.

Email: info@covenantfn.org
Telephone: (212) 245-3500
Mail: Covenant Foundation
1270 Avenue of the Americas
Suite 304
New York, NY 10020

Making a request to exercise your rights

Submitting requests: You may request to exercise your rights by making a request using the contact information above.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.

We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.