Privacy Policy

Last modified: August 11, 2021

Introduction

This privacy policy (“Privacy Policy”) applies to the personal information The Harry Frank Guggenheim Foundation (“Foundation,” “we,” “us,” and “our”) collects about you through our programs, such as the website operated and made available by the Foundation located at HFG.org and any other websites under our control (collectively, the “Websites”). To the extent this Privacy Policy applies to information collected through our Websites, it applies regardless of media platform (e.g., computer, smartphone, tablet, etc.) used.

Your privacy is important to us, and this Privacy Policy is designed to make clear our intentions and approach to the collection and use of personal information in connection with our programs and Websites and the choices you have.

Please contact us at info@hfg.org if:

  • You have any questions about this Privacy Policy;
  • You would like to review, update, correct or delete personal information we have collected about you;
  • If you would like to change any of your choices about personal information we collect about you; or,
  • You would like to receive your personal data in a machine-readable format.

Your Consent; Opting Out

By using the Websites and/or by otherwise participating in our programs, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from using the Websites or participating in our programming. Specifically, by using our websites and/or otherwise submitting any Personal Information (as defined below in “Information We Collect & How We Collect It”) to us, you consent and agree that we may collect, use, and disclose that information (including information which may be personally identifiable) in accordance with this Privacy Policy, and as permitted or required by law. You have the option of refraining from submitting Personal Information and reviewing, updating, correcting and deleting Personal Information you have submitted (by contacting us at info@hfg.org, and can limit your use of the Websites or participation in our programs to those aspects that do not require Personal Information if you do not agree with our practices outlined in this Privacy Policy regarding Personal Information. However, your ability to participate in our programs and your experience on our Websites may be affected if you opt not to provide Personal Information to us. You can also request that we refrain from using Personal Information for certain uses described in the Privacy Policy (by contacting us at info@hfg.org). You can also opt-out of our collection of Website User Information by refraining from visiting our website or rejecting or deleting cookies (see Website User Information & Cookies/Web Beacons/Tracking below).

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. 

Information We Collect & How We Collect It

For the purposes of operating, improving, and monitoring the user experience on our Websites and our operations generally, we collect various information from those using the Websites. This information is broadly of two types: (1) Personal Information (information which is personal to you and can be used to identify you, such as your name, email address, an identification number, location data, an online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity) and (2) Website User Information (such as the number of users—but not their names—who have viewed an article, other resource, or page on our Website).

Website User Information & Cookies/Web Beacons/Tracking

When you access our Websites, we may collect Website User Information including, but not limited to, pages visited, hyperlinks used, type of device used, date, and time spent on our Websites.

Collecting such Website User Information may involve logging the IP address, operating system and browser software used by individual site visitors. From such information a user’s Internet Service Provider and other data could be inferred but cannot be used to personally identify you. We use this information to understand how to service users of our Websites and improve our Websites and programs by using Google Analytics or other website analysis tools. 

We may also use cookies, flash cookies, web beacons, tags, and/or other technologies to store and help track information about you to provide you with a customized and personal service. Most browsers are initially set to accept such technologies and offer easy instructions on setting your browser to reject some or all of them. For example, you may choose to delete cookies at any time. However, please note that various personalized functions and benefits of the Websites may not work properly if you reject our cookies or other web technologies.

We do not track visitors across third party websites to provide targeted advertising, and therefore do not respond to Do Not Track (DNT) signals.

Personal Information

What Personal Information Will Be Collected?

The Personal Information that we collect depends on the context of your interactions with us and the programs you attend, the parts of the Websites you access, the choices you make and the content you use. The Personal Information we collect may include the following: 

Name and Contact Data. We may collect your first and last name, email address, postal address, phone number, and other similar contact data.

Demographic Information. We may collect information such as gender, ethnicity, and age range, academic history/background. 

Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access. 

Communications and opinions in online discussion forums offered through the Websites;

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

All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Examples of Interactions Which Might Result in the Collection of Personal Information

You can access content on our Websites and use most features of our Websites without revealing any Personal Information. We only collect Personal Information when you provide it to us directly (or as noted in the Website User Information). Examples may include the following: example: 

  • When you register for an account on the Websites [e.g. submit a grant application]; 
  • If you reserve tickets to one of our programs;
  • If you register for and participate in our programs, activities, initiatives, and events;
  • If you register with us to receive email newsletters or other communications from us;
  • If you contact us through the Websites;
  • When you participate in surveys;
  • When you submit testimonials;
  • When you participate with social media accounts operated by Foundation;
  • When you request a mailed copy of a publication or other Foundation material;
  • When you provide User Content (as defined in the Terms and Conditions of Use) such as comments or written submissions on any part of the Websites that permit it; and
  • When we need to verify your account information.

When you interact with any Foundation page or account on a social media platform, such as: Facebook, Twitter, LinkedIn, , or YouTube] (collectively, “Foundation Social Media”), or when you use your social media account or credentials to log into the Websites, we may also collect the Personal Information that you make available to us on that page or through that account. (Please note that when you use third party social media platforms, your use of those platforms is governed by their privacy policies and not this Privacy Policy.)

Collection of Personal Information by Third Party

The Websites may use third-party services to collect Personal Information for certain activities, such as analytics, email communications, online grant applications or event registration. Use of Personal Information is controlled both by this Privacy Policy and the privacy policies and practices of those third-party service providers. If we are using a third-party service to collect Personal Information in connection with a feature we offer on our Websites, we will provide you with a link to the service provider’s privacy policy.

Current Third-Party Vendors:

How We Use Personal Information We Collect

We use Personal Information collected in the following ways: To indicate that you are the author of User Content (as defined in our Terms and Conditions of Use) if you submit such content with your name;

  • To communicate with you periodically via email, if you have subscribed to one of our email lists or newsletters;
  • To facilitate your registration for an event or program;
  • To communicate with you in connection with a Foundation activity, program, or request;
  • To communicate with you in connection with processing your grant application or employment application;
  • To communicate with you about your account or any transactions with us;
  • To respond to you when you contact us. We may also archive this information and/or use it for future communications with you.
  • To contact you with service messages related to or affecting your use of our Websites, for example, to send you updates about changes in our terms or policies;
  • To investigate any activities that may violate our policies or be illegal;
  • To manage and operate our organization in general.

If you are a European Union data subject, the legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it. We may process and use Personal Information for one of the following reasons:

  1. you have given us permission to do so; 
  2. we need to perform a contract with you; 
  3. the processing is in our legitimate interests and it’s not overridden by your rights; or
  4. to comply with the law. 

Disclosure of Personal Information

Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Information we gather from you through the Websites. We may process or share data on the following legal bases:

Consent: We may process your data when you have given us specific consent to use your personal information for a specific purpose.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 

Third Party Service Providers/Program Partners. We might share Personal Information with trusted third-party vendors to help us in operating our Websites, programs, and services. Specifically, these instances might include but are not limited to: data analysis, email delivery, hosting services, customer service, and marketing efforts .Also, if we work with a partner to help us to develop content and programs, we might share our email list and other information with them on a confidential basis. 

Legal and Governmental Authorities and/or Protection of Vital Interests. To comply with legal requirements that may arise, we may share your Personal Information if requested to do so by legal or government authorities, or to protect our rights and property under the law. Such uses include, but are not restricted to: responding to court orders or subpoenas, to establish or exercise our legal rights or defend against legal claims and attacks on our reputation, to protect our property, including intellectual property and trademarks, or to enforce this Privacy Policy or our Terms and Conditions of Use. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Information when necessary to investigate, prevent, or take action regarding illegal or suspected illegal activities and to protect and defend the rights, property, or safety of Foundation and its staff, its properties, users of our Websites, or others.

Disclosure to Affiliates, Assignees of Successors. We may disclose and/or transfer your Personal Information to an affiliate, assignee or other successor or potential successor entity in connection with a merger or other reorganization, provided that party agrees to treat your Personal Information with protections similar to those under this Privacy Policy. If we intend to share your Personal Information under these circumstances, we will notify you and give you the option to opt-out.

User Content. Your name or username will appear next to any User Content you submit to us. If you post Personal Information in comments or other public forums on our Websites or on Foundation Social Media, that information will be publicly available. If you are concerned about your privacy, we encourage you to use a username that is not personally identifiable and to refrain from posting Personal Information in comments or other public forums on our Websites or Foundation Social Media. You may delete your Personal Information in comments or other forums but we are not able to recall information which you have made public prior to such deletion.

Aggregated Data. We may share information in an aggregated form or publish information based on aggregated data. However, we will only do so in a way that your personal identity is not ascertainable.

Your Communications Preferences

You can elect to opt-out of subscription and marketing communications from us via the unsubscribe mechanism provided within the communications that you receive from us. Even if you unsubscribe from general email communications, we reserve the right to notify you of changes or updates to the Websites and to communicate with you about your user account(s) or User Content you have submitted as necessary.

Access, Review, Updating, Correcting and Deleting Personal Information

You may review, edit or delete the Personal Information you have provided to us by contacting us at info@hfg.org. Please note, however, that even if you delete your information, there may still be residual information about you in our systems, for example in our log files. Also, please note that we may retain certain Personal Information in which we retain a legitimate interest not overridden by your interests or fundamental rights, to comply with our legal obligations, meet regulatory requirements, prevent fraud and abuse, or enforce our Terms and Conditions of Use. Upon request, we will also provide you with a copy of your personal data in a machine-ready format and send it to another data controller. You will need to provide sufficient identifying information, such as your name, email address and possibly additional information as a security precaution in order to do any of the foregoing.

Data Retention

We will retain your Personal Information for as long as your account is active or as needed to provide you with services. If you wish to cancel your account or request that we no longer use your Personal Information to provide you with services, please contact us at info@hfg.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, and enforce our policies and agreements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your Responsibilities

It is your responsibility to maintain the confidentiality of your password(s).

You are also responsible for ensuring the accuracy of the Personal Information you submit to us. Submitting inaccurate information, or failing to maintain the accuracy of information that changes (for example, a change of email address) may disrupt your ability to receive email communications, may affect the information you receive from us, and may impact our ability to contact you/and or process your grant application. You can update your Personal Information at any time by logging into your relevant user accounts with us and our third party service providers. If you have any questions about updating your Personal Information, please contact us at info@hfg.org.

External Links

We may occasionally provide links to Websites operated by outside parties, including social media platforms (“Third-Party Websites”), that we believe may be of interest to you. We do not disclose your Personal Information to these Third-Party Websites without obtaining your consent. However, if you choose to interact with Third-Party Websites from our Websites (such as by “liking” something on Facebook or sharing via a social media platform), then your activities will not be governed by this Privacy Policy but by the privacy policy on that Third-Party Site. Please review their privacy policies and terms of service before disclosing any Personal Information there. We do not review and expressly do not endorse and are not responsible for the privacy practices of these Third-Party Websites. 

 We may also maintain a page on Facebook or other Foundation Social Media (as defined in “Information We Collect and How We Collect It” above). Those pages and your interaction with them are governed by the privacy policies of Facebook or other relevant Foundation Social Media, not by our Privacy Policy. As with other Third-Party Websites, we do not endorse and are not responsible for the privacy practices of social media platforms, although we may have a presence on them.

Security

We are committed to protecting the security of our users’ Personal Information. To that end, we use industry standard security practices to keep your Personal Information private, and to protect it from disclosure to or access by third parties. We will not share it with third parties, except as directed by you or as otherwise specified in this Privacy Policy. Please note, however, that we do not and cannot guarantee the security of Personal Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems, or that transmission of your information over the Internet will be intercepted. You should only access our Website within a secure environment. We disclaim all liability involving the interception or unauthorized use of Personal Information submitted through our Websites.

Changing Our Privacy Policy

We review our privacy practices from time to time, and these practices are subject to changes and updates. We will notify you of any material change to this Privacy Policy by reflecting the change on this Privacy Policy page, and by updating the Effective Date located at the top of this page. The updated version will be effective as soon as it is posted. If the change affects how we collect, use or disclose Personal Information, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification by email (sent to the email address specified in your account). To ensure familiarity with the current version of our Privacy Policy, return to this page periodically. We will not apply any changes retroactively, and you have the option to opt-out of further collection of Personal Information and deletion of any existing Personal Information. 

Minors

This Website is directed solely at adults. If you are under the age of thirteen (or if being a “minor” is defined as a younger age in your relevant jurisdiction, that relevant age), please do not provide us with any of your Personal Information, including your email address. 

Governing Law

This Privacy Policy shall be governed by the laws of the State of New York (United States), excluding any laws that might direct the application of the laws of another jurisdiction, and applicable US federal laws. 

We engage in periodic self-assessment to ensure compliance with our Privacy Policy. We verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and where applicable, in conformity with United States law and the European Union General Data Protection Regulation (“GDPR”). We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

International Users

Note that we may store and process Personal Information on servers or on a cloud located in the United States or elsewhere. The data protection laws of the United States generally may not be as comprehensive or the same as those in the country where you are located. By using our Websites, you agree and consent that your Personal Information may be transferred to or stored in facilities in the United States or elsewhere.

Regardless of where we store and process data, we take steps to protect your information consistent with the principles set forth in this Privacy Policy, which are intended to comply with the Privacy Shield Framework issued by the U.S. Department of Commerce. As a nonprofit organization, we are not subject to the jurisdiction of the United States Federal Trade Commission, which oversees the implementation of the Privacy Shield program. Consequently, we cannot self-certify compliance.

Notwithstanding anything to the contrary set forth herein, a European Union “data subject” (as such term is defined in the GDPR) may seek an administrative or judicial remedy or to lodge a complaint with a supervisory authority, in particular in the member state of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. Information on how to file such a complaint is available here http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by emailing us at info@hfg.org. 

If you are under 18 years of age, reside in California, and have a registered account with Websites, you have the right to request removal of unwanted data that you publicly post on the Websites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Websites, but please be aware that the data may not be completely or comprehensively removed from our systems.

Questions or Concerns

If you have any trouble logging in, or have any privacy-related questions or unresolved problems, please contact us at info@hfg.org.

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