ITDP Policy for Protecting Your Online Privacy
This privacy policy applies only to itdp.org (the “Site”), which is operated by the Institute for Transportation & Development Policy and/or its affiliated entities (“ITDP,” “we” or “us”). This privacy policy does not pertain to information that is collected offline. BY USING THE SITE, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITE.
A. Information Collected
This privacy policy applies only to information collected on the Site and does not apply to information collected by ITDP through any other means.
We collect two types of information from visitors to the Site: (1) Personally Identifiable Information (“PII”) and (2) Non-Personally Identifiable Information (“Non-PII”), such as your IP address or cookies.
(1) Personally Identifiable Information
“Personally Identifiable Information” is information that identifies you personally, such as your name, address, telephone number, or email address. ITDP collects and stores the PII that you have provided to us. Here are some examples of manners in which we may collect your personally identifiable information on the Site:
- We may collect your first and last name and email address if you subscribe to receive our news bulletin;
- We may collect your email address if you contact us with a question;
- We may collect your first and last name, employer name, address, credit card and billing information when you make a donation; and
- We may collect your first and last name, date of birth and email address if you choose to participate in a contest or sweepstakes.
The above list provides an example of the PII that may be collected on the Site. If you do not want ITDP to collect your PII, please do not provide it to us.
(2) Non-Personally Identifiable Information
“Non-Personally Identifiable Information” can be technical information or it can be demographic information, such as your age, gender or interests. Non-PII does NOT identify you personally. Here are some examples of the Non-PII that is collected via the Site and a description of how this information is used:
- Internet Protocol (IP) address — Your IP address is a number that lets computers attached to the Internet know where to send your data — such as the web pages you view. We use this information to deliver our web pages to you upon request, to tailor our Site to the interests of our users and to measure traffic within our Site.
- Cookies — A “cookie” is a small text file that may be used to collect information about your activity on the Site. For example, when someone visits a page within the Site, a cookie is placed on the user’s machine (if the user accepts cookies) or is read if the user has visited the Site previously. Cookies may also be used to track users across the Web. We use the information we collect from cookies for marketing and informational purposes. Collected data may also be shared, in aggregate form, with third-parties. We do not currently honor any “do-not-track” signal sent by browsers. However, you may opt-out of targeted advertising by visiting networkadvertising.org/choices. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Site.
- Google Analytics –- The Site uses Google Analytics to help analyze how users use our Site. The tool uses cookies to generate information about your use of the Site (including IP address, operating system, browser type, language, and referring website) and to transmit that information to Google. This information is then used to evaluate visitors’ use of the Site and to compile statistical reports on Site activity for ITDP. ITDP uses these reports to monitor online engagement and improve our Site.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any PII of visitors to our Site (such as a name, email address or billing information) without first notifying you. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any PII from any source, unless you explicitly submit that information via a fill-in form on our website. Site visitors that don’t want their visit data reported by Google Analytics can install the Google Analytics opt-out browser add-on. If you want to opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser. The Google Analytics opt-out browser add-on does not prevent data from being sent to the Site itself or in other ways to web analytics services.
- Web Beacons (also known as “clear gifs,” “web bugs” or “pixel tags”) — “Web Beacons” are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages of the Site and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages.
- Demographic Information — “Demographic Information” may be your gender, age, zip code and interests, which you voluntarily provide to us on the Site. We use this information to provide you with personalized services and to analyze trends to ensure the information provided by the Site meets your needs.
Please note that we also consider aggregated information, which is not personally identifiable, to be Non-PII. The above list provides an example of the Non-PII that is collected via the Site.
B. Use of Information Collected Via the Site
(1) Personally Identifiable Information
We use your PII that is collected on the Site primarily for the following purposes:
- To deliver services, such as educational programs, newsletters or other information that you request;
- To alert you to important information regarding our mission and our policies, including relevant information distributed by ITDPor to forward promotional materials;
- To complete a transaction or service requested by you;
- To fulfill the terms of a promotion;
- To ensure the Site is relevant to your needs;
- To help us create and publish content most relevant to you;
- To match your donation with your employer’s donation;
- To notify you about a material change to this privacy policy, if necessary;
- To allow you access to limited-entry areas of the Site; and
- To contact you in response to your requests or when you contact us.
(2) Non-Personally Identifiable Information
Non-PII is used as described in Section A (2) above and in other ways as permitted by applicable laws, including combining Non-PII with PII.
C. Sharing and Disclosure of Information
(1) Personally Identifiable Information
Except as described in this privacy policy or at the time we request the information, we do not otherwise use, share, or otherwise disclose your PII to any third parties.
Necessary exceptions include:
(i) To fulfill a service to you. For example, if you subscribe to receive information from us or order materials from us, we may share your PII in order to provide the information and materials to you. In addition, if you email us a question, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your PII in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion.
(iii) To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Site and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). For example, if you want to find out if your employer matches donations, we may use a third party to compile and access that information and to help us to maintain our records. We seek to ensure that these unaffiliated third parties will not use the PII for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Site will have access to users’ PII, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any PII to us.
(iv) To complete your transaction. If you choose to make a purchase or donation on the Site, we may collect from you your credit card number, billing address and other information related to such transaction, and we may use such collected information in order to complete your transaction. We may also provide such information, or other PII provided by you, to unaffiliated third parties as necessary to complete your transaction (for example, to process your credit card).
(v) To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of ITDP or act in urgent circumstances to protect the personal safety of our end users.
(vii) To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
(viii) To protect against potential fraud, we may verify with third parties the information collected from the Site. In the course of such verification, we may receive PII about you from such services. In particular, if you use a credit card or debit card to purchase services with us, 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 has not been reported as lost or stolen.
(2) Non-Personally Identifiable Information
We use Non-PII collected on the Site in the manner disclosed above, in Section A (2). We may share this Non-PII with third parties.
D. Collection and Use of Information from Children under the Age of 13
The Site does not knowingly target children under the age of 13 and we do not collect PII from any child under the age of 13. In the event we learn that such information has been provided to the Site, we will delete or destroy it.
E. International Transfer of Information
If you choose to provide us with PII, ITDP may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your PII to the United States which does not have the same data protection laws as the EU and by providing your PII you consent to:
- the use of your PII for the uses identified above in accordance with this privacy policy; and
- the transfer of your PII to the United States as indicated above.
F. Forums, Chat Rooms and Other Public Posting Areas
Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don’t want people to know your e-mail address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
G. Third Party Web Sites
This privacy policy applies solely to information collected on the Site. The Site may contain links to other web sites. We are not responsible for the privacy practices or the content of these other web sites.
H. Accessing Your Personally Identifiable Information and Privacy Preferences
We provide you with an opportunity to access your PII to ensure it is correct, accurate and current. To edit your PII, please send a request to mobility@itdp.org. We will make reasonable efforts to accommodate your request.
I. Assignment
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the PII and Non-PII collected via the Site.
J. Changes to this Privacy Policy
We reserve the right to change this privacy policy from time to time. When we do, we will also revise the “last update” date at the bottom of this privacy policy. For changes to this privacy policy that may be materially less restrictive on our use or disclosure of PII you have provided to us, we will attempt to obtain your consent before implementing the change by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Site.
K. Security
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to ITDP is done at your own risk.
Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing PII to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice on our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
L. Contacting Us
If you have any questions about this privacy policy or our privacy practices, please contact us at mobility@itdp.org. All information you provide in any written communication will also be covered by this policy.
M. Your California Privacy Rights
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us:
ITDP Headquarters
9 East 19th Street, 7th Floor
New York, NY 10003 USA
mobility@itdp.org
Effective Date: 2013-12-19
Last Updated: 2015-3-24