Your privacy is important to Cummings-Feola Family Foundation, LLC. We have developed this privacy policy ("Privacy Policy") that covers how we collect, use, disclose, and protect your personal information. Please read this Privacy Policy in its entirety to understand how Cummings-Feola Family Foundation, LLC will handle the privacy of personal information that you provide through the areas defined below.

This Privacy Policy applies to the following areas (collectively our “Digital Properties”):

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• Cummings-Feola Family Foundation, LLC website

• Cummings-Feola Family Foundation LLC social media properties including,

  but not limited to Facebook, Twitter, and Instagram (collectively “Social

  Media Sites”)

• Cummings-Feola Family Foundation, LLC mail, email, and phone

  communications including, but not limited to marketing, event, and fundraising communications

  

Please remember that this Privacy Policy applies only to information collected by our own communications channels. We are not responsible for the privacy practices of websites or communications networks that are operated or owned by third parties. For example, links to other third-party websites, including those of our corporate supporters and partners, can be accessed from our Digital Properties. Please be advised that the privacy policies of those third-party sites or communications platforms operated by other third parties may not be consistent with this Privacy Policy.

Cummings-Feola Family Foundation, LLC may use and disclose the information that you provide through its Digital Properties or other communications channels only for purposes permitted or required by law, for purposes described in this Privacy Policy, or for purposes, which you might authorize.

Cummings-Feola Family Foundation, LLC also has developed Terms of Use describing your responsibilities when using its Digital Properties and/or the Best Friends communication channels. Please read the Privacy Policy and the Terms of Use carefully.

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CHANGE TO THE POLICY

Cummings-Feola Family Foundation, LLC may change this Privacy Policy at any time. If and when a change occurs, notice will be prominently posted on the Digital Properties covered by the Privacy Policy. However, please refer back to the Privacy Policy regularly because your use of the Websites, Social
Media Sites, Applications and/or other communication channels signifies that you agree to be bound by this Privacy Policy.

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WHAT INFORMATION DOES CUMMINGS-FEOLA FAMILY FOUNDATION, LLC COLLECT?
In several areas of our Digital Properties, Cummings-Feola Family Foundation, LLC collects user-submitted personally identifiable information, such as your name, home address, email address, and telephone number.

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Cummings-Feola Family Foundation, LLC also collects anonymous demographic information, which cannot identify you personally, such as ZIP code, gender, or interests. We may append to the data you provide additional data from publicly available sources in an effort to enhance your relationship with Cummings-Feola Family Foundation, LLC.

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We may collect information about your interaction with our Digital Properties. For example, we may use website analytic tools on the Websites to retrieve information such as the site you came from or the keywords you used to find the Websites. We will also use technologies, such as cookies and pixel-based tracking, to collect information about the pages you view, the links you click on and other actions you take on the Websites. We use the aggregated information to provide a more useful and engaging experience to Website visitors. This information will sometimes be used to display content to you on our Websites, Applications or Social Media Sites.

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In order to access certain areas on our Digital Properties, you may need to first complete certain steps to become either a registered user or a subscriber. During these steps, you may be required to provide us with personally identifiable information such as your name, ZIP code and email address. This information is used to help us understand who uses our Digital Properties, to operate and improve our Digital Properties, and to deliver the services or carry out the transactions you have requested.

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COMMUNICATION TO CHILDREN

The Cummings-Feola Family Foundation, LLC Digital Properties are directed at a general audience. Please note that Website programs and Applications such as personal fundraising and sponsorship adoptions may only be used under the supervision of an adult, per the Terms of Use.

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HOW DOES CUMMINGS-FEOLA FAMILY FOUNDATION, LLC SECURE MY INFORMATION?
Cummings-Feola Family Foundation, LLC provides visitors to our Digital Properties with a secure experience when making a donation or purchasing merchandise through them. We work with Payment Card Industry Data Security Standard (PCI-DSS) compliant vendors. When personal information is transmitted, it is protected through the use of industry-standard security technology, such as the Secure Socket Layer (SSL) protocol.

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Even with these measures in place, users should use special caution when using publicly accessible computer terminals or transmitting personal information over unsecured wireless networks. In addition, on certain Website pages like blogs and news stories, we offer visitors the opportunity to provide comments or other user-generated content. You may also be able to comment on Social Media Sites or while using our Applications. Any information that you disclose when posting a message to these areas, along with the screen name or ID used, becomes public. We are not responsible for any personally identifiable information that you choose to disclose in the public areas of our Websites, Applications or Social Media Sites.

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Donor Privacy: Cummings-Feola Family Foundation, LLC does not sell, rent, or exchange its donor list for direct mailing purposes. Its Board of Directors adopted a policy prohibiting the sale, rental, or exchange of its donor list. This Privacy Policy outlines how donor information is used.

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HOW DOES CUMMINGS-FEOLA FAMILY FOUNDATION, LLC USE MY PERSONAL INFORMATION?​

Cummings-Feola Family Foundation, LLC collects and uses your personal information to circulate news about Cummings-Feola Family Foundation, LLC and its programs, to promote events, to acquire new members and subscribers, to operate the Cummings-Feola Family Foundation, LLC Digital Properties, and for other internal marketing, promotional, and fundraising purposes. We may use your personal information, demographic information or usage information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive; (2) to enable you to participate in the features of an Application or Website, including event registration, fundraising, or GPS mapping; (3) to improve an Application or our services, to customize your experience on the Application or Website, or to serve you specific content that is most relevant to you; (4) to contact you with regard to your use of our Digital Properties or (5) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

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Corporate Partners: Cummings-Feola Family Foundation, LLC may, from time to time, share personally identifiable information with carefully selected corporate partners to provide the programs, products or services for which we contracted. These corporate partners are required to protect the privacy of your

personally identifiable information, and not use or disclose your personally identifiable information for any other purpose. To opt out of mail and emailed offers, you may opt out by sending an email
to info@cummingsfeolafoundation.org. Keep in mind that this Privacy Policy applies only to our communications channels; if you independently provide information to a third party, you will be subject to that third party’s privacy policy.

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Outside Contractors: Cummings-Feola Family Foundation, LLC may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products such as to help us perform statistical analysis, send you email or postal mail, process donations or send email or other messages on your behalf (such as issue advocacy emails to legislators). Access to your personally identifiable information by these Outside Contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function for us. We also require that these Outside Contractors protect the privacy of your personally identifiable information consistent with this Privacy Policy, and not use or disclose your personally identifiable information for any purpose other than providing us with products or services for which we contracted.

 

Other: We may share aggregated demographic information with our funders, such as grant-making organizations and foundations, for the purpose of demonstrating that we are meeting our organization goals.

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Cummings-Feola Family Foundation, LLC may release personal information if we believe that the law or legal process served on Cummings-Feola Family Foundation, LLC requires it, to protect and defend the rights or property of Cummings-Feola Family foundation, LLC, or in an emergency, to protect the personal safety of an identifiable visitor or the public.

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HOW DOES CUMMINGS-FEOLA FAMILY FOUNDATION, LLC USE COOKIES?

The Cummings-Feola Family Foundation, LLC Websites and Applications use "cookies" to ensure the integrity of the registration and transactional processes and to help you personalize your online or mobile experience. A cookie is a text file that is placed on your device’s hard drive or other storage medium by a Web page server. Most Web and mobile browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Cummings-Feola Family Foundation, LLC Digital Properties you visit. To protect our visitors, cookies do not save payment or credit card information. You have the ability to accept or decline cookies.

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HOW DOES CUMMINGS-FEOLA FAMILY FOUNATION, LLC USE PIXEL TRACKING?
Cummings-Feola Family Foundation, LLC may use pixel-based tracking on its Websites to gather information about your website activities and display relevant content to you on the Websites and other media networks. Any personally identifiable information shared with or gathered by these media networks is considered confidential.

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HOW DOES CUMMINGS-FEOLA FAMILY FOUNDATION, LLC USE MY EMAILY ADDRESS?
Cummings-Feola Family Foundation, LLC sends email to opt in addresses only. An individual who receives email from us may opt out of email at any time by following the opt-out instructions contained in any Cummings-Feola Family Foundation, LLC email and may need to manage your email preferences on those sites individually.

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HOW CAN I MANAGE MY COMMUNICATIONS PREFERENCES?

There are many self-service options available to manage your mail, email, and other communication preferences. If you need assistance in managing your preferences please email info@cummingsfeolafoundation.org.

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• Mail: The Direct Marketing Association (DMA) maintains a national Do Not Mail list. If you would like to remove yourself from all direct marketing lists, visit the DMA website to update your preferences.

• Email: In compliance with the CAN-SPAM Act, all Cummings-Feola Family Foundation, LLC emails have the option to unsubscribe by replying to info@cummingsfeolafoundation.org.

• Phone: The FTC’s National Do Not Call Registry will allow you to remove a number from all telemarketing lists. Visit the National Do Not Call Registry website to update your preferences.

• Internet Activity: Cummings-Feola Family Foundation, LLC is investigating a “Do Not Track” mechanism that would allow you to choose whether you want to allow Websites covered by this Privacy Policy to collect information about your Internet activity. Currently, Do Not Track signals are not effective on our Websites. You will be notified of any actions taken by Cummings-Feola Family Foundation, LLC resulting in a change to this Privacy Policy by the methods described in the section entitled “Changes to the Policy.”

• Other communications preferences: For any other communications preferences you would like to change, please email info@cummingsfeolafoundation.org

 

EU GENERAL DATA PROTECTION REGULATION (GDPR) CONSIDERATION

Cummings-Feola Family Foundation, LLC does not intend to solicit users from within the European Economic Area (EEA) to visit its Websites, Applications, or Social Media Sites. Best Friends commits to continue to follow safe data handling processes and will follow European data privacy laws and regulations to the extent applicable.

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If the processing of your personal information is subject to the GDPR, and your personal information is processed based on legitimate interests you have the right to object to the processing on grounds related to your specific situation.

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If the processing of your personal information is subject to the GDPR, you also have certain rights to request to have your personal information deleted, request that your personal information be restricted, and to ask for portability of your personal information.

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To the extent they are applicable, you can exercise these rights (including making these requests) by emailing us at info@cummingsfeolafoundation.org Please put the statement “GDPR Privacy Rights” in the subject of your request, as well as your name, country, or region, and enough information to allow us to respond. If your use of our Websites, Applications, or Social Media Sites falls under GDPR regulations that are applicable to us, we agree, subject to any legally permitted exception or extension to respond to access, deletion, rectification, or suspension requests within 30 days of receipt of the request.

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CONTACT INFORMATION

Cummings-Feola Family Foundation, LLC welcomes your comments regarding this Privacy Policy. If you have any questions or believe that Cummings-Feola Family Foundation, LLC has not adhered to this policy, please contact Cummings-Feola Family Foundation, LLC at info@cummingsfeolafoundation.org. We will use commercially reasonable efforts to promptly determine and remedy the problem.