Notice of Privacy Practices

Last updated June 21, 2024


This privacy notice for Headstrong Project (“Company,” “we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

  • Visit our website at theheadstrongproject.org, or any website of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you still have any questions or concerns, please contact us at hipaa-security@theheadstrongproject.org.

Your Health Data

 

We are required by law to maintain the privacy and security of your protected health information.  Click here to review and download our full HIPAA policy.

  • We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
  • We must follow the duties and privacy practices described in this notice and give you a copy of it.
  • We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Changes to the Terms of This Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.

Your Digital Data

 

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • contact preferences
  • billing addresses
  • debit/credit card numbers

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • health data

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Classy. You may find their privacy notice link(s) here: https://www.classy.org/terms/privacy/.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

 

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
  • To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

 

3. Do we share your information?

The Headstrong Project does not share your phone number or other personal information with third parties or affiliates outside of The Headstrong Project.

 

4. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

 

5. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@theheadstrongproject.org.

 

7. What are my privacy rights?

In Short:  You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at info@theheadstrongproject.org.

 

8. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

9. Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

 

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

 

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information YES
C. Protected classification characteristics under California or federal law Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details, and payment information YES
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
G. Geolocation data Device location YES
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO

 

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use your personal information?

The Headstrong Project does not share your phone number or other information with third parties or affiliates outside of The Headstrong Project.

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at info@theheadstrongproject.org, or by referring to the contact details at the bottom of this document.

 

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;

 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by email at info@theheadstrongproject.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

10. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

11. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@theheadstrongproject.org or by post to:

 

The Headstrong Project
4504 162nd Street, Suite #203
Flushing, NY 10018

 

Your Donor Data

 

Our Commitment to Privacy – Donor Privacy Policy

The Headstrong Project supports the protection of individual privacy, and is committed to ensuring the confidentiality of personally identifiable information provided by its donors. Your privacy is a priority, and we take critical steps necessary to protect your personally identifying information. In this section of our website, we provide more detail on how we use the personal information that we collect when you make a gift to The Headstrong Project.

 

Information Collected by the Headstrong Project

Personal Information is information that identifies you personally, such as your name, address, telephone number, email address, birthdate or other identifying characteristics. We collect and store personal information that you share with us or that is available from public sources. Below are examples of ways in which we may collect your information:

  • When you request information via one of the email addresses identified on our website, or otherwise contact us in person, by phone, or email, with an inquiry.
  • We may collect your name, email address, telephone number, and other contact information if you register for and/or attend an event.
  • We may collect information such as your name, email address, telephone number, and payment information when you make a contribution, either on our website, over the phone, by mailing in a check, or any other manner in which you might make a contribution.
  • Information you provide on our website donation portal.
  • Information you give us on Fund Agreements or other forms.
  • Information about your charitable gifts and grant transactions with us (such as your fund balance, grant history, and parties to transactions).
  • Responses to donor interest surveys.
  • Responses to donor demographic surveys.

The above list provides a sample of ways personal information may be collected by The Headstrong Project. From time to time, we may collect personal information from you in ways not described above. We restrict access to personal information to those employees who need to know that personal information to provide our services to you.

 

Use + Disclosure of Personal Information

The Headstrong Project respects and values the trust you place in us when you give us your personal information and is committed to maintaining the confidentiality of our donors’ personal information. It is our policy and practice to collect the least amount of personally identifiable information necessary to fulfill required duties and responsibilities, complete a particular transaction, deliver services, or as required by law. This applies to the collection of all personally identifiable information regardless of source or medium.

  • We will not trade, share or sell a donor’s personal information, collected on the website or through any business activities, with anyone else, except under the following circumstances. Donors can opt to be anonymous if they do not wish to have their information shared.
  • Contact information for donors is shared with the fundholder for stewardship purposes.
  • Information will be shared with governments, law enforcement or other legal entities as required by law.
  • Donors may opt in to share testimonials with The Headstrong Project, which may be featured on our website, social media, or in other publications.
  • Donor names may be featured in recognition lists with other donors at their associated giving level publications such as the website or annual report. Upon making a donation, the donor will be prompted to select their anonymity preference, thus determining their preference to be featured in such publications.
  • We will collect payment information, billing address, and other information necessary to process a donation or event registration.
  • We will use your information to comply with the law or in the good faith belief that such action is necessary to conform to the requirements of the law or comply with legal process served on us, protect and defend our rights, or act in urgent circumstances to protect the personal safety of others.
  • We will use your personal information to protect against potential fraud. We may verify with third parties the information collected in the course of processing a gift, event registration or other donation. If you use a credit card, we may use card authorization and fraud screening services to verify that your card information and address match the information that you supplied to us, and that the card being used has not been reported lost or stolen.

Except as described in this Donor Privacy Policy or at the time we request the information, we do not otherwise disclose your personal information to any third parties. The Headstrong Project may share personally identifiable information with other individuals or organizations that provide services to The Headstrong Project. We require these third parties to protect personally identifiable information it receives pursuant to this policy and applicable law. The Headstrong Project will take reasonable and appropriate measures to protect personally identifiable information from unauthorized access or disclosure.

As a donor submitting your personal information to The Headstrong Project, you consent to the terms and conditions of the policy and to our processing and use of personal information for the purposes stated below.

When you make a gift online, send in a donation via mail, give at an event or at another interaction, we may collect personal information such as name, email address, mailing address and telephone number and store it in our donor database.

 

Gift Processing + Credit Card Transactions

Credit card information is not stored permanently and is used only to process the transaction for which it is intended.

We will use your information to comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or act in urgent circumstances to protect the personal safety of others.

We may verify with third parties the information collected in the course of processing a gift, event registration or other donation. If you use a credit or debit card on our website, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us and that the card being used has not been reported lost or stolen.

Please note that this policy only covers information relating to you as a donor that we collect from you when you make a donation.

If you would like to update your personal information or your communication preferences, please contact us at info@theheadstrongproject.org.

Changes to the Privacy Policy

We reserve the right to change our Donor Privacy Policy at any time. When we do, we will update the effective date below.

Effective Date

The effective date of this Donor Privacy Policy is 11/01/2022.