For purposes of this policy, “Site” refers to our organization’s website, which can be accessed at www.eastbaymeditation.org
I. Information We Collect
We collect two general categories of information: “Non-personal Information” and “Personal Information”. Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs. Personal Information is information you give to us when choosing to be on our email lists or support us through donations. This information includes but is not limited to your Email address, First name and last name, Phone number, Address, State, Province, ZIP/Postal code, City, Cookies and Usage Data which you submit to us through the Site.
When opting to donate for events online, we may require you to provide to a third party payment processor, certain financial information like your bank account or credit card information in order to facilitate the processing of payments. All financial information will be collected directly by third party payment processors according to their privacy policies.
1.1 Information We Automatically Collect from Your Use of the Site.
When you use the Site, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary given our interest in being able to provide and improve the functionalities of the Site.
Usage Information. We collect information about your interactions with the Site such as the pages or content you view, your searches for Products or Services, donation requests you have made, and other actions on the Site.
Log Data and Device Information. We automatically collect log data and device information when you access and use the Site. That information includes, among other things: details about how you’ve used the Site (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Site.
II. How we use Information
We use, store, and process information, including personal information, about you to provide and improve the Site and comply with our legal obligations.
Enable you to access and use the Site.
Operate, protect, improve, and optimize the Site and experience, such as by performing analytics and conducting research.
Provide customer service.
Send you service or support messages, updates, security alerts, and account notifications.
Send you promotional messages and other information that may be of interest to you based on your preferences (including information about EBMC or donor offers)
We process this information given our legitimate interest in improving the Site and our users’ and customers’ experience with it, and where it is necessary for the performance of the contract with you and/or a legal obligation.
2.1 Comply With Our Legal Obligations.
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Verify or authenticate information provided by you (such as to verify your authorization to act as an agent on behalf of a nonprofit organization).
Conduct checks against databases and other information sources, to the extent permitted by applicable laws.
Resolve any disputes with any of our users or customers and enforce our agreements with third parties.
We process this information given our legitimate interest and legal obligation to protect the Site, to measure the adequate performance of our contract with you, and to comply with applicable laws. EBMC may process your information if it is necessary for legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site.
III. Sharing and Disclosure
Processing is lawful only if and to the extent one of the following applies:
3.1 With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent. If you participate in promotional activities conducted by EBMC partners or third parties we may also share information if you have provided us with prior consent to do so.
3.2 Other Situations.
3.2.1. Profiles and other Public Information.
The Site lets you publish information, including personal information, that is visible to the general public. For example, if you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Site, that content is publicly visible. Information you share publicly on the Site may be indexed through third party search engines. If you change your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.2.2. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
EBMC may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against EBMC, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with our users and customers, or (v) to protect the rights, property or personal safety of EBMC, its employees, its users, customers or members of the public.
Where appropriate, we may notify users and customers about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon EBMC’s property, its users and customers and the Site. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user or customer about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.2.3 Third Party Companies.
EBMC Meditation Center enters into contracts with third parties to provide certain donations to EBMC users, customers, or companies that offer their products and/or services on the Site (“Third Party Companies”). EBMC will share your account information with Third Party Companies when you request donations or purchase products and/or services from such Third Party Companies. EBMC will need to share your account information, including your personal information, to implement a contract between you and the Third Party Company. Your account information will be processed according to the privacy policies of such Third Party Companies. We will provide you with these policies as reasonably appropriate.
3.2.4 Service Providers.
EBMC uses a variety of third parties to help us provide services related to the Site. Service providers may be located inside or outside of the European Economic Area (“EEA”). The EEA unites the EU Member States and the three EEA EFTA States (Iceland, Liechtenstein, and Norway) into a market governed by the same basic rules (such as GDPR & CCPA).
If EBMC needs to share your information, including personal information, with a service provider, in order to ensure the adequate performance of our contract with you, we are permitted to do so.
3.2.5 Business Transfers.
3.2.7 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, insights about the sector, demographic profiling, marketing and advertising, and other business purposes. We may share this aggregated data with the public.
IV. Third Party Partners and Integrations
The Site may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). EBMC doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, EBMC, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
V. Your Rights
You may exercise any of the rights described in this section by sending an email to email@example.com. Please note that we may ask you to verify your identity before taking further action on your request.
5.1 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your EBMC Account).
5.2 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
5.3 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Site to you, you can request that we erase your personal information and close your EBMC Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an EBMC Account for fraud or safety reasons, we may retain certain information from that EBMC Account to prevent that user or customer from opening a new EBMC Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, EBMC may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., forum postings) may continue to be publicly visible on the Site, even after your EBMC Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Site to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
5.4 Withdrawing Consent and Restriction of Processing.
Where you have expressly provided your consent to the processing of your personal information by EBMC you may withdraw your consent at any time by changing your Account settings or by sending a communication to EBMC specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 5.6 and pending the verification whether the legitimate grounds of EBMC override your own.
5.5 Objection to Processing.
In some jurisdictions, applicable law may permit you to legally object to EBMC’s processing. In these instances, you may require EBMC not to process your personal information for specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing EBMC will no longer process your personal information for these purposes unless we can demonstrate a legal basis for doing so or such processing is required for the establishment, exercise or defense of legal claims.
At any time, regardless of applicable law, you may object to us processing your personal information for direct marketing purposes. You may, at any time, ask EBMC to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org
5.6 Lodging Complaints.
VI. Operating EBMC
6.1 EU Model Clauses.
If your information is shared with corporate affiliates or third party companies or service providers outside the EEA, we have, prior to sharing your information with such corporate affiliate or third party company or service provider, established the necessary means to ensure an adequate level of data protection. This agreement may incorporate the basis of the EU Model Clauses (a set of clauses issued by the European Commission).
6.2 California Privacy Rights.
California law permits users and customers who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. EBMC does not share personal information with third parties for its own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for direct marketing purposes by withholding consent.
6.3 Children’s Privacy
The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks. If you know or have reason to believe that your EBMC Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your EBMC Account, please contact us following the instructions in the Contact Us section below.
IX. Contact Us