PJ Our Way General Privacy Policy

Last Revised: July 10, 2018

The Harold Grinspoon Foundation (“HGF” “We” or “Us” or “Our”) operates the PJ Our Way website (“PJ Our Way Website”) currently located at www.pjourway.org. This General Privacy Policy relates to information collected online and offline by HGF in connection with your use (and that of any person you register) of the services available on the PJ Our Way Website, including without limitation the PJ Our Way engagement program (the PJ Our Way Website, together with any associated and successor websites, applications, programs, and services, are sometimes referred to herein collectively as the “Service”). As used herein, “you” means a user of the Service and, in addition, when the user of the Service is a minor registered by a parent and/or guardian, the term “you” also includes such parent and/or guardian. This General Privacy Policy is incorporated into, a part of, and governed by the PJ Our Way Terms of Use.

You should carefully read this General Privacy Policy. By using the Service or permitting your child to use the Service, you are signifying your acceptance of this General Privacy Policy. If you do not agree to this General Privacy Policy, you may not use the Service, and you may not permit your child to use the Service.

As used in this General Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

This General Privacy Policy serves to notify you of the following:

WHAT INFORMATION ABOUT ME IS COLLECTED?

Depending on your use of the Service, we collect certain types of information, which may be considered personally identifiable information.

Personally Identifiable Information

Personally identifiable information is information that identifies you or can be used to identify or contact you. Such information may include your name, address, e-mail address, and/or telephone number and in some cases persistent identifiers such as IP addresses.

Additional Collected Information

Additional collected information is information that any single of item of which, by itself, cannot be used to identify or contact you, such as demographic information (like age, profession, gender, current location, zip code, birth date, or year of birth), IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. Certain additional collected information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered additional collected information when they are taken alone or combined only with other additional collected information (for example, your viewing preferences).

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect personally identifiable information that you submit to us. We may also receive personally identifiable information about you from third parties providing fraud screening services as part of your use of the Service.

Registering and Using the Service. You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information (including personally identifiable information and additional collected information), such as name, postal address, email address, gender, and birth date. We may also receive personally identifiable information about you from third parties providing fraud screening services as part of the registration process. In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments. Also, we will have access to any personally identifiable information that you choose to share through the Service (such as your name if you include it in a book review or question or other content that you post to the Service).

Cookies and Action Tags. We may collect additional collected information passively using cookies and action tags. “Cookies” are small text files that are placed on your computer or mobile device in order to identify your Web browser and the activities of your computer on the Service and other websites. Cookies are used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), and to allow us to statistically monitor how you are using the Service to help us improve our offerings.

Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including e-mail sent on our behalf, may contain action tags. By using cookies and action tags together, we are able to gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. Finally, you should be aware that other third parties may also use their own cookies or action tags when you click on their links to their websites or services on or from the Service. This General Privacy Policy does not govern the use by such third-party websites.

We also collect additional collected information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. You can do this through your browser (like Mozilla Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you block cookies on your browser, certain features on the PJ Our Way Website may not work.

IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICE PRIVATE?

No. Any information shared in the Public Areas (as defined below) of the Service is available to the public, including to all users. Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this General Privacy Policy. If you wish to keep any information private or proprietary, do not submit it to the Public Areas of the Service. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER’S INFORMATION OR IDENTIFY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.

IS A USER NAME OR AVATAR PRIVATE?

No. While user names and avatars are available to the public, including to all users, when a user shares or posts information in the Public Areas (as defined below) of the Service, our PJ Our Way Website has safety measures in place to protect the privacy of our users.  Avatars are created by choosing from a pre-selected sampling of colors and designs, not images from users.  Our PJ Our Way Website also contains a mechanism that prevents users from creating user names that contain their first or last names.

DOES HGF COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. Please see our Children’s Privacy Policy for our guidelines concerning the collection of information from children under the age of 13.

WHAT DOES HGF DO WITH THE INFORMATION IT COLLECTS?

In general, we use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service purposes, and so that we and third parties can contact you about products and services that may be of interest to you. We may use your information to send you a welcoming e-mail that may confirm your user name and password. If you “opt in”, we and third parties may send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, you have the option to unsubscribe or change your preferences. In addition, if you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments for future reference. We may also use the information collected to send you important service announcements and updates regarding the Service. You will not be able to unsubscribe from these service announcements and updates as they contain important information relevant to your use of the Service. We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service.

WHEN DOES HGF DISCLOSE INFORMATION TO THIRD PARTIES?

Except as set forth in this General Privacy Policy, or as specifically authorized by you with respect to disclosures not described herein, we will not disclose any information we gather from you through the Service.

Laws and Legal Rights. We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the PJ Our Way Terms of Use, to detect fraud, or to protect the safety and/or security of our users, the Service or the general public.

Third Parties Generally. We may provide to third parties additional collected information, including where such information is combined with similar information of other users of the Service.  For example, we might inform third parties regarding the number of unique users who use the Service, or the demographic breakdown of our users of the Service. We may also provide personally identifiable information to trusted third parties who assist us in operating our PJ Our Way Website, conducting our business, or delivering services to you, or our community partners, so long as those parties agree to keep this information confidential.

Partners. In connection with our operations and in providing the Service, we partner with philanthropists as well as educational, religious, and community programs and organizations. We may provide to these partners personally identifiable and additional collected information of our users so that our partners may contact users about products, services, events, and programming that may be of interest. Our partners only have access to personally identifiable and additional collected information for subscribers within that partner community’s zip code.

Outside Contractors. We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing fraud screening, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected on the Service, including your personally identifiable information. We require that these contractors agree to: (1) protect the privacy of your personally identifiable information consistent with this General Privacy Policy, and (2) not use or disclose your personally identifiable information for any purpose other than providing us with the products or services for which we contracted. List of vendors

Public Areas. The Service features various community and blog areas and other public forums (the “Public Areas”) where Service users can share information, post book reviews, and post questions for others to answer. These Public Areas are open to the public and should not be considered private. We cannot prevent such information from being used in a manner that may violate this General Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings. Any information you share in a Public Area (including personally identifiable information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personal information in a Public Area, you can send us an e-mail to request that we remove it by contacting us at info@pjourway.org. You should understand that in some cases, we may not be able to remove your personal information.

DOES THIS GENERAL PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?

No. This General Privacy Policy applies solely to information collected by us through the Service. Our Service may provide you with access to other websites and services. This may include providing you with the ability to automatically post updates on, e.g., Facebook and Twitter. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. We encourage you to read the privacy policies or statements of each and every such website and service.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with industry standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Personally identifiable information collected through the Service is not transferred outside of the United States.  This Service may be viewed and hosted throughout the world.  If you access and use the Service from outside of the United States, any personally identifiable information collected will be transferred to and maintained by our offices in the United States. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. By accessing and using the Service and submitting such information on it, you voluntarily consent to the international transfer and hosting of such information.  If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?

Except as otherwise described in this General Privacy Policy, we will only use personally identifiable information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must “opt-in” and give us permission to use your personally identifiable information for any other purpose. You may also change your preference with respect to receiving certain marketing communications from us by contacting info@pjourway.org.

CAN I UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?

Upon request, we will inform you of the existence, use and disclosure of personal information relating to you and give you access to that information, subject to any legal restrictions or rights of refusal.

You have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to: (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by accessing the Family Dashboard feature of the Service or contacting info@pjourway.org. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third-parties in accordance with this General Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all personally identifiable information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably practicable.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS GENERAL PRIVACY POLICY?

You should be aware that we may revise this General Privacy Policy at any time. However, we will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “Opt In” to such changes. We may also make non-significant changes to this General Privacy Policy that generally will not significantly affect our use of your personally identifiable information. We encourage you to check this page periodically for any changes. Continued use of the Service following the posting of non-significant changes to this General Privacy Policy will mean that you accept those changes.

WHOM DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this General Privacy Policy or feel that we are not abiding by the terms of this General Privacy Policy, please contact our Privacy Agent in any of the following ways:

By e-mail:
info@pjourway.org

By postal mail or courier:
Attn: Privacy Agent
The Harold Grinspoon Foundation
67 Hunt Street, Suite 100
Agawam, Massachusetts 01001

If you are a Canadian and, having shared your concerns with us, you are still not satisfied, you may file a complaint with your privacy regulator. For example, the Office of the Privacy Commissioner of Canada can be reached by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1 800 282 1376.

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. For inquiries regarding our disclosure policy, please send us an email to info@pjourway, or write us at: Attn: Privacy Agent, The Harold Grinspoon Foundation, 67 Hunt Street, Suite 100, Agawam, Massachusetts 01001 We will be happy to honor your request.

BY USING THE SERVICE OR PERMITTING YOUR CHILD TO USE THE SERVICE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS GENERAL PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS GENERAL PRIVACY POLICY, YOU SHOULD NOT USE THE SERVICE OR PERMIT YOUR CHILD TO USER THE SERVICE. CONTINUED USE OF THE SERVICE FOLLOWING THE POSTING OF CHANGES TO THIS GENERAL PRIVACY POLICY THAT DO NOT SIGNIFICANTLY AFFECT THE USE OR DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION WILL MEAN THAT YOU ACCEPT THOSE CHANGES.