The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
Notice: Where YourCause collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which YourCause discloses that information, the choices and means, if any, YourCause offers individuals for limiting the use and disclosure of personal information about them, and how to contact YourCause. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to YourCause, or as soon as practicable thereafter, and in any event before YourCause uses or discloses the information for a purpose other than that for which it was originally collected.
Where YourCause receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
Choice: YourCause will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, YourCause will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
YourCause will provide individuals with reasonable mechanisms to exercise their choices.
Data Integrity: YourCause will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. YourCause will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Transfers to Agents: YourCause will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where YourCause has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, YourCause will take reasonable steps to prevent or stop the use or disclosure.
Access and Correction: Upon request, YourCause will grant individuals reasonable access to personal information that it holds about them. In addition, YourCause will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security: YourCause will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement: YourCause will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that YourCause determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to the YourCause Privacy Office at the address given below. YourCause will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between YourCause and the complainant, YourCause has agreed to participate in third-party dispute and mediation procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
For disputes involving all personal information received by YourCause from Switzerland, YourCause has agreed and to cooperate with the Swiss FDPIC;
For disputes involving employment-related personal information received by YourCause from the EEA, YourCause has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
For disputes involving all other personal information received by YourCause from the EEA, YourCause has agreed to eTrust dispute resolution. Individuals who submit a question or concern to YourCause and who do not receive acknowledgment from YourCause of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the eTrust Safe Harbor Dispute Resolution Program on the Internet or by mail. Inquiries by mail should identify YourCause as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether eTrust may share the details of the inquiry with YourCause. eTrust will act as a liaison to YourCause to resolve these disputes.
EU and Worldwide
26 York Street
616 Corporate Way
Suite 2 #4000
For information about eTrust or the operation of eTrust’s dispute resolution process, visit eTrust on the Internet (www.etrust.org) or request this information from eTrust by mail using the contact information listed above. The eTrust dispute resolution process shall be conducted in English.
Limitation on Application of Principles
Adherence by YourCause to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to the YourCause Privacy Office by mail to:
YourCause Privacy Office
2508 Highlander Way #210
Carrollton, Texas 75006
EFFECTIVE DATE: FEBRUARY 15, 2013
To view the full US-EU Safe Harbor List, please visit: https://safeharbor.export.gov/list.aspx
To view the full US-Swiss Safe Harbor List, please visit: https://safeharbor.export.gov/swisslist.aspx