Privacy Policy
The WIZDM.org website and
service including (without limitation) wizdm.org and all other websites,
mobile applications and other interactive properties through which the service
is delivered (collectively, the/our “Service”) are owned, operated and distributed
by Jewish Heritage Connection Inc, a registered Section 501(c)(3)
nonprofit organization (referred to in this Privacy Policy as “Social Impact
Initiative” or “we” and through similar words such as “us,” “our,” etc.). By
accessing any part of the Service, you are agreeing to the terms and conditions
described below (this “Privacy Policy”) and the terms and conditions of our
terms of service (the “Terms of Service”). If you do not agree to any of these
terms, you should not use the Service. This Privacy Policy applies to all
users, including but not limited to users who are simply viewing content
available via the Service, users who have registered as members of the Social
Impact Initiative, and teachers, mentors, personnel, or administrators associated
with any individual, entity, or group affiliated with or using the Service.
We may, at our sole
discretion, modify this Privacy Policy at any time. Use of information we
collect now is subject to the Privacy Policy in effect at the time such
information is used. If we make material changes in the way we collect or use
information, we will notify you by posting an announcement on the Service or
sending you an email. By accessing the Service at any time after such
modifications, you are agreeing to be bound by the updated policy. This Privacy
Policy was last modified as of August 21, 2020.
General
Your privacy is very
important to us. Accordingly, we have developed this Privacy Policy in order
for you to understand how we collect, use, communicate and disclose and make
use of Personal Data (as defined below). The following outlines our privacy
policy.
EU Personal Data
If you are located in the
European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you
may have additional rights under the EU General Data Protection Regulation
(the “GDPR”) with respect to your Personal Data, as outlined in the EU
Privacy Notice below.
Student-based And Other
Qualifying Users
A “Qualifying
Institution” is a school, college, university, organization, institution,
entity, youth group, or youth movement that the Social Impact Initiative has,
AT ITS SOLE DISCRETION, agreed to provide access to and/or accounts with the
Service.
If you are a student
attending a Qualifying Institution or if you are a member of a Qualifying
Institution and are accessing the Service through an account provided by the
Qualifying Institution (a “Student-based User”), you may only access the
Service if you are at least 13 years old.
You must be 13 years of
age or older to use our Service. If you are under the age of 16, you may not
use our Service without parental consent. We do not knowingly collect or
solicit Personal Data from anyone under the age of 16, unless you are a
Student-based User (as defined in this Privacy Policy). If you are under 16,
please do not attempt to register for the Service or send any Personal Data
about yourself to us unless you are a Student-based User. If we learn that we
have collected Personal Data from a child under age 16 who is not a
Student-based User, we will delete that information as quickly as possible. If
you believe that a child under 16 may have provided us Personal Data, please
contact us at support@wizdm.org.
Personal Data
When you register with us
and become a Social Impact Initiative participant, when you choose to teach or
attend a class, we will ask you for Personal Data. “Personal Data” refers to
information about you that can be used to contact or individually identify you.
This includes, but is not limited to, your name, email address, but does not
include your credit card number or billing information. To the extent
applicable, transactions involving your billing and payment information are
processed by PayPal and Stripe and
are subject to their privacy policies. We do not store any of the credit card
or banking information that you provide to these payment processors.
In order to send you
email from Social Impact Initiative, we need your email address. To provide you
with additional services, we may also request your name, general location, and
telephone number. We may give some or all of this information to the teachers
for classes that you sign up for so that they can coordinate their classes. We
will not give your name, email, or other Personal Data to unaffiliated third
parties except with your consent or as otherwise set forth in this privacy
policy. Though we employ industry standard measures to preserve user privacy,
we may need to disclose Personal Data when required by law or when we have a
good faith belief that such action is necessary to comply with a current
judicial proceeding, a court order or legal process that we receive or to
protect our interests or the safety of others. In addition, we may provide
Personal Data to employees, consultants or other business or persons for the
purpose of processing such information on our behalf. In such circumstances, we
require that these parties agree to protect the confidentiality of such
information and to comply with the terms of this Privacy Policy. We may use
your Personal Data to operate, improve, understand and personalize our
Service. Further, the Social Impact Initiative reserves the right to share
any user data, including Personal Data, with any Qualifying Institution,
partner, school, movement, or organization to further the goals of the Social
Impact Initiative.
Voluntary Disclosure
Any Personal Data or
content that you voluntarily disclose in public areas becomes publicly
available and can be collected and used by other users for any reason. Your
profile pages (“Profile”) and any online classrooms you participate in are
typically publicly available. You have the ability to change your account
settings to limit access to your profile, and may delete content you post to
public classrooms. If you need assistance with controlling your account privacy
settings or with deleting content, please contact us at support@wizdm.org.
Removal of posted content does not ensure complete or comprehensive removal of
the content or information (e.g., some content may be “invisible” to other
users but remain on our servers in some form). You should exercise caution
before disclosing your Personal Data via these or any other public venues.
For example, if you
choose to sign up for a Social Impact Initiative account, you may have a
Profile on the Service, containing your full name and some basic information
including your location and bio. You may also add additional optional
information to your Profile. You may control what type of Profile information
is shown to others through your Account Settings. Any information you choose to
provide as part of your Profile should reflect how much you want other Social
Impact Initiative users to know about you. We recommend that you guard your
anonymity and sensitive information and we encourage members to think carefully
about what information about themselves they disclose in their profile pages.
You can review and revise your profile information at any time.
Children’s Privacy
As noted in our Terms of
Service, you must be 13 years of age or older to use the Service. If you are
under 16 you may not use the Service without parental consent. We do not
knowingly collect or solicit Personal Data from anyone under the age of 16,
unless you are a Student-based User. If you are under 16, please do not attempt
to register for the Service or send any Personal Data about yourself to us
unless you are a Student-based User. If we learn that we have collected
Personal Data from a child under age 16 who is not a Student-based User, we
will delete that information as quickly as possible. If you believe that a
child under 16 may have provided us Personal Data, please contact us at support@wizdm.org.
Information About Cookies
We use your IP address to
help diagnose problems with our server, to administer our Service, and to
analyze traffic patterns on the Service. The Service also uses cookies and
similar technologies such as pixel tags, web beacons, clear GIFs, and
JavaScript (collectively, “Cookies”) to enable our servers to recognize
your web browser and tell us how and when you visit and use our Service, to
analyze trends, learn about our user base and operate and improve our Service.
For example, we use Cookies to deliver content specific to your interests, to
save your password so you don’t have to re-enter it each time you visit, and to
track whether emails we send you have been viewed. Cookies are small files –
usually consisting of letters and numbers – placed on your computer, tablet,
phone, or similar device when you use that device to visit our Service. We
sometimes combine information collected through Cookies that is not Personal
Data with Personal Data that we have about you, for example, to tell us who you
are or whether you have an account with us. We may also supplement the
information we collect from you with information received from third parties.
Cookies can either
be “session Cookies” or “persistent Cookies”. Session Cookies are
temporary Cookies that are stored on your device while you are visiting our
Service or using our Service, whereas “persistent Cookies” are stored on
your device for a period of time after you leave our Service. The length of
time a persistent Cookie stays on your device varies from Cookie to Cookie. We
use persistent Cookies to store your preferences so that they are available for
the next visit, and to keep a more accurate account of how often you visit our
Service, how often you return, how your use of the Service may vary over time.
We also use persistent Cookies to measure the effectiveness of advertising
efforts. Through these Cookies, we may collect information about your online
activity after you leave our Service. Your browser may offer you a “Do Not
Track” or “DNT” option, which allows you to signal to operators of
websites, and web applications, and services that you do not wish such
operators to track certain of your online activities over time and across
different websites.
Some Cookies are placed
by a third party on your device and may provide information to us and third
parties about your browsing habits (such as your visits to our Service, the
pages you have visited and the links and advertisements you have clicked).
These Cookies can be used to determine whether certain third party services are
being used, to identify your interests, to retarget advertisements to you and
to serve advertisements to you that we or others believe are relevant to you.
We do not control third party Cookies.
We use the following
types of Cookies:
- Essential
Cookies. Essential Cookies are required for providing you with features or
services that you have requested. For example, certain Cookies enable you
to log into secure areas of our Service. Disabling these Cookies may make
certain features and services unavailable. - Functionality
Cookies. Functional Cookies are used to record your choices and settings
regarding our Service, maintain your preferences over time and recognize
you when you return to our Service. These Cookies help us to personalize
our content for you, greet you by name, and remember your preferences (for
example, your choice of language or region). - Performance/Analytical
Cookies. Performance/Analytical Cookies allow us to understand how
visitors use our Service such as by collecting information about the daily
number of visitors to the Service, the daily requests we receive for
particular files on the Service, and what geographical areas those
requests come from. These aggregated statistics are used internally to
better provide services to the public and may also be provided to others.
Performance/Analytical Cookies also help us measure the performance of our
advertising campaigns in order to help us improve our campaigns and the
Service’s content for those who engage with our advertising. For example,
Google, Inc. (“Google”) uses cookies in connection with its Google
Analytics services. Google’s ability to use and share information
collected by Google Analytics about your visits to the Service is subject
to the Google Analytics Terms of Use and the Google Privacy Policy. You
have the option to opt out of Google’s use of cookies by visiting the
Google advertising opt-out page at https://www.google.com/privacy_ads.html or
the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
You can decide whether or
not to accept Cookies. One way you can do this is through your internet
browser’s settings. Most browsers have an option for turning off the Cookie
feature, which will prevent your browser from accepting new Cookies, as well as
(depending on the sophistication of your browser software) allow you to decide
on acceptance of each new Cookie in a variety of ways. You can also delete all
Cookies that are already on your computer. If you do this, however, you may
have to manually adjust some preferences every time you visit a site and some
service and functionalities may not work.
To explore what Cookie
setting are available to you, look in the “preferences” or “options” section of
your browser’s menu. To find our more information about Cookies, including
information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Third Party Advertising
We may use third party
providers, including Facebook and Google AdWords, to advertise the Service
across the internet. These providers may use cookies, web beacons, and other
storage technologies to collect or receive information from the Service and
elsewhere on the internet and use that information to provide measurement
services and display targeted ads to you.
A cookie is used to
indicate to other websites that you visited a particular page, and allows us to
tailor our marketing to better suit your needs and only display ads that are
relevant to you. This cookie does not in any way give access to your computer
or mobile device.
If you do not wish to see
ads from us, you can opt out in several ways:
- Opt
out of Google’s use of cookies by visiting Google’s Ads
Settings. - Opt
out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
Other Sites
The Service may contain
links to other websites or services. We are not responsible for the privacy
practices or the content of such websites or services, and you should review
the privacy policy of each such website or service to make sure that you are
comfortable with it before providing any Personal Data. For example, all
teacher payments for classes are processed through third party payment
processors. As discussed above, we do not receive any of the credit card
information you provide to our third party payment processors, and all such
information is subject to their privacy policies.
Teachers and Mentors
As discussed above, we
may give your Personal Data to the teachers and Mentors for classes
(“Teachers”) that you sign up for so that they can coordinate their classes. As
part of our Terms of Use, Social Impact Initiative Teachers agree not to abuse
other users’ Personal Data. Abuse is defined as using Personal Data for any
purpose other than those explicitly specified in the Teachers’ Class. However,
please understand that Social Impact Initiative Teachers are not our employees
or consultants and that we are not party to any transaction between you and the
Teacher. As a result, we cannot control their actions and cannot be held liable
for any actions that they may take.
Business Transfers
In the event that we are
acquired by or merged with a third party entity, we reserve the right to
transfer or assign the information we have collected from users, including
without limitation Personal Data, as part of such merger, acquisition, sale, or
other change of control. In the unlikely event of our bankruptcy, insolvency,
reorganization, receivership, or assignment for the benefit of creditors, or
the application of laws or equitable principles affecting creditors’ rights
generally, we may not be able to control how your Personal Data is treated,
transferred, or used.
Transfers to the United
States
The Service is hosted in
the United States. If you are accessing the Service from the European Union,
please see the section titled “Transfers of Personal Data” in the EU
Privacy Notice below. If you are accessing the Service from any other region
with laws or regulations governing personal data collection, use, and
disclosure that differ from United States laws, please be advised that through
your continued use of the Service, which is governed by United States law, this
Privacy Policy, and our Terms of Service, you are transferring your Personal
Data to the United States and you consent to that transfer.
California Privacy Rights
California Civil Code
Section 1798.83 permits users of the Service who are California residents to
request certain information regarding its disclosure of Personal Data to third
parties for their direct marketing purposes. To make such a request, please
send an email with ‘California Privacy Rights’ in the heading to support@wizdm.org
or write us at the address listed below.
EU Privacy Notice
If you are located in the
European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you
may have additional rights under the EU General Data Protection Regulation
(the “GDPR”) with respect to your Personal Data, as outlined below.
For this EU Privacy
Notice section, we use the terms “Personal Data” and “processing” as
they are defined in the GDPR, but, in addition to the information identified in
the Privacy Policy as Personal Data above, “Personal Data” generally means
information that can be used to individually identify a person,
and “processing” generally covers actions that can be performed in
connection with data such as collection, use, storage and disclosure. Social
Impact Initiative will be the controller of your Personal Data processed in
connection with the Service.
If there are any
conflicts between this section and any other provision of this Privacy Policy,
the policy or portion that is more protective of Personal Data shall control to
the extent of such conflict. If you have any questions about this section or
whether any of the following applies to you, please contact us at support@wizdm.org.
What Personal Data Do We
Collect From You? We collect Personal Data about you when you provide such
information directly to us, when third parties such as our business or
education partners or service providers provide us with Personal Data about
you, or when Personal Data about you is automatically collected in connection
with your use of our Service.
Information we collect
directly from you: We receive Personal Data directly from you when you provide
us with such Personal Data, including without limitation the following:
- First
and last name - Email
address - Date
of birth - Gender
- Biographical
information - Location
information (limited to city, state, zip code, country, and time zone) - Employment
history - Links
to your social media accounts - Any
other information you choose to share publicly on the Service, for
example, anything you post to a public part of your Profile or an online
classroom on the Service - Information
we receive from third party sources: Some third parties such as our
business or education partners and service providers provide us with
Personal Data about you, such as the following: - Account
information for third party services: If you interact with a third party
service when using our Service, such as if you use a third party service
to log-in to our Service (e.g., Facebook Connect), or if you share content
from our Service through a third party social media service, the third
party service will send us information about you, such as information from
your public profile, if the third party service and your account settings
allow such sharing. The information we receive will depend on the policies
and your account settings with the third party service.
Information we
automatically collect when you use our Service: Some Personal Data is
automatically collected when you use our Service, such as the following:
- IP
address - Your
activity on the Service. This includes class usage information such as
class enrollment and which classes you’ve watched. It also includes
community interaction data, such as which members you’re following, your
comments, your projects, or project likes. - Device
identifiers - Web
browser information - Page
view statistics - Browsing
history - Transaction
information (e.g. transaction amount, date and time such transaction
occurred) - Cookies
and other tracking technologies (e.g. web beacons, pixel tags, SDKs,
etc.). For more information, please review the “Information About Cookies”
section above. - Location
information (e.g. IP address) - Log
data (e.g. access times, hardware and software information)
How Do We Use Your
Personal Data? We process Personal Data to operate, improve, understand and
personalize our Service. For example, we use Personal Data to:
- Create
and manage user accounts and profiles - Personalize
content on the Service. This includes showing users their saved classes
and class watch history, and providing class recommendations. - Provide
users and Teachers with community features - Provide
Teachers with student lists and pay Teachers appropriately - Communicate
with you about the Service - Contact
you with announcements, updates or offers regarding the Service - Process
orders - Provide
support and assistance for the Service - Analyze
and improve the Service - Meet
contract or legal obligations - Respond
and fulfill user inquiries and requests - Resolve
disputes - Protect
against or deter fraudulent, illegal or harmful actions - Enforce
our Terms of Service - Complete
corporate transactions (for more information, see our “Business Transfers”
section above)
We will only process your
Personal Data if we have a lawful basis for doing so. Lawful bases for
processing include consent, contractual necessity and our “legitimate
interests” or the legitimate interest of others, as further described below.
- Contractual
Necessity: We process the following categories of Personal Data as a
matter of “contractual necessity”, meaning that we need to process
the data to perform under our Terms of Service with you, which enables us
to provide you with the Service. When we process data due to contractual
necessity, failure to provide such Personal Data will result in your
inability to use some or all portions of the Service that require such
data. - First
and last name - Email
address - Password
- If
you are a Teacher, the content of your classes - Legitimate
Interest: We process at least the following categories of Personal Data
when we believe it furthers the legitimate interest of us or third
parties. - First
and last name - Email
address - Location
information - IP
address - Your
activity on the Service, including class usage information and community
interaction data - Examples
of these legitimate interests include: - Operation
and improvement of our business, products and services - Personalization
of web content on the Service - Analyzing
the use of the Service - Marketing
of our products and services - Provision
of customer support - Protection
from fraud or security threats - Compliance
with legal obligations - Completion
of corporate transactions - Consent:
In some cases, we process Personal Data based on the consent you expressly
grant to us at the time we collect such data. When we process Personal
Data based on your consent, it will be expressly indicated to you at the
point and time of collection. - Other
Processing Grounds: From time to time we may also need to process Personal
Data to comply with a legal obligation, if it is necessary to protect the
vital interests of you or other data subjects, or if it is necessary for a
task carried out in the public interest.
How and With Whom Do We
Share Your Data? We share Personal Data with vendors, third party service
providers and agents who work on our behalf and provide us with services
related to the purposes described in this Privacy Policy or our Terms of
Service. These parties include:
- Payment
processors - Fraud
prevention service providers - Third
party providers of advertising services - Ad
networks and marketing tools - Analytics
service providers - Engineering
and development tools - Staff
augmentation and contract personnel - Hosting
service providers
We also share Personal
Data when necessary to complete a transaction initiated or authorized by you or
provide you with a product or service you have requested. In addition to those
set forth above, these parties also include:
- Other
users (where you post information publicly or as otherwise necessary to
effect a transaction initiated or authorized by you through the Service),
such as when users and Teachers interact through the Service - Social
media services (if you interact with them through your use of the Service) - Third
party business partners who you access through the Service
We also share Personal
Data when we believe it is necessary to:
- Comply
with applicable law or respond to valid legal process, including from law
enforcement or other government agencies - Protect
us, our business or our users, for example to enforce our terms of
service, prevent spam or other unwanted communications and investigate or
protect against fraud - Maintain
the security of our products and services
We also share information
with third parties when you give us consent to do so. Furthermore, you
acknowledge that we may transfer your Personal Data, and that any acquirer of
us or our assets may continue to use your Personal Data, as set forth in
the “Business Transfers” section above.
How Long Do We Retain
Your Personal Data? We retain Personal Data about you for as long as you have
an open account with us or as otherwise necessary to provide you Service. In
some cases we retain Personal Data for longer, if doing so is necessary to
comply with our legal obligations, resolve disputes or collect, or is otherwise
permitted or required by applicable law, rule or regulation. Afterwards, we
retain some information in a depersonalized or aggregated form but not in a way
that would identify you personally.
What Security Measures Do
We Use? We seek to protect Personal Data using appropriate technical and
organizational measures based on the type of Personal Data and applicable
processing activity.
Personal Data of
Children: As noted above, we do not knowingly collect or solicit Personal Data
from anyone under the age of 16, unless you are a Student-based User (as
defined in this Privacy Policy) or student of another qualifying organization
or youth movement as determined by the Social Impact Initiative.
What Rights Do You Have
Regarding Your Personal Data? You have certain rights with respect to your
Personal Data, including those set forth below. For more information about
these rights, or to submit a request, please email support@wizdm.org. Please note
that in some circumstances, we may not be able to fully comply with your
request, such as if it is frivolous or extremely impractical, if it jeopardizes
the rights of others, or if it is not required by law, but in those
circumstances, we will still respond to notify you of such a decision. In some
cases, we may also need to you to provide us with additional information, which
may include Personal Data, if necessary to verify your identity and the nature
of your request.
- Access:
You can request more information about the Personal Data we hold about you
and request a copy of such Personal Data. You can also access certain of
your Personal Data by emailing support@wizdm.org. - Rectification:
If you believe that any Personal Data we are holding about you is
incorrect or incomplete, you can request that we correct or supplement
such data. You can also correct some of this information directly by
making changes to your Profile. You can request that we correct or
supplement such data by emailing support@wizdm.org. - Erasure:
You can request that we erase some or all of your Personal Data from our
systems by emailing support@wizdm.org. - Withdrawal
of Consent: If we are processing your Personal Data based on your consent
(as indicated at the time of collection of such data), you have the right
to withdraw your consent at any time. Please note, however, that if you
exercise this right, you may have to then provide express consent on a
case-by-case basis for the use or disclosure of certain of your Personal
Data, if such use or disclosure is necessary to enable you to utilize some
or all of our Service. - Portability:
You can ask for a copy of your Personal Data in a machine-readable format.
You can also request that we transmit the data to another controller where
technically feasible. - Objection:
You can contact us to let us know that you object to the further use or
disclosure of your Personal Data for certain purposes, such as for direct
marketing purposes. - Restriction
of Processing: You can ask us to restrict further processing of your
Personal Data. - Right
to File Complaint: You have the right to lodge a complaint about WIZDM.org’s
practices with respect to your Personal Data with the supervisory
authority of your country or EU Member State.
Transfers of Personal
Data: The Service is hosted and operated in the United States (“U.S.”) through WIZDM.org
and its service providers, and if you do not reside in the U.S., laws in the
U.S. may differ from the laws where you reside. By using the Service, you
acknowledge that any Personal Data about you, regardless of whether provided by
you or obtained from a third party, is being provided to WIZDM.org in the U.S.
and will be hosted on U.S. servers, and you authorize WIZDM.org to transfer,
store and process your information to and in the U.S., and possibly other
countries. You hereby consent to the transfer of your data to the U.S. as set
forth herein.
WIZDM.org is committed to
the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S.
Department of Commerce regarding the collection and use of Personal Data
transferred from the EU. These Principles are (1) notice, (2) consent, (3)
accountability for onward transfer, (4) security, (5) data integrity and
purpose limitation, (6) access and (7) recourse, enforcement, and liability
with respect to all Personal Data received from within the EU in reliance on the
Privacy Shield. The Privacy Shield Principles require that we remain
potentially liable if any third-party processing Personal Data on our behalf
fails to comply with these Privacy Shield Principles (except to the extent we
are not responsible for the event giving rise to any alleged damage). WIZDM.org’s
compliance with the Privacy Shield is subject to the investigatory and
enforcement powers of the U.S. Federal Trade Commission. For more information
about the Privacy Shield Program, please visit https://www.privacyshield.gov/.
Please contact us at support@wizdm.org with any questions or
concerns relating to the Privacy Shield. If you do not receive timely
acknowledgment of your Privacy Shield-related complaint from us, or if we have
not resolved your complaint, you may also resolve a Privacy Shield-related
complaint through JAMS, an alternative dispute resolution provider located in
the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for
more information or to file a complaint, at no cost to you. Under certain
conditions, you may also be entitled to invoke binding arbitration for
complaints not resolved by other means.
If you have any questions about this EU Privacy Notice or our data practices generally, please contact us using the following information:
Jewish Heritage Connections, Inc.
Email address for contact:
support@wizdm.org
Physical address:
525 Chestnut St
Cedarhurst NY 11516
The Privacy Policy, together with the Terms of Service, constitutes the entirety of agreements between you and WIZDM.org and supersedes all prior or contemporaneous agreements, representations, and understandings between you and WIZDM.org, whether written or oral. There are no representations, promises, warranties, covenants, or undertakings other than those contained on the Privacy Policy or the Terms of Service.