Your privacy is important to us at VoLo Foundation, a trust recognized as tax exempt as a private foundation under Section 501(c)(3) of the Internal Revenue Code of 1986, as amended (“VoLo Foundation,” “Foundation,” “we,” “us,” or “our”) and we are committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”). This Privacy Policy will inform you as to how we treat your personal information, including personal data, when you visit our Site (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website currently located at https://volofoundation.org (the “Website”) and as otherwise provided for herein with respect to the Foundation’s social media pages on various third party social media platforms or through other Foundation channels (each, an “Other Channel,” together with the Website, collectively, the “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using the Site, you agree to this Privacy Policy. This policy may change from time to time (see Changes to this Privacy Policy) https://volofoundation.org/terms-of-use/. Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This policy applies to information we collect:

• on the Site;
• in email, text, and other electronic messages between you and the Site;
• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to the Site;
• by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal information through your use of the Site, including any data you may provide through the Site when you purchase, access or use any of our products/services.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

Controller

VoLo Foundation is the controller and responsible for your personal information.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager at the email address below.

[privacy@volofoundation.org]

Collection of Information

Personal information means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
• Profile Data includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our Site, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information by law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). Nor do we collect from you any information about criminal convictions and offenses.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by postal mail, phone, email or Other Channels. This includes personal information you may provide when you:

• • subscribe to our publications;
  • request marketing to be sent to you;
  • inquire about services; or
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, web beacons, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. See our section on Cookies.

• Third parties or publicly available sources. We may receive personal information about you from various third parties as set out below:

• • Technical Data about you from analytics providers or search information providers;
  • Contact, Financial, and Transaction Data from providers of technical and delivery services; or
  • Google Analytics. We may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Site and how we can improve it.  Google Analytics collects information such as how often users visit a website, what pages they visit, and what other websites they used prior to coming to such website.  Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information.  We do not combine the information collected through the use of Google Analytics with your personal information.  Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google.  Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Notice.  Google utilizes the data collected to track and examine the use of the Site, to prepare reports on its activities and share them with other Google services.  Google may use the data collected on the Site to contextualize and personalize the ads of its own advertising network.  To more fully understand how Google may use the data it collects on the Site please review “How Google uses information from sites or apps that use our services” (located here https://policies.google.com/technologies/partner-sites?hl=en-US or any successor URL).
  • Sprout Social Services.  We may use Sprout Social Services to provide a platform for our social media publishing, analytics, and engagement.  Sprout may collect information about you from your social media interactions with us, such as your social media handle, username, profile, postings, and messages you exchange with us.

Please rest assured that we will only collect personal information that you knowingly and willingly provide by way of completed forms and emails, or information about the type of browser, IP address, or type of operating system you are using to assist us in providing and maintaining superior quality service. It is the intent of the Foundation to use personal information only for the purpose for which it was requested and any additional uses specifically provided on the Site and in accordance with the terms of our Privacy Policy and Terms of Use.

It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent as a means to better understand the way in which other websites garner, make use of, and share information collected.

Use of Information Collected

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party including our affiliates) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal information where more
than one basis has been set out in the table below. Generally, we do not rely on consent as a legal basis for processing your personal information. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing Communications from Us

At times, we may find it necessary to use personal information as a means to keep you informed of other possible products and/or services that may be available to you from the Site. We may also be in contact with you with regard to completing surveys and/or research questionnaires related to your opinion of current or potential future products and/or services that may be offered. You will receive marketing communications from us if you have requested information from us or purchased products and/or services from us and you have not opted out of receiving that marketing, or if you have opted in to our marketing program. See our section on Unsubscribe or Opt-Out for more details.

Third Party Marketing

The Foundation does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties.

Disclosures of Your Personal Information

We may find it beneficial to share specific data with our Foundation group and trusted partners, or our payment processing vendors, in an effort to conduct statistical analysis, provide you with email, text messages and/or postal mail, deliver support, fill orders and/or arrange for deliveries to be made, or otherwise for the purposes set out in the table above. Any third parties shall be strictly prohibited from making use of your personal information, other than to deliver those services which you requested, and as such they are thus required, in accordance with this Privacy Policy, to maintain the strictest of confidentiality with regards to all your information. We may share your personal information with Internal Third Parties (as set out in the Glossary) or External Third Parties (as set out in the Glossary).

We may deem it necessary to follow websites and/or pages that our users may frequent in an effort to glean what types of services and/or products may be the most popular to customers or the general public.

We may disclose your personal information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:

• Remain in conformance with any decrees, laws, and/or statutes or in an effort to comply with any process which may be served upon us and/or our Site;
• Maintain, safeguard and/or preserve all the rights and/or property of the Foundation; and
• Perform under demanding conditions in an effort to safeguard the personal safety of users of https://volofoundation.org and/or the general public.

We may also disclose your personal information to third parties to evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users/consumers is among the assets transferred.  If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with applicable law. We do not allow our third party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International Transfers of Data from the European Union

The Foundation has its headquarters in the United States. The Foundation has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). The Foundation relies on certain derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the United States personal information with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest of the Foundation that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it consistent with your relationship with the Foundation and the practices described in this Privacy Policy.

If You Fail to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Cookies

Please note that certain information about your computer hardware and software and browsing actions and patterns may be collected by the Foundation through automatic data collection technologies as you navigate through and interact with our Site. This information is used by us for operation of our Site and our business, to maintain quality of the Site and our business, and to provide general statistics regarding use of the Site. The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Please review the “Cookies” section and specifically the “Use of Cookies” subsection below for more information on cookies and how you can manage your cookies settings.
• Flash cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the “Choices About How We Use and Disclose Your Information” subsection below.
• Web Beacons. Pages of the Site and our e-mails 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 or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

Use of Cookies

The Site uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you visit certain Site pages, a cookie helps us to recall your specific information on subsequent visits. When you return to the Site, the information you previously provided can be retrieved.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please see the “Choices About How We Use and Disclose Your Information” subsection below for more information about managing your computer’s settings for cookies.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Site are served by third parties, including servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Choices About How We Use and Disclose Your Information” subsection below.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. Certain mechanisms are available to you on your browser settings that provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. To learn how you can manage your Flash cookies settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see our section on “Cookies.”
• Promotional Offers from Us. If we have sent you a promotional email, you may click on the unsubscribe link at the bottom of the email to be omitted from future email distributions.

We do not control third parties’ collection or use of your information to serve interest-based advertising (the collection of data across web domains owned or operated by different entities, or the use of such data, for the purpose of tailoring advertising based on preferences or interest known or inferred from the data collected). However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising at the following websites:

NAI Website (US): https://optout.networkadvertising.org/?c=1

DAA Website (US): https://optout.aboutads.info/?c=2&lang=EN