Privacy Policy
Effective as of June 27, 2023
Welcome!
Welcome to the EM:RAP GO Website at https://www.emrapgo.org/ (the “Website”), which includes all subdomains and sub-pages present and future. We are delighted that you have chosen to visit and use the Website.
We want you to know we take your privacy and protection of Personal Information very seriously. We are providing this Privacy Policy (the “Policy”) to tell you about who we are, what Personal Information we collect from you and about you, and what we do with your Personal Information, all while you use the Website or otherwise interact with us. The Policy also explains your rights under the law, and how you can contact us and the necessary authorities to enforce those rights. We ask that you please read it carefully.
Key Elements of this Policy
Here are the key elements of this Policy so you can know the most important parts right away to make an informed decision about your consent for our collection, use and disclosure of your Personal Information. You can find the details in the rest of the Policy.
| Personal Information we collect from you but only with your consent | What we do with it | Third parties we share it with |
|---|---|---|
| Newsletter Information | Send you our newsletter | Companies that provide our communications, specifically MailChimp |
| Assistance Information | Determine your eligibility to receive free or discounted EM:RAP subscriptions | Companies that provide the infrastructure for the Website, specifically silverorange |
| Volunteer Information | Determine what volunteer opportunities might be available to you | Companies that provide the infrastructure for the Website, specifically silverorange |
| Donation Information | Communicate with you about your Donation | Companies that provide the infrastructure for the Website, specifically silverorange, and payment processor Recurly |
| Billing Information | Process your payments for your Donation | Payment processors, specifically Braintree and Recurly |
Some Terms
Before we get started with the details, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your Personal Information and privacy in the place where you live. These include: (1) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States; (2) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; and (3) the “UK GDPR” which applies to our activities in the United Kingdom; please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR as applicable. EM:RAP GO is committed to adhering to these and any other applicable Data Protection laws.
“Personal Information” is information we collect from you or about you and which is defined in the CCPA as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” The similar concept in the GDPR is “personal data”, defined as “any information relating to an identified or identifiable natural person.” In either case, it can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and/or numbers) that gets attached to you. Any mention of “Personal Information” in this Policy shall also mean personal data as defined in the GDPR.
Other terms and definitions used in this Policy may be found in our Terms of Use, and will have the same meaning in this Policy as they do there.
About Us and Contacting Us
EMRAPGO, Inc. (“EM:RAP GO”) is a duly-registered domestic non-profit organization in the State of California, USA, at the address listed below. Where this Policy refers to “EM:RAP GO”, it may refer to EMRAPGO, Inc. and/or its shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.
Under the CCPA, EM:RAP GO does not meet the definition of a “business”, but we voluntarily conform to the obligations for businesses under the CCPA. Under the GDPR, EM:RAP GO is a “data controller”. That means we collect Personal Information directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your Personal Information; it is used in this Policy in that way. The CCPA defines processing as “any operation or set of operations that are performed on Personal Information or on sets of Personal Information, whether or not by automated means”; any use of processing in this Policy would also meet such definition.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:
EM:RAP GO Privacy Officerprivacy@emrap.org
Here is the mailing address for you as well:
EM:RAP GO Privacy Officer1812 W. Burbank Blvd., #356
Burbank, CA 91506
USA
Your Rights
You have the following rights regarding your Personal Information held by EM:RAP GO, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay (if any) for any of the Website. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Website.
- The right to withdraw at any time your consent for EM:RAP GO to process your Personal Information;
- The right to have your Personal Information erased from EM:RAP GO’s records;
- The right to access your Personal Information and any relevant information around its processing and use;
- The right to have a copy of your Personal Information given to you in an easy to read format so that you can transfer it to another business or data processor;
- The right to have your Personal Information corrected or updated if you believe it is inaccurate or out of date;
- The right to opt out of marketing communications we send you, at any time;
- The right to know whether EM:RAP GO sells or shares your Personal Information (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
- The right to demand that EM:RAP GO not sell your Personal Information;
- The right to restrict the processing of your Personal Information if it is inaccurate or if our processing or use of it is against the law; and
- The right to refuse any marketing or advertising targeted at you by EM:RAP GO. Please note however that EM:RAP GO does not do any targeted marketing or advertising.
If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above, or refer to certain relevant sections further in this Policy.
Personal Information Collected from You and What We Use It For
In the table below, please find all the Personal Information we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this Personal Information. Under the CCPA, there is no equivalent concept. However, by submitting this Personal Information you acknowledge having granted to EM:RAP GO your consent to process the Personal Information.
| Personal Information category | Personal Information processed | What we use it for (the “purpose” of processing) | Legal basis for processing under the GDPR |
|---|---|---|---|
| Newsletter information | Your name and email address | To communicate with you and send you the newsletter | Your consent in giving us this information |
| Assistance Information | Your name, email address, mailing address, education and residency information, and any personal information included on your submitted identification | To determine your eligibility to receive free or discounted EM:RAP subscriptions | Your consent in giving us this information |
| Volunteer Information | Your name, email address, mailing address, education and residency information, and any personal information included on your submitted identification | To determine what volunteer opportunities might be available to you | Your consent in giving us this information |
| Donation Information | Your name and email address | To communicate with you about your Donation | Your consent in giving us this information |
| Billing Information | Credit card holder name, credit card number, expiration date, CVV/CVC number and billing address | To allow you to pay for Donations you make to EM:RAP GO | Performance of a contract between you and us |
Personal Information Collected About You from Third Parties and What We Use It For
EM:RAP GO does not collect personal data about you from third parties.
Sensitive Personal Information
We do not collect any of what the GDPR considers sensitive Personal Information from you, unless you voluntarily submit it to us, which we encourage you not to do.
Who We Transfer Your Personal Information To
We routinely share some of your Personal Information with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area or the U.K. — please see the “Transfer of Your Personal Information Outside of the European Economic Area and the U.K.” further down in this Policy for more information including on how we safeguard your Personal Information when this occurs.
We will share Personal Information with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of EM:RAP GO’s Terms of Use; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks).
We may also share Personal Information: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with EM:RAP GO (in which case we will require such entities to honor this Policy); or (2) if EM:RAP GO merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).
We will never share your Personal Information with other third parties except under these circumstances. We do not sell, rent or lease your Personal Information to any third party for direct marketing purposes or any other purpose.
| Personal Information category | Who we transfer it to | What they do with it |
|---|---|---|
| Newsletter information | Companies that provide email Website, specifically MailChimp, as detailed more fully in the Email Communications section below | Manage our mailing list and send you the newsletter |
| Assistance Information | Companies providing technical infrastructure for the Website, specifically silverorange | Store it so that we may retrieve it to use it for the purposes described above |
| Volunteer Information | Companies providing technical infrastructure for the Website, specifically silverorange | Store it so that we may retrieve it to use it for the purposes described above |
| Donation Information | Companies providing technical infrastructure for the Website, specifically silverorange | Store it so that we may retrieve it to communicate with you |
| Donation Information | Payment processing companies, specifically Recurly | Communicate with you about your Donation, and manage your recurring Donation |
| Billing Information | Payment processing companies, specifically Recurly and Braintree | Process your payments for your Donations |
How We Protect Your Personal Information
We have implemented very strict technical and organizational procedures for ensuring that, by default, only Personal Information which is necessary for each specific purpose of the processing are processed by us. These procedures prevent your Personal Information from being lost; or used or accessed in any unauthorized way.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
EM:RAP GO uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website, and these third parties have been selected for their high standards of security, both electronic and physical.
Finally, all information, including Personal Information, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check EM:RAP GO’s valid SSL security certificate.
Tracking Technology (“Cookies” and Related Technologies)
EM:RAP GO uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and in the Website, and by interacting with the Website you agree to their use. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.
Specifically, we use cookies and related technologies for the following functions:
- to facilitate payment processing for your Donations and to keep track of certain preferences while using the Website to make Donations.
Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:
Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use our Website. Furthermore, deleting certain cookies may prevent certain functions from working at all.
Email Communications and Compliance with Anti-Spam Laws
EM:RAP GO uses MailChimp to manage our mailing list and send out our newsletter, and Recurly to send out emails related to Donations (MailChimp and Recurly, collectively the “Email Service Providers”). Personal Information is transferred to the Email Service Providers in order to manage the mailing list and for the emails to be sent out properly. Your Newsletter Information and Donation Information is only used to send out emails; the Email Service Providers do not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party. For more information, please refer to MailChimp’s Privacy Policy and Recurly’s Privacy Policy.
You may unsubscribe from EM:RAP GO’s newsletter mailing list at any time by following the link at the bottom of all EM:RAP GO emails. Other types of emails, such as transactional, relational, and other emails related to your Donation will not have an opt-out option as they are necessary for the use of the Website.
EM:RAP GO’s practices in regards to its email are designed to be compliant with anti-spam laws, specifically the CAN-SPAM Act of 2003. If you believe you have received email in violation of any anti-spam law, please contact us using the contact information further up in this Policy.
Transfer of Your Personal Information Outside of the European Economic Area (EEA) and the U.K.
For our European users, we endeavour to keep your Personal Information inside the EEA or the U.K. (as applicable). However, certain of our data processors (and EM:RAP GO) are in other countries where your Personal Information may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:
- The United States. Your Personal Information is only transferred to companies in the United States that have signed the Standard Contractual Clauses and informed us they are GDPR-compliant.
- Canada. Canada has been determined to have an “adequate level of protection” for your Personal Information under European data protection law.
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the U.K. Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Website.
Supervisory Authorities and Complaints
If you are in the EEA or the U.K., under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about EM:RAP GO’s data practices, we invite you to contact the supervisory authority in your country. For example, if you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, United Kingdom, SK9 5AF). If you are in France, you should contact the Commission Nationale de l’Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here.
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
Data Retention
Your Personal Information will only be kept for as long as it is necessary for the purpose needed for that processing.
Automated Decision-Making
EM:RAP GO does not use any automated decision-making processes in providing the Website.
Children’s Privacy Statement
The Website is not intended for children under the age of 16. We do not knowingly collect any Personal Information from a child under 16. If we become aware that we have inadvertently received Personal Information from a person under the age of 16 through the Website, we will delete such information from our records.
Changes to This Privacy Policy
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Website if we make significant changes. If we have your email, we will also email you to tell you the Policy has been updated and what the important changes are.