Date Last Revised: November 2021
This Policy describes:
- The types of information we collect from you or that you may provide when you visit our website, or receive services therefrom available at: www.sholom.com as well as any websites, web services, related sites, and blogs owned by or under the control of Sholom linked to the foregoing web address (collectively, our “Website”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Please check the Policy periodically for updates. Your continued use of our Website after we make changes is deemed to be acceptance of those changes.
What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.
Information You Provide to Us
Personal Information is any information that can be used to individually identify you from a larger group, such as data including, but not limited to, your:
- first and last name
- email address
- telephone number
- mailing address
- or other information
You may provide us with Personal Information in various manners, such as through requests for information, submitting an application or request for services, by subscribing to a service, creating an account, sending us an email, or in other manners where you interact with the Website. The information that you provide in each case will vary.
Automated Information Collection
In addition to the information that you provide to us, we may also collect information about you during your visit to or use of our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive.
(a) Cookies are usually defined in one of two ways, and we may use both of them:
(1) session cookies, which do not stay on your device after you close your browser, and
(2) persistent cookies, which remain on your device until you delete them or they expire.
We use the following categories of cookies on our Website:
- Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.
- Performance Cookies. These cookies collect anonymous information on how people use our Website to help us understand how you arrive at our site, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
- Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
- Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks, which may remember the websites you visit and share that information with other parties/advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.
(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
(e) Third-party Websites and Services. We may work with a third-party service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. We do not control the practices of such third-party services providers, but we may be able to provide your information about such practices upon request.
Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested, or information about our services. In general, we will allow you to make choices about what information we provide you, and that you provide us at the point of information collection or at any time after you have received a communication from us while you are subscribed to our services. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
If we provide you with information about our services, or in response to your request for information, you will have the option to stop receiving such information (provided we can still fulfill your request for services). You may opt out of messages at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
- To discontinue receiving SMS messages from the Sholom at any time, reply STOP or text STOP to ________ or call ________. For help, reply HELP or text HELP to ________ or call ________.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security – and we may require additional authentication in order to protect your privacy. It is your responsibility to keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
Information of Minors
We do not intentionally seek to gather information from individuals under the age of eighteen. We do not target the Website to minors, and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.
How We Use Your Information
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:
- Preventing malicious activity and providing you with a secure experience.
- Providing service and support for services you request.
- Providing marketing communications that are effective and optimized for you.
- Keeping you up-to-date with the latest benefits available from us.
- Preventing unwanted messages or content.
- Measuring the performance of our marketing programs.
- Contacting you about services and offers that are relevant to you.
How We Share Your Information
We do not sell or lease your information to any third party. We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy, or as necessary to provide you with the services you have requested. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us. We will share your Personal Information with these third parties in order to fulfill the service that they provide to us. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:
- Responding to duly authorized information requests from law enforcement or other governmental authorities.
- Complying with any law, regulations, subpoena, or court order.
- Investigating and helping prevent security threats, fraud, or other malicious activity.
- Enforcing or protecting the rights and properties of Sholom or its subsidiaries.
- Protecting the rights or personal safety of Sholom’s employees.
There are circumstances where Sholom may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to transfer or share Personal Information with prospective or actual partners or affiliates. In such circumstances, Sholom will ensure your information is used in accordance with this Policy.
Your California Rights (for California Residents Only)
Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
If you are a California consumer, as defined by the California Consumer Privacy Act of 2018, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under California law. Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.
- Access. You may email us at firstname.lastname@example.org to request a copy of the Personal Information our Website databases currently contain, subject to verification of identity.
- Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information by submitting a request via email to email@example.com. In your email, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
- Portability. Upon request and when possible, we can provide you with copies of your Personal Information. You may submit a request via email to firstname.lastname@example.org. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
- Deletion. If you should wish to cease use of our Website and have your Personal Information deleted from our Website, then you may submit a request by emailing us at email@example.com. Upon receipt of such a request for deletion, we will confirm receipt and will confirm once your Personal Information has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
We do not sell your Personal Information. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide You with an opportunity to opt out of sales of your Personal Information.
In addition, if a California resident exercises his or her rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
Application of this rights is subject our ability to identify a person as a California resident, and our ability to verify a person’s identity, which may require you to provide us with additional information and confirmations.
For Website Visitors Outside of the United States
Our Website is designed for use by individuals in the United States only. We do not warrant or represent this Policy or the Website’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
Changes to this Policy
Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.
How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at firstname.lastname@example.org.