Privacy – heroeshearts.org

Heroes’ Hearts International, Inc. (“Heroes’ Hearts”) respects your privacy and preferences. This privacy policy (the “Privacy Policy”) sets forth the terms under which you share your personal data with Heroes’ Hearts, what information Heroes’ Hearts processes, how Heroes’ Hearts collects and uses your data, and your rights with respect to understanding and modifying how it will be collected and used.

I. How does this Privacy Policy apply to you?

Generally: This Privacy Policy applies to the personal data provided to Heroes’ Hearts when you make a donation, register for an event, sign up for a newsletter, visit our Website, or otherwise provide us with information via the Heroes’ Hearts Website located at www.Heroes’ Hearts Store.org, or any other domain names owned or controlled by Heroes’ Hearts (the “Website”). It also applies to personally identifiable data (“Personal Information”) you may provide to Heroes’ Hearts via telephone, email, regular mail, social media, texting, mobile applications, at a special event, in response to a solicitation, or face-to-face.
Minors: Heroes’ Hearts will not knowingly solicit, collect, or otherwise process any Personal Information from children under the age of 16 without parental consent. Children under 16 are not authorized to make a donation or purchase, sign up for an event or program, or otherwise provide any personally identifiable information without consent from a parent or legal guardian.

II. Categories of Information We Collect

We collect Personal Information in three ways. First, we collect Personal Information that you provide to us. Second, we collect certain Automated Information that may contain Personal Information when you use our Website. Third, we may collect Personal Information from public sources or from third parties who have obtained such Personal Information in compliance with applicable laws and have the legal authority to provide such Personal Information to us.

Heroes’ Hearts will only collect Personal Information about you that is relevant to the type of transaction or project you have engaged in with us.

Contact information:

We may receive and retain Personal Information about you when you contact Heroes’ Hearts to make a donation; purchase an item at The Heroes’ Hearts Store Store online; apply for a position with Heroes’ Hearts; sign up for any of Heroes’ Hearts’s activities or online content (such as newsletters or message boards); or when you telephone, email, or write to us, or engage with us via social media channels. Data such as your name, email or postal address, telephone or mobile number are necessary both to execute these transactions as well as to enable us to contact you for further engagement. National ID/passport will be relevant if you are signing up for an international build.
Credit card and billing information: When you make a donation or purchase, in addition to your contact information, Heroes’ Hearts asks for your billing address and credit card or other financial services information. Heroes’ Hearts uses a third-party banking agent to process your payments via a secured socket layer connection (TLS 1.2 using SHA 256 encryption) to a secured server that verifies your credit card/bank information. The agent returns a unique tracking number only, which cannot be decrypted to obtain the payment card information, and Heroes’ Hearts never retains your complete credit card number. Only employees who need access to your Personal Information to perform a specific job are granted access to that information, and Heroes’ Hearts and our banking agent will not share your credit card/bank information with any other third party.

Sensitive Personal Data:

We do not collect your “Sensitive Personal Information” (e.g., mental or physical health or dietary information, racial or ethnic origin, religious beliefs, sexual orientation, citizenship or citizenship status). All Personal Information of a child will be treated as Sensitive Personal Information and collected and retained only with explicit consent of a parent or legal guardian. Should you support Heroes’ Hearts in a substantial way, we may provide an account manager to help tailor your relationship to us and the information you receive from us to suit your interests. If this is the case, we may collect demographic data where relevant to your relationship with Heroes’ Hearts. If you give us permission and provide us with Sensitive Personal Information, this may also be recorded so we can communicate with you in a considerate and appropriate manner.

All Sensitive Personal Information is stored on a password-protected system to which only a limited number of relevant staff have access. It is deleted when no longer needed by us, is never shared with third parties without your permission, and is available to you at any point should you wish to see it.

It is optional for you to engage in any event or activity; however, if you choose to do so, we may require that you provide certain Personal Information. Depending upon the activity, some of the information we ask you to provide is required and some is voluntary. If you do not provide required information for a particular event or activity, you may not be permitted to engage in that event or activity.

Automated Information:

We also collect information, some of which may be Personal Information, through automated means when you visit our Website (“Automated Information”) such as:

• the IP address of the device you use to connect to the internet (which may include information about your geographic location)
• the unique identifiers of your device
• your browser characteristics
• your device characteristics
• your operating system
• your language preferences
• the websites you visited before coming to our Website or through which you were referred to our Website
• information on actions taken by you on our Website
• dates and times of your visits to our Website
• the pages you accessed on our Website

Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Website unavailable or difficult to view or use.

Information We Obtain from Third Parties:

We may obtain Personal Information from third parties in a number of ways:

We may obtain Personal Information from third parties for marketing and business purposes. If we obtain Personal Information from third parties for any of these purposes, we will require that any third parties from whom we may obtain such Personal Information represent to us that they have acquired the Personal Information in compliance with all applicable laws and have the right to provide us such Personal Information for our marketing purposes.

We may collect Personal Information from publicly available sources.

III. How will Heroes’ Hearts use your personal data?

Heroes’ Hearts will use your Personal Information for the following purposes:

a. For administrative reasons, including:
• “service administration,” which means that Heroes’ Hearts may contact you for reasons related to administering any donations you have made, the completion of commercial or other transactions you have entered into with us, or the activity or online content you have signed up for;
• to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used;
• in relation to correspondence with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
• for internal record keeping so as to document your relationship history with us;
• to complete sales transactions you have entered into with us, for example at The Heroes’ Hearts Store Store;
• to implement any instructions you give us with regard to withdrawing consent to send marketing information;
• to use IP addresses to identify the location of users, to block disruptive use, and to establish the number of visits from different countries.
b. For marketing and fundraising
Sections III and IV describe what data may be used for marketing and fundraising purposes and under what circumstances.
c. Analysis
To analyze and improve the activities and content offered by the Heroes’ Hearts Website to provide you with the most user-friendly navigation experience. We may also use and disclose Personal Information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

IV. Why do we hold and process personal data?

Heroes’ Hearts may request from you, or you may volunteer to provide, your contact information, including your name, mailing address, phone number(s), social media handles and email address(es), and payment information. We hold and process supporters’ Personal Information for a number of reasons:
• to keep a record of donations made and actions taken by our supporters and our communications with them;
• to send supporters marketing information about our projects, fundraising activities and appeals where we have their consent or are otherwise permitted to do so;
• to fulfill contractual obligations entered into with supporters;
• to support volunteers, such as during builds or fundraising events;
• to support community-based fundraising and campaigning;
• to ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted;
• to manage supporters’ accounts and provide customer service;
• to offer contests, giveaways, or other promotions;
• to enforce the Website terms of service; and/or
• to perform other functions as described at the time Heroes’ Hearts collects information.

Targeted Fundraising for U.S. and Canadian Residents.

We may use certain Personal Information (name, address, telephone number or e-mail information, etc.) to contact you for the purpose of raising money for Heroes’ Hearts, but any such communication will provide you with the opportunity to opt-out of receiving such future communications. If you do not elect to opt-out, we may exchange or rent your information with other organizations. If you re-engage with Heroes’ Hearts without indicating your intent to opt-out, we will re-subscribe your email to ensure that you do not miss Heroes’ Hearts updates. You are free to opt-out of fundraising solicitations and your decision will have no impact on your ability to receive services from Heroes’ Hearts or to volunteer with us.

If you did not opt-out from receiving fundraising communications, we may also analyze your Personal Information to create a record of your interests and preferences. This allows us to ensure communications are relevant and timely, to contact you in the most appropriate and relevant way and in general to provide you with an improved user experience. It also helps us to understand the background of our supporters so that we can make appropriate requests for support, enabling us to raise funds and partner with families sooner and more cost-effectively.

If you did not opt-out from receiving fundraising communications, Heroes’ Hearts may also share data from its U.S. and Canadian resident supporters with select third-party sponsors and service providers based on our assessment that the products or services may be of interest to these supporters or that the sponsor or provider can help Heroes’ Hearts identify what services or appeals may be of interest to our supporters. We may also provide our U.S. and Canadian resident supporters with information about services from third parties. If you do not wish for your data to be used in this way, you may follow the instructions for modifying your consent (see below Section IX, “How to control what we send you or update your Personal Information”).

V. When will we send you personalized marketing communications?

Heroes’ Hearts will contact you for marketing purposes—for example, to keep you up to date on our work, or let you know how you can support that work—only where we have your consent or we are otherwise allowed to do so because of your prior engagement with Heroes’ Hearts.

We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information. We will not send you marketing material if you tell us that you do not wish to receive it. Instructions for how to do so are below (see Section IX below “How to control what we send you or update your Personal Information”).

VI. How and when do we obtain information about you?

In addition to the means otherwise described in this Privacy Policy, including with respect to the information we collect, Heroes’ Hearts may obtain your personal data in the following circumstances:

a. When you give it to a Heroes’ Hearts Affiliate or Heroes’ Hearts Store National Organization
We may obtain your Personal Information indirectly when you sign up for an event sponsored by a Heroes’ Hearts Affiliate or National Organization, such as a Global Village trip. In such cases, the Heroes’ Hearts Store National Organization will share your data with Heroes’ Hearts to enable us to contact you about your volunteer event or about future Heroes’ Hearts programs and support opportunities. It may also be shared if it is a necessary part of completing a contract or other legal obligations to you in connection with your participation in an event.
Each local Heroes’ Hearts Store organization in the United States and Canada (a “Heroes’ Hearts Affiliate” or “Affiliate”) is a separate legal entity, governed by an independent board of directors, executive committee, or other governing body. Each Affiliate is solely responsible for its own collection and use of your personal data. Collection and processing of your Personal Information by those organizations is governed by their privacy policies and may in some instances be shared with Heroes’ Hearts.

Most country-level Heroes’ Hearts Store organizations outside the United States (“Heroes’ Hearts Store National Organization” or “National Organization”) are legally independent of Heroes’ Hearts, governed by their own boards of directors who are responsible for the collection and use of Personal Information that you may provide. Collection and processing of your Personal Information by those organizations is governed by their privacy policies and may in some instances be shared with Heroes’ Hearts provided that you have given your consent.

b. When you give it to Heroes’ Hearts indirectly
We will obtain your Personal Information when you communicate to your employer or to a retail partner of Heroes’ Hearts during your point of purchase that you affirmatively designate Heroes’ Hearts to receive a personal contribution from you.
Sometimes your Personal Information is collected by an organization working on Heroes’ Hearts’s behalf (for example, a professional fundraising agency). In such cases, the agency is acting on our behalf, and we are the “data controller” responsible for the security and proper processing of your data, just as if you had given it to Heroes’ Hearts directly.

c. When you access Heroes’ Hearts’s Website or sponsored social media
We might also obtain your Personal Information through your visit to our Website or your use of social media such as Instagram, Facebook, WhatsApp, Twitter, or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
http://privacycenter.instagram.com/policy https://www.facebook.com/policy.php https://twitter.com/en/privacy https://www.whatsapp.com/legal/#privacy-policy https://www.linkedin.com/legal/privacy-policy

d. When the information is publicly available
We might also obtain Personal Information about individuals who may be interested in giving major gifts to organizations like Heroes’ Hearts. In these cases, we may seek to find out more about these individuals’ interests and motivations for giving through publicly available information. The information sources may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and services that aggregate data on charitable giving. If you are a resident of the European Economic Area and your country has adopted the provisions of the GDPR, Heroes’ Hearts will not retain your Personal Information collected from public sources without your consent, which we will seek at the earliest practicable opportunity.

e. When and why we use cookies
Cookies are a useful way for us to understand how supporters use Heroes’ Hearts’s Website. When you visit our Website, we will use cookies to collect data from your computer or other device, such as a smart phone or tablet. Cookies are created by your web browser when you visit our Website. Every time you return to our Website, your browser will send the cookie file back to the Website’s server. Cookies improve your experience of using our Website by, for example, preserving your preference settings so that you are shown information likely to be most relevant to you, and measuring your use of the Website so that we may continuously improve it. Cookies can also be used to show you relevant Heroes’ Hearts content on social media services.

The Heroes’ Hearts Website may contain hyperlinks to websites owned and operated by other organizations, including private sector partners, other NGOs and charities, and Heroes’ Hearts Affiliates and Heroes’ Hearts Store National Organizations. These third-party websites have their own privacy policies, including policies on the use of cookies, which would apply to the use of Personal Information you submit, or which is collected by cookies while visiting those websites. Heroes’ Hearts cannot accept responsibility for the privacy practices of such third-party websites, and we recommend therefore that you familiarize yourself with their policies.

Other ways we use cookies to enable us to improve our services:
• remembering if you are logged in so you can move around the Website without having to log in again on each page (for example if you are in checkout);
• measuring how many people are using each page of the Website and for how long so that we can try to improve the quality of our Website;
• enabling you to view content shared on social media or sharing sites, such as YouTube or Twitter.

If you reside in the United States or Canada, cookies may also be used for “re-targeting” in advertising campaigns so that third-party vendors can display advertising to you about Heroes’ Hearts or other related entities as you use the internet.

How to manage and delete cookies. If you wish to restrict or block the cookies set by the Heroes’ Hearts Website, you can do this through your computer or device’s browser settings. The Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.

Please be aware that restricting cookies may affect the functionality of the Heroes’ Hearts Website.
If you visit our Website as an anonymous visitor (e.g., you switch off cookies), Heroes’ Hearts may still collect certain information from your browser, such as the IP address (which uniquely identifies a computer or other internet device).

VII. How we share your information inside and outside the Heroes’ Hearts Store Network

If you reside in the U.S. or Canada, and unless you instruct us otherwise by opting out, Heroes’ Hearts may share your personal data with organizations with which Heroes’ Hearts partners, as well as other companies whose products and services may be of interest to you. In these cases, we may also provide you with information about services from third parties, unless you inform us that you do not want to receive this information.

Sharing of information within the Heroes’ Hearts Store network: We may share your Personal Information with a Heroes’ Hearts Store National Organization, such as in connection with your participation in a Global Village build, or to enable a National Organization where you have expressed interest to update you about its own programs and campaigns or with local Heroes’ Hearts Affiliates. Before we will share your Personal Information, Heroes’ Hearts requires that the Heroes’ Hearts Store National Organization or local Heroes’ Hearts Affiliates receiving the data (the “Receiving Organization”) maintain security controls that will assure that your data is securely stored and accessible only by appropriately trained personnel. Unless you inform us that you do not consent, Receiving Organizations may in the future contact you about their own programs and activities.

Likewise, when you provide Personal Information to a National Organization in connection with your participation in a Global Village build or other international volunteer event that Heroes’ Hearts sponsors or with a local Heroes’ Hearts Affiliate, your personal data may be shared between (i) the Receiving Organization and any other Heroes’ Hearts Store National Organization that hosts the volunteer build (the “Hosting Organization”) or the local Heroes’ Hearts Affiliate, and (ii) the Receiving Organization and Heroes’ Hearts. Unless you inform Heroes’ Hearts or the Receiving Organization that you do not consent to marketing by the Hosting Organization or the local Heroes’ Hearts Affiliate, the Hosting Organization or the local Heroes’ Hearts Affiliate may also contact you about its own programs and activities in the future.

Heroes’ Hearts’s service providers and business partners: We may need to share your information with service providers, data brokers, third-party advertisers, payment processors, and/or government agencies who help deliver our mission, services, objectives, and fundraising activities. Heroes’ Hearts may rent, sell, or exchange names, postal addresses, telephone numbers and donation history to other organizations.

Facebook and other Social Media Sites: We may also use your email address and phone number to match to your Facebook or other social media account(s) in order to show you Heroes’ Hearts content while you use those services. We only do this where you have consented to receiving marketing emails, either by opting in (where you reside in the European Economic Area) or by not opting out (where you reside in the United States and Canada). In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Heroes’ Hearts.

Updating your preferences with Heroes’ Hearts will not guarantee that you will never see Heroes’ Hearts content on social media, since the social media site may select you based on other criteria.

Where legally required: We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing).

VIII. How long will Heroes’ Hearts keep your Personal Information?

We will hold your Personal Information on our contact lists only for as long as you continue to provide your consent. If you are a U.S. or Canadian resident, your ongoing consent is presumed unless you inform us that you wish to be removed from our contact list. (Instructions for doing this are set forth below in Section IX.) If you are not a U.S. or Canadian resident, your consent will be presumed to expire after 24 months, unless renewed consent is provided by you. Beyond that, we will hold your information only for as long as necessary to comply with our legal and regulatory obligations—such as, for example, to provide documentation on funding sources in connection with a review or audit of our compliance with U.S.C. Sec. 501(c)(3).

If you request that we stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Legacy income is vital to the running of Heroes’ Hearts. We may keep data (including Personal Information) you provide to us indefinitely to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyze the source of legacy income we receive.

IX. How to control what we send you, update your Personal Information, opt out of communications, delete your Personal Information from our records, request a copy of your Personal Information, or appeal a decision on how we handle your personal data

In certain countries and in certain states, you have specific rights regarding your Personal Information. This section describes your rights and explains how to exercise those rights.
Your data privacy rights

• Right to opt-out of sharing personal data-you are able to elect to direct us not to use your Personal Information. We share Personal Information (including name, contact information and donation history) in the context of cooperatives managed by third-party vendors such as data brokers. The Personal Information provided is used by the third-party vendors to create a score or profile which may then be used to send solicitations on behalf of other organizations. These organizations will not have direct or continued access to your Personal Information unless you choose to provide it to them directly by responding to an appeal. We do not share health-related data in connection with these efforts.
• Right to access-you can request and receive all Personal Information in a form that is concise, transparent, and easily intelligible and in an appropriate, commonly used electronic format, depending on the nature of the data. The right to access Personal Information may be limited by local law.
• Right to correction-you have the right to correct inaccuracies in your Personal Information.
• Right to deletion-you have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Please note that in cases of deletion, limited Personal Information will remain to document the request. The right to access Personal Information may be limited by local law.
• Right to portability-you have the right to request that your data be transferred to another entity in a format that we can transmit securely
• Right of appeal-if you exercise one of your privacy rights and we are unable to process your request, we will endeavor to provide you with an explanation as to why the request was denied. The explanation will include information on how to appeal, including the relevant regulatory authorities, based on your state or country of residence. All requests for appeal will be reviewed by Heroes’ Hearts’s General Counsel in consultation with Heroes’ Hearts privacy and risk professionals.

You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from Heroes’ Hearts.

For your protection, we will use commercially reasonable efforts to verify your identity when you are exercising your right to have personal data corrected or deleted or to receive a copy of your personal data before implementing your request. If you are submitting a request on behalf of someone else, we may ask for additional verification, such as written documentation or other proof of authority. We will try to comply with your request as soon as reasonably practicable, consistent with applicable law.

For California Residents. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make a request, please contact us by any method detailed above. We will respond to your request consistent with applicable law.

Timing of implementation. In responding to requests not to receive marketing information, we will take all reasonable steps to remove you from all Heroes’ Hearts marketing lists. If you are a resident of the European Economic Area and your country has adopted the provisions of the GDPR, we are committed to meeting the following service levels:
• Email: 48 hours from receipt of email
• SMS: 48 hours from receipt of SMS
• Mail: six to eight weeks from receipt of ‘do not mail’ request.

This period is longer than for other channels due to the production times for mailing or telephone campaigns.
If you have already been selected for inclusion in a Heroes’ Hearts marketing campaign at the time you requested to not receive such information, we may be unable to remove you from that campaign within these time periods.
If you are a resident of the European Economic Area and your country has adopted the provisions of the GDPR, you have the right to request a copy of the Personal Information we hold about you, to have any inaccuracies corrected, and to have any Personal Information deleted from our systems (a “Subject Access Request” or “SAR”). In line with standard guidelines for these requests, we will require you to prove your identity with two pieces of approved identification. We will respond to such requests within 30 days of receipt.

X. How Heroes’ Hearts keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details and keep them secure. For example, our online forms that ask for Personal Information are stored on networks that are password-protected and routinely monitored. Laptops are not used to store sensitive Personal Information unless they are both password-protected and encrypted. All Sensitive Personal Information is stored on a secure database, to which only a limited number of relevant personnel have access. It is deleted when no longer needed by us and is never shared with third parties, except as expressly set forth in Sections III and IV.

Within Heroes’ Hearts, we undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers, and contractors. Where we share your personal data with a Heroes’ Hearts Store National Organization or Affiliate, the National Organization or Affiliate is required to take comparable steps to assure that your information is securely stored and accessed only by appropriately trained personnel.

We use external companies to collect or process Personal Information on our behalf. We do comprehensive checks on these companies before we work with them, and in our legal agreements, we clearly set out our requirements regarding how they manage the Personal Information to which they have access. We have a robust partner-monitoring framework to ensure these contractual obligations are met.

XI. Changes to Heroes’ Hearts’s Privacy Policy

This Privacy Policy was last updated as of the date written above. It may be updated from time to time, so you may wish to check it each time you submit Personal Information to Heroes’ Hearts. If you do not agree to these changes in this update, please review the instructions in Section IX to update your preferences and discontinue use of the Website . If material changes are made to the Privacy Policy, we will notify you by placing a prominent notice on the Website.