1. Privacy Statement
The terms "you" and "your" refer to each individual who is a source of Personally Identifiable Information to Spero's Hope, including (i) individuals who transact business with Spero's Hope, such as our clients, vendors, contracting parties, and other users of our services ("External Users"), (ii) employees of Spero's Hope and its affiliates, including its affiliates and subsidiaries outside of the United States, as well as applicants for employment by Spero's Hope or its affiliates ("Internal Users"); and (iii) casual visitors to our Website, who do not participate in or receive Spero's Hope services ("Site Visitors"). For convenience, we use the term "User" to refer collectively to our External Users, Internal Users, and Site Visitors.
2. General Information on Privacy
The term "Personally Identifiable Information" as used in this Policy refers to two categories of personal data: General Personally Identifiable Information and Sensitive Personally Identifiable Information. General Personally Identifiable Information: means first and last name, birth date, gender, email address, mailing address, profession, education, or professional affiliations used to identify you. All other levels of personal information including, but not limited to, religion, race, health status, political opinion, sexual preferences, income, social security number, credit card numbers, order history, or prescribing habits are known as "Sensitive Identifiable Information", and together, we refer to General Personally Identifiable Information and Sensitive Identifiable Information as simply "Personally Identifiable Information." Spero's Hope will collect and use only as much Personally Identifiable Information as is (i) required by law or (ii) necessary to fulfill the purpose for which the Information is collected, as such purposes are detailed in this Policy.
3. Notice of Information Collection
Through the Website, we offer convenient online access to our services and communicate important information about events. We collect two types of information, general data which is not individually identifiable, and individually identifiable information. The collection of personally identifiable information only occurs when individuals provide it to us knowingly and voluntarily.
Depending on the interactions with Spero's Hope, we may use the information submitted by you in the following ways:
- signing up as a client for one or more of our services
- to make an appointment to meet with us
- to register for a workshop or program
- as part of the application process for vocational tuition assistance
- to sign up to become a volunteer
- to attend an event
- to make a donation
- to send you information relating to Spero's Hope and/or to respond to your inquiries
- to contact you regarding feedback and surveys
- to apply to work at Spero's Hope
When you provide Personally Identifiable Information to Spero's Hope, we will tell you why the information is being requested and for what purpose it will be used. For example, we may collect and use Personally Identifiable Information to provide you with information regarding our services, to fulfill a request related to our services, to market products and services which we think may be of interest to you, or to communicate with you for other purposes.
We will always provide you the opportunity to (i) opt-out of our use of General Personal Information and (ii) opt-in for our use of Sensitive Personal Information, as discussed in Section 5 (Choice).
3.1. Personal Data - External Users
If you conduct business with us, it is likely that you will provide Personally Identifiable Information to us in connection with this business relationship. This Personally Identifiable Information may be as simple as information contained on your business card, or may be more detailed. We use Personally Identifiable Information provided by our External Users to fulfill business transactions in which the parties are engaged, to monitor and ensure performance of each party's obligations, and for other business purposes ("Business Contact Information"). We also may use this Personally Identifiable Information to notify our External Users of business and other developments that concern Spero's Hope or that concern the Users' business and other interests ("Business Updates"). If an External User chooses to withhold Business Contact Information that we request for the purposes stated above, it may not be possible for us to undertake, or continue a business relationship with that User. In contrast, all External Users are entitled to opt-out of use of their Personally Identifiable Information for Business Updates, in accordance with Section 5 (Choice).
3.2. Personal Data - Internal Users
If you are a job applicant or a Spero's Hope employee, we will collect Personally Identifiable Information to facilitate or sustain the employment relationship ("HR Data").
3.3. Personal Data - Site Visitors
Most of our services do not require any form of registration, allowing a Site Visitor to visit our Website without telling us who he or she is. However, some services may require registration. When you register with us, you may need to complete certain fields (some are required and some are optional), as well as choose a user name and password. In these situations, if you choose to withhold Personally Identifiable Information requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your inquiry or request.
We also use your information for the purpose of operating and maintaining the Spero's Hope Website and to understand usage trends and preferences. This helps us to enhance the way the Website works and looks, as well as to create new features and functionality. We may use collected information to remember your information so that you do not have to re-enter it during your visit or the next time you visit the Spero's Hope Website. We may monitor aggregate usage metrics such as total number of visitors.
3.4. Use and Disclosure of Information
Subject to the provisions of Section 6 (Onward Transfer), Spero's Hope will not sell, share, or otherwise distribute Personally Identifiable Information to third parties outside of Spero's Hope.
4. Use of Anonymous Information; Cookies and Other Tracking Systems
In the course of providing services, operating this website, and otherwise conducting our business, we will compile and use anonymous information. Anonymous information is information in a form that does not allow a third party to identify you. Anonymous information might include, for example, the fact that an unidentified site visitor viewed certain pages on our website, or performed certain searches on the website. Anonymous information might also include survey responses and other feedback that users provide to us, where this information has been de-identified to prevent disclosure of the user who provided the information. We use anonymous information, and engage consultants to assist us in using this information, to improve our good and services, and the features and content of this website, to compile and analyze aggregate statistics about our users, and to engage in related business, marketing, and research activities, on the commitment that any such uses will not identify you.
When you visit our website, we do not collect any information from which a third party may be able to personally identify you, such as your name, address, email address or telephone numbers, without your express consent. To compile anonymous information concerning use of our website, Spero's Hope may request or provide your browser with "cookies". Cookies, by themselves, cannot be used to discover the specific identity of the user. A cookie is a small piece of information that is sent to your browser and stored on your computer's hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie or to reject cookies and this will enable you to decide if you want to accept it or not. Spero's Hope may not permit you to access certain web pages within its website in the event your browser does not accept a cookie request.
On occasion, we may use internet tags (also known as action tags, single-pixel gifs, clear gifs, invisible gifs, and 1-by-1 gifs) in combination with cookies and may deploy these tags through a third-party advertising partner. These tags are on different pages of our website to measure the visitors' responses to our website and the effectiveness of our advertising campaigns (including how many times a page is opened and the information viewed). These internet tags may provide certain demographic information, but again, never personally identifiable information. If you would like more information about web tags and cookies associated with online advertising or to opt-out of third-party collection of anonymous information, please visit the network advertising initiative website at www.networkadvertising.org.
By using our website you agree that we can place the types of cookies set out above on your device. Please be aware that if you block cookies, some site functionality may be lost, disabled, or prone to errors.
Spero's Hope will not use your Personally Identifiable Information in ways unrelated to the ones described above without first notifying you and offering a choice. This choice may be offered at the bottom of our online or offline communications to you as well as on the website form pages. If you would like to exercise your choice and advise us on your preferences about how we contact you or to "opt out" of communications from Spero's Hope, please contact us in accordance with Section 14 (Contact Us).
5.1. Opt-Out of Use of General Personal Information
Spero's Hope will provide you the opportunity to let us know if you wish to opt-out at any time from our use of your General Personal Information, including certain or all contacts from Spero's Hope, and we will do everything we can to honor such requests. To unsubscribe from our promotional emails, please click the link found at the bottom of each email or update your account preferences. Opting-out of certain uses may impact our relationship with you, as further outlined in Sections 3.1 through 3.3.
5.2. Opt-In for Use of Sensitive Personal Information
In the event that Spero's Hope would like to use your Sensitive Personal Information for a purpose other than the purpose for which it was originally collected, we will provide you the opportunity to "opt-in" or decide whether you agree to such use of your Sensitive Personal Information. Without your explicit consent, we will not use your Sensitive Personal Information for a purpose other than the purpose for which it was collected.
6. Onward Transfer
Spero's Hope does not sell, rent or lease your Personally Identifiable Information to others. Unless we have your permission or are required by law, we only share your Personally Identifiable Information with other Spero's Hope affiliates or our contractors who are acting on our behalf for the uses described above including, but not limited to, credit card processing and email distribution. Our contractors are obligated to keep Personally Identifiable Information confidential and may not use it for any purpose other than to carry out the services they are performing for Spero's Hope. Additionally, we ensure that our affiliates' privacy policies are at least as protective of your information as this Policy.
Subject to your permission or as permitted by applicable law, the Personally Identifiable Information that you provide us may be transferred across state or country borders to consolidate data storage, to simplify information management, or to permit centralized decision-making and analysis.
To the extent permitted by applicable laws, we may disclose Personally Identifiable Information to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of Spero's Hope, our customers, our Website, or our Users. To the extent that US discovery laws conflict with foreign national data protection and/or privacy laws, we will comply with orders of and direction from the court or other regulatory authority that has jurisdiction to resolve such conflict.
Spero's Hope is committed to ensuring the security of your Personally Identifiable Information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of Personally Identifiable Information, we have put in place appropriate physical, electronic and organizational measures to safeguard and secure this Information. Spero's Hope employees are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personally Identifiable Information. Moreover, we provide access to our databases containing Personally Identifiable Information on a need-to-know basis only.
We actively monitor and scan our systems on a regular basis for security holes and vulnerabilities in order to make your visit to our site as safe as possible.
Financial transactions are processed by PayPal, our preferred vendor, to ensure the security of your financial information. No financial information is ever stored on our servers or in our systems. We use safeguards to protect the security of your credit card transactions. We use the latest industry standard encryption and security protocols that make it very difficult for anyone to intercept or obtain access to your credit card information. When we work with other companies, such as PayPal, those companies also use encryption and security controls.
However, this policy should not be construed in any way as giving business, legal, or other advice, or warranting as fail-proof, the security of information submitted to or collected by Spero's Hope. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
8. Access and Data Integrity
Spero's Hope strives to keep your Personally Identifiable Information accurate. We will provide you with reasonable access to Personally Identifiable Information you have provided to Spero's Hope and reasonable ability to review and correct it, or ask for deletion, as applicable. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. To access your Personally Identifiable Information, please contact us in accordance with Section 14 (Contact Us).
Individuals who believe their complaints have not been resolved to their satisfaction through Spero's Hope normal procedures may contact the data protection authority in their jurisdiction. Spero's Hope is committed to working with national data protection authorities to (i) resolve disputes over Spero's Hope privacy practices and (ii) comply with the decisions and orders of these data protection authorities. If you have questions regarding how to contact the data protection authority in your jurisdiction, please contact us in accordance with Section 14 (Contact Us).
This website is not intended for, or designed to attract, individuals under the age of 18.
11. Links to Other Sites
12. Change in Control
Should there be a corporate change in control, through merger, acquisition or bankruptcy, we reserve the right to transfer Personally Identifiable Information collected from you to the new party-in-control of Spero's Hope in the normal course of business, provided such party agrees to comply with this Policy.
14. Contact Us
If you have any questions, concerns or comments about our privacy practices, please contact us at firstname.lastname@example.org or (929) 314-HOPE (4673).
Last updated: January 24, 2015