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Generally Speaking, “Personal Information“ means any information about an individual from which that person may be identified. Personal Information includes obvious things, like your name, telephone number, email address and street address, as well as less obvious things like your IP address, device ID and location information. Personal Information does not, however, include information from which the identity of an individual has been definitively removed (also known as anonymous or anonymized data).
We collect Personal Information directly from you when you provide it to us, such as when you create an account with us or otherwise communicate with us, verbally or in writing. We also may collect information indirectly through automated technologies, such as cookies, or from third parties.
You can generally visit our Website without having to submit any Personal Information about yourself to us. However, to make a donation or subscribe to our newsletters, you will be required to provide us with Personal Information.
When you make a donation, we will collect the following information that you provide to us, as applicable:
- your name;
- your email address;
- mailing address;
- phone number;
- other Personal Information on your check, if you send a donation in a check.
Additionally, if you wish to make a donation or purchase products, we will also need to process your payment information in order to process your transaction. Payment processing is performed by third-party service providers.
If you contact us for more information via our Website or signup to our newsletters or register for an account to make an appointment or to take a class, we will collect your contact information:
- your name;
- your email address; and
- any other information you may submit to us directly.
If we ask you to provide any Personal Information not described above, the Personal Information that you are asked to provide and the reasons why you are asked to provide it will be made clear to you when asked to provide it.
Device and Usage Information
When you visit, use or interact with the Website, even if you do not have an account, we, or our authorized third-party service providers, may automatically collect information about your use of the Website via your device, some of which information is personal information. Device and Usage Information that we collect consists of:
- Information About your Device: information about the devices and software you use to access the Website – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Website, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device), the operating system of your computer or mobile device, device screen size, and other similar technical information.
- Usage Information: information about your interactions with the Website, including access dates and times, hardware and software information, device event information, crash data, cookie data. This information allows us to understand the screens that you view, how you’ve used the Website (which may include administrative and support communications with us or whether you have clicked on third-party links), and other actions on the Website. We, or our authorized third parties, automatically collect log data when you access and use the Website, even if you have not created an account or logged in. We use this information to administer and improve the Website, analyze trends, track users’ use of the Website, and gather broad demographic information for aggregate use.
We also collect broad geographic location (e.g., country or city-level location) based upon IP address, in order to determine our marketing strategies.
Cookies and Similar Technologies
We or authorized third parties collect some information, including Device and Usage Information and Location Information by automated means using cookies, and server logs for analytic purposes. Google and Facebook set cookies as described in the Behavioral Remarketing section below.
With the Device and Usage Information and Location Information collected by our third-party analytics services, we generate and process aggregated information, such as statistical or demographic data. Aggregated Information may be derived from Personal Information, but is not considered Personal Information under the law if it does not directly or indirectly reveal your identity. For example, we may track the total number of visitors to our Website or the number of visitors to each page of our Website, and we may aggregate usage data to calculate the percentage of users accessing a specific feature of the Website and analyze this data for trends and statistics.
We may use your Personal Information for a number of different reasons, as further explained below.
- Communicating with you about your use of the Website and our services or providing you information or newsletters you have requested.
- Processing your donations and purchases, through our third-party payment processors.
- To acknowledge receipt of your payments for tax purposes and to help prevent fraudulent transactions.
- To register you for an appointment or for our classes and events.
- Generating user analytics to improving our Website, guide our marketing strategy and enhance our offerings.
- Responding to your general inquiries.
- Marketing our services. This allows us to provide you with information about new products. We will provide an option to unsubscribe or opt out of further communication on any electronic marketing communication sent to you (or you may opt out by contacting us.
- Complying with our legal and regulatory obligations. We may use Personal Information to fulfill our legal obligations; for the prevention of fraud and monitoring security; to enforce our legal rights; to comply with any legal or regulatory reporting obligations; and/or to protect the rights of third parties.
- Where necessary, recovering any payments due to us for our legal or other services, including enforcing such recovery through debt collection agencies or taking other legal action (including in connection with legal and court proceedings).
- Making changes to our business, for example, if we undergo a re-organization (i.e., we merge, combine or divest a part of our business), in which case we may be required to transfer some or all of your Personal Information to third parties as part the process, as further described below.
We disclose your Personal Information to those of our personnel who need to process Personal Information in order to provide our services. In addition, we may disclose your Personal Information to the categories of third parties indicated below (and for the following reasons):
- Entities and individuals that help us provide the Website and our services;
- Professional service providers, such as auditors, bankers, lawyers, consultants, accountants and insurers;
- Governments, regulators, law enforcement and fraud prevention agencies, but only as authorized as explained below; and
- In the event of a business transfer, as explained below.
The following categories of third parties may collect, process or receive your Personal Information in order to assist us in providing our Website and products:
- Entities that host various components of our Website;
- Email marketing providers;
- Payment processors;
- Social Media for marketing purposes; and
- Fundraising consulting service providers.
Service providers may only process your Personal Information for the specified purposes of providing their services to us and in accordance with our instructions unless they, aggregate and anonymize any Personal Information such that you may no longer be identified or identifiable at any time or in any manner.
We will disclose your Personal Information: (i) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant or other judicial or administrative order (as further explained below); (ii) to protect the safety of any person; (iii) to protect the safety or security of our Website or to prevent spam, abuse, or other malicious activity of actors on our Website; or (iv) to protect our rights or property or the rights or property of those who use our Website and/or products.
If we are required to disclose Personal Information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or otherwise via a mutual legal assistance mechanism (e.g., treaty).
Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, or the detection or prevention of a crime, we may provide information, including Personal Information, to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
We may transfer your Personal Information to an affiliate, a successor entity upon a merger, consolidation or other corporate reorganization in which The SF SPCA participates, or to a purchaser or acquirer of all or substantially all of The SF SPCA’s business or assets, including a successor in bankruptcy.
The SF SPCA tracks users’ use of the Website, and may track users across third-party websites. We do not respond to Do Not Track (DNT) signals.
If you would like us to stop using your Personal Information, or if you want to change Personal Information you previously have provided to us via the Website, please contact us at email@example.com and we will comply unless precluded from doing so for record-keeping purposes or by applicable law.
We allow you to opt out of future communications at any time by clicking the “Opt Out” or “Unsubscribe” link in the email or replying to any email you receive with a message that reads “Opt Out” in the subject line.
For marketing communications, we will allow you to opt out of future communications at any time by clicking the “Opt Out” or “Unsubscribe” link in the email or replying to any email you receive with a message that reads “Opt Out” in the subject line.
We use social plugins on our Website and may include icons that allow you to interact with third-party social networks such as YouTube, Pinterest, Instagram, Twitter and Facebook. For example, you may “like” us on Facebook or follow us on Twitter. The third-party social plugin may set a cookie when your browser creates a connection to the servers of such social networks and the plugin may transmit your Personal Information to the social networks. Your use of these social plugins is subject to the privacy policies of the third-party social networks.
The SF SPCA uses remarketing services to advertise on third party websites to you after you visit our Website. For instance, we use Google and Facebook to send request information to Google and Facebook and track conversions. We provide Personal Information to Google and Facebook and Google and Facebook may set cookies on your hard drive.
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You may learn more about interest-based advertising and opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA.
We recognize the privacy interests of children, and we encourage parents and guardians to take an active role in their children’s online activities and interests. We target our Website and the services we offer to adults and not to children under 16 years of age. To the extent that we are required to collect information regarding a minor in order to provide our services, we will only do so with parental consent or collect the information from the parent directly.
Your Personal Information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.
We have put in place reasonably appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. The measures that we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also require those parties to whom we transfer your Personal Information to comply with the same.
While we take all reasonable steps necessary to provide the most secure Website, you understand and assume the risks associated with your activities on the Internet.
Our Service is targeted to users in the United States. We are located in the United States, and the Personal Information that we collect is stored on servers located in the United States. This means that your Personal Information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region.
San Francisco SPCA
Attn: Legal Department
201 Alabama Street
San Francisco, CA 94103