Meals on Wheels America’s Commitment to Privacy
Meals on Wheels America is committed to maintaining your confidence and trust as related to the protection of your personal information. Our commitment applies to all people who communicate with us through any and all of our communication channels, including this Website and online or offline communications. We respect the privacy of those who interact with Meals on Wheels America, and will seek to protect the integrity and confidentiality of personal information gathered from our donors, members, Website visitors, other supporters and anyone else who contacts us. We understand our ethical responsibilities and the important role we play as custodians of your personal information.
Effective as of March 1, 2023
We at Meals on Wheels America are committed to adhering to the legal rights bestowed upon Users as may be applicable to the use of our Platforms. These include the rights to access information about Users’ personal data that we process and to have their personal data deleted or corrected as needed, among other rights.
What Information is Collected and How is Such Information Collected and Used?
- Information You Provide to Us
- How We Otherwise Collect Information
- How We Use Information We Collect
- With Whom is Collected Information Shared?
- How is Your Information Secured?
- How to Access Your Personal Information and Control Its Use?
We will collect data only as is permitted through legal means, offer consumers the clear option to choose if their data will be collected and used, and tell you up front why and how we collect, store, and use data. Meals on Wheels America can be contacted by email at firstname.lastname@example.org.
1. Information We Collect and How Such Information is Collected and Used
As discussed below, we do not collect any Personally Identifiable Information (“PII” or “Personal Information”) from you unless you voluntarily provide it to us. When you visit our Website or interact with us through one of our Platforms, we may collect information from you as described below.
Information You Provide to Us
How information is provided to us through various operations is explained in more detail below.
- Donations: If you make a donation to Meals on Wheels America using the Website, we will collect your name, address and credit or debit card or other financial account information in order to process the contribution. We will also ask your permission to contact you in the future; without your permission, we will not contact you. We may also include your name, city and state, and donation range (not a specific amount) on our Website and in various reports that may be made public. Certain states and the Federal government also require us to report the names and addresses of donors, as well as the amounts of their donation(s) on an annual basis; such reports are reviewed by state officials but are not made public. Other than for legally required disclosures, you can change your preferences at any time.
- Purchases: If you will be purchasing items from our Website, certain information will be required from you to complete the transaction. Transactions may be processed directly through Meals on Wheels America or through third-party vendors or credit card processors. Information required may include your contact information (name and address) and your financial information (for example, credit card number and expiration date). This information is used for billing purposes and to fill your orders and for other purposes with your permission. This information will also be used to contact you if we have trouble processing your order. Privacy policies for our third-party vendors providing goods and services will be available on the applicable webpage and apply to the transactions contemplated; the application of the Meals on Wheels America privacy policies end when you enter sites of our vendors. Please consult the privacy policies of any third-party vendor to determine how they will access your information.
- Surveys: Meals on Wheels America will periodically request information via surveys on or through our Platforms. Participation in these surveys is completely voluntary; you may choose whether or not to participate and therefore disclose the requested information. Information requested may include contact information (such as name and mailing address), and demographic information (such as zip code, age). Contact information may be used to contact you and may be used for such other purposes as you permit. Survey information will be used for purposes of monitoring or improving the use and performance of the Platform. Meals on Wheels America will not share your personal information collected through such surveys with any organizations without your consent except as may be described herein or as may be compelled by law.
- Sensitive Personal Data and Information: Unless specifically requested or invited, please do not send or otherwise disclose to us sensitive information, including but not limited to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. In those limited and very unlikely circumstances where we may request or invite you to provide any of the foregoing information, we will only do so with your express consent or your ability to “opt-in” to approve our collection and processing of such data, in accordance with applicable data protection law requirements. Where you provide us with such information without request from Meals on Wheels America, we reserve the right (but do not have any obligation) to erase any such information at our discretion.
- Information About Minors: Our Website and other Platforms are not intended for use by persons under the age of 16. We do not knowingly collect Personal Information online from persons in this age group. If you are a User under the age of 16, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 16 without parental consent, or if we learn a User under the age of 16 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible.
How We Otherwise Collect Information
- Location Information: Any comment system on our Website may utilize an opt-in Geolocation service in accordance with a prevailing community standard such as HTML 5. Such Geolocation opt-in ability is managed by the user’s browser settings. If a user chooses to opt-in to the Geolocation service, the user’s comments may be associated with the user’s location, both internally within Meals on Wheels America and publicly on the Website.
- Cookies and other Passive Information Collection, Use, and Choices: Like most Websites, we use automatic data collection technology when you visit our Website to passively gather non-personally identifiable information but that identifies your computer to track your use of our Website and to collect certain basic information about you and your usage habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a Website you visit, and similar information concerning your use of the Website and the Services (the “Usage Information”).
Collection of Usage Information may be done using various techniques in the following ways:
IP addresses: An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Website, we may view the IP address of the device you use to connect to the Internet. We may use this information to determine the general physical location of the device and understand from what geographic regions our Website visitors come. We also may use this information to improve the functionalities and features of our Website.
You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit our Website, but may not be able to use some areas of the Website and/or the Services offered there. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies.
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and internet browser type and version.
- Social media widgets: Our Website may include social media tools, including social media widgets or plug-ins, to connect you to your social media accounts. These features may set a cookie or use other automatic collection and tracking technology to collect information about you and your use of the social media features through and in connection with our Website. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.
How We Use the Information We Collect
- to respond to your inquiries and to send you information that you request and to process your donations;
- to send you important information regarding our relationship with you, such as to let you know what we are doing with your donations and to solicit additional donations, or regarding the Website, changes to our terms, conditions, and policies, and other administrative information;
- to notify you about upcoming events and opportunities to further engage with Meals on Wheels America, including participating in future fundraising and advocacy efforts;
- to promote our mission and initiatives, and the missions and initiatives of our Members;
- for our business purposes, such as data analysis, audits, recordkeeping, developing new products or Services, enhancing the Website, providing a safe user experience on our Website, improving our Services, identifying Website usage trends, optimizing your experience on the Website, determining the effectiveness of our fundraising campaigns, and managing legal issues;
- if you choose to complete a survey, we may use the information for purposes of evaluating your feedback from the survey; and,
- if we intend to collect and use Personal Information for another purpose, such as publicly recognizing our donors in an Honor Roll of Donors, we may seek your permission at the time the information is collected if the Donor has not previously opted out.
Non-Personally Identifiable Information. We may use any information that does not personally identify you, your computer, or your device for any purpose.
With Whom is Collected Information Shared?
- Contracted Service Organizations, specifically to the companies or individuals that we hire to provide services to us, such as Website hosting services, relationship management services, communication and fundraising services, and payment processing. In such circumstances, we will seek to ensure that our contracts with such service providers include specific requirements such as limiting their processing of personal data to identified purposes, not sharing any PII, and maintaining appropriate security measures comparable to ours.
- Uses and Disclosures to Comply with Laws, which may include disclosures of Personal Information collected through our Platforms as we believe to be necessary or appropriate: (A) under applicable law, including laws outside your country of residence; (B) to comply with legal process; (C) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (D) to enforce our terms and conditions; (E) to protect our operations or those of any of our affiliates; (F) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; (G) to allow us to pursue available remedies or limit the damages that we may sustain; or (H) as may be required as a result of a reorganization, merger, sale, bankruptcy, assignment or transfer, or similar proceeding.
2. How Is Your Information Secured?
At Meals on Wheels America, you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. We strive to take appropriate security measures to prevent unauthorized access to, or unauthorized alteration, destruction or disclosure of, your PII. We use a variety of security measures to protect your data, including physical, electronic, and procedural safeguards. Our systems follow the applicable requirements of Payment Card Industry (PCI) compliance Requirement 3 (Protect Stored Cardholder Data) and Requirement 6 (Develop and Maintain Secure Systems and Applications). Within the system, cardholder primary account number (PAN) is encrypted when saved with strong cryptography and masked when displayed to the internal user. Cardholder data is transmitted encrypted through Transport Layer Security (TLS) 1.2). We do not store CVV numbers. Our hosted systems are protected by network and web application firewalls, intrusion detection and prevention systems, and anti-virus software. Our systems are monitored 24 hours a day, 7 days a week and housed in a restricted access facility. We also incorporate industry-standard security controls (like firewalls) and protocols (like SSL/TLS) to create a Website that is resistant to standard internet-based threats. Our systems of controls are regularly assessed and audited.
Meals Wheels America is based in the United States. No matter where you are located, your Personal Information will be collected and processed in the United States. The laws of the United States and other countries governing data on protection may not be as comprehensive or as protective as the laws in the country where you live.
No Website or electronic data can ever be completely secure, but we are always working to maintain up-to-date and appropriate security mechanisms. You agree that Meals on Wheels America shall not be liable to you for any modification, suspension, or discontinuance of the Website. Users should also be aware that certain elements of our Website are operated by third-party vendors who have their own linked privacy policies. Once you begin to interact with such sites, the privacy policies and other terms of such vendors apply, and it is your sole obligation to review and understand the privacy practices and policies of these other Websites.
3. How to Access Your Personal Information and Control its Use?
As explained below under Data Rights and throughout this Policy, you have rights to access your information, know how it is being used, correct or delete any information we maintain, and express any concerns about our policies or the use of your data.
- Contact Information. In order to obtain this information, please reach us through email@example.com via the contact information below. Where possible, please use a Data Subject Access Request (“DSAR”) form for any questions about the privacy or our use of your Personal Information.
If you have specific questions about our Website, please contact firstname.lastname@example.org.
To contact us by mail or phone, please use the following:
Meals on Wheels America
Attn: General Counsel
1550 Crystal Drive, Suite 1004
Arlington, VA 22202
Telephone: 888-998-6325; 703-548-5558.
Always include your name and contact information when you reach out to Meals on Wheels America. Please note that it may take up to 90 days to stop receiving communications by regular mail after you have requested that your data be removed from our lists.
- Cookies: You can opt-out of the use of certain cookie-related processing by following the instructions in Section 1(b)ii above (Cookies and other Passive Information Collection, Use, and Choices).
- Data rights: If you would like to submit a data access, correction, restriction, or deletion request, you may do so by contacting us at email@example.com or via the contact information above. Please use a DSAR form. We will process such requests with respect to any Personal Information that we are able to link to you individually based on the information that you can provide to us. This would include, for examples:
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Have us delete any data we have about you.
- Unsubscribe from our communications.
- Request that we do not solicit you for donations.
- Express any concern you have about our use of your data.
These rights and options that you have with respect to Personal Information are subject to limitations and exceptions under applicable law.
- European Union: If you are within the European Union, you have the following rights:
- You have the right to request from Meals on Wheels America access to your Personal Information, and the rectification of inaccurate Personal Information concerning you.
- You have the right to request that Meals on Wheels America not subject your Personal Information to automated processing.
- You have the right to obtain from Meals on Wheels America the erasure or the restriction of processing of your Personal Information in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when Meals on Wheels America is required by law to maintain or otherwise process your Personal Information, for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another person.
You may exercise these rights by contacting Meals on Wheels America using the contact information provided above.
If you are within the European Union, you also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law. However, we encourage you to contact us first at firstname.lastname@example.org and we will try to resolve your concerns.