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The Trustees of the Kouns Family Foundation (the “Foundation”), have established the following Privacy Policy that will be posted on the Foundation’s website, communicated within the Foundation and be available to interested parties, as appropriate. The Privacy Policy applies throughout the Foundation.   

PRIVACY POLICY NOTICE   

The Kouns Family Foundation 

v1.0 2022-06-15  

This Policy describes the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy applies to information we collect: (i) on the Website, and (ii) in email and other electronic messages between you and the Foundation.   If you have any questions about this policy or about how we use your personal information, please contact us by visiting https://www.kounsfamilyfoundation.org and write to us using the "Contact" page of the website. Attention: Privacy Policy

Please read this Policy carefully before using the Website. By accessing or using the Website, you hereby agree to be bound by this Policy.  If you do not agree to this Policy for any reason, please do not use the Website. 

We have Four Guiding Principles: 

1. We do not ask for personal identification information unless we truly need it to communicate with you or provide you access to our information or services, and then we ask only for the minimum information necessary. 

2. We do not sell, trade, or rent your personal identification information to anyone and we do not disclose your personal information for other  purposes beyond providing the information and services you requested. 

3. We do not use or share your personal identification information unless it is necessary for us to administer activities in order to provide you with information that you requested or to provide you with access to our services or to comply with the law. 

4. We do not store personal identification information for any longer than necessary. Introduction In this policy, we will explain what information we collect, how we collect the information, and how we use and protect your personally identifiable information. We will also explain what rights you have with regards to your personally identifiable information and how you can exercise those rights. 

Our Foundation and Website 

The Kouns Family Foundation is a single USA based entity with no affiliates or subsidiaries. We are the controller of your personal identification information and determine what identification information is collected, how this identification information is going to be used and how this identification information is protected. Our website is: https://www.kounsfamilyfoundation.org   Unless otherwise specifically stated, we consider this to be a US-based website. 

What Information We Collect 

You may visit our Website without being required to provide your name, email address, or similar personal information. However, we may collect several types of information from and about users of the Website, including information.  

• by which you may be personally identified, such as name, mailing address, email address, and telephone number (“personal data”);  

•  that is about you but individually does not identify you (“anonymous data”);  • including the Internet Protocol (IP) address used to connect your device to the Internet; 

• login information, browser type and version, time zone setting, browser plug-in types and versions; 

• Operating system and platform;  

• about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site; and/or 

• cookie strings that a website stores on a visitor’s computer and that the visitor’s browser provides to the website each time the visitor returns. Website visitors who do not wish to have cookies placed on their computers should set their browser to refuse cookies before using the Foundation website, with the drawback that certain website features may not function properly.  

We do not collect “Sensitive Data” which means personal identification information that discloses your medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership. 

We collect this information in the following ways: 

• Directly from you when you provide it to us. You may give us your personal data by filling in forms (such as grant applications), or by corresponding with us through the Website, by email, or otherwise. This includes personal data you provide (i) when you send an email inquiry to the Foundation, (ii) when you sign up to receive emails from us, (iii) in connection with grant applications or awards, or (iv) when you register for and/or participate in our programs, initiatives, and events.

• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through browser cookies. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy. 

• From third parties, such as our grantee organizations. We may receive personal data about you from third parties and other sources, including your organization/company, publicly available sources, and third-party analytics providers. For example, we may receive your personal data if someone at your organization designates you as a contact person for that organization or includes information about you in a grant application. 

How We Use Your Information 

Before we process  personal identification information, we apply the following test to determine whether processing is appropriate: 

• The purpose test – is there a legitimate interest behind the processing? 

• Necessity test – is the processing necessary for that purpose? 

• Balancing test – is the legitimate interest overridden, or not, by the user’s  interests, privacy rights or freedoms? If passing the test, we may use the information we collect to: 

• communicate with you, including to respond to your inquiries and provide information you request from us  

• provide, maintain, and improve the Website, including research and analytics regarding users of the Website and usage patterns  

• notify you about changes to the Website or the Policy  

• process grant applications and manage grants  

• send you emails, mailings, and other information about programs, grants, initiatives, and events  

• process your event or program registration; or  

• administer and protect the Website, including to detect, investigate, and prevent activities that may violate our policies or be illegal. 

We process personal data on the following legal bases:  

(1) where you have given us your consent;  

(2) as necessary to perform our agreements;  

(3) as necessary to comply with legal obligations to which we are subject; and/or (4) as necessary for our legitimate interests in providing services where those interests do not override your fundamental rights and freedom related to data privacy. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another reason that is compatible with the original purpose(s) and/or as required or permitted by law. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. 

How We Share Your Information The Foundation does not sell, rent, or otherwise disclose your personal data to any third parties, except as described below: 

• In Connection with the Foundation’s Work: We may publicly announce the name and affiliations of our grantees and principal investigators in connection with a grant or research/publication activities more generally 

• Third-Party Service Providers: We may disclose your personal data to third-party service providers who use the information to perform services on our behalf, such as website hosting; monitoring and analyzing the use of our Website (Google Analytics); contacting you with email announcements, newsletters, or other information that may be of interest to you; or otherwise improving our website (Google Places). We require all third-party service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with agreed terms.  

• Program Partners: We may disclose your personal data to program partners with which, for example, we hold or organize events. We require program partners to respect the security of your personal data and to treat it in accordance with agreed terms and the law. 

• Other Legal Reasons: We may use or disclose your personal data as we deem necessary or appropriate under applicable laws; to respond to requests from public, governmental, and regulatory authorities; to comply with court orders, litigation procedures, and other legal processes; to obtain legal remedies or limit our damages; and to protect the rights, safety, or property of our employees, you, or others. 

Data Storage 

• Our websites and web applications are hosted in the USA. 

• The website is accessed only by staff located in USA. In all instances, we have appropriate contractual and security measures in place to ensure that personal identification information is protected. 

• Our relationship management, marketing and accounting systems for all our Foundation is USA-based. 

• We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller. 

• Our banking arrangements are based in the USA.  

• We retain your personal data only for as long as is necessary for our legitimate interests, in accordance with our retention policies, and in accordance with applicable laws.

Our security measures 

No data transmission over the internet can be 100 percent secure; therefore, the Foundation cannot ensure or warrant the security of any information submitted on or to the Website. Nevertheless, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. We have what we believe are the “Risk Based” appropriate security controls in place to protect personal identification information. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control. Your rights You have certain rights with regard to your personal information. If you wish to exercise any of these rights, please notify us via the Contact page of the website. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. 

Your rights are as follows: 

• The right to be informed As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you. 

• The right of access You may request a copy of the personal identification information we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal identification information we hold about you as well as the following information: 

• The purposes of the processing 

• The categories of personal identification information concerned 

• The recipients to whom the personal identification information has been disclosed 

• The retention period or envisioned retention period for that personal identification information 

• When personal identification information has been collected from a third party, the source of the personal identification information 

• If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or unreasonable expense (which you may have to meet), we will inform you. 

• The right to rectification When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this personal identification information. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected. 

• The right to erasure (the ‘right to be forgotten’) Where no overriding legal basis or legitimate reason continues to exist for processing personal identification information, you may request that we delete the personal identification information. This includes personal identification information that may have been unlawfully processed. We will take all reasonable steps to ensure erasure. 

• The right to restrict processing You may ask us to stop processing your personal identification information. We will still hold the identification information but will not process it any further. This right is an alternative to the right to erasure. 

If one of the following conditions applies you may exercise the right to restrict processing: 

• The accuracy of the personal identification information is contested 

• Processing of the personal identification information is unlawful 

• We no longer need the personal identification information for processing but the personal identification information is required for part of a legal process 

• The right to object has been exercised and processing is restricted pending a decision on the status of the processing 

• The right to identification information portability You may request your set of personal identification information be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation. 

• The right to know 

You have the right to know if  your personal identification information has been exposed due to a breach in security. 

Complaints 

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner. 

Changes to Our Policy 

We may make changes to this Policy from time to time. We will post any changes to this page along with a notice at the beginning of the Policy of the last date that any changes were made. Your continued use of the Website following the posting of any changes will mean you accept those changes. Users from Outside the United States The Website is operated and controlled by the Foundation in the United States. 

By using the Website, you: 

• acknowledge that your information will be processed as described in the Policy; and  

• consent to having your information transferred to the Foundation and/or our third-party service providers or others, in the United States or elsewhere, as described in the Policy. 

If you are an EU national and reside in the EU, or are a non-EU national residing in the EU, we will transfer and process your personal data collected through the Website to the United States consistent with the requirements of the General Data Protect Regulation and under a legal basis, such as your consent, to perform a contract with you, the processing is in our legitimate interests and it not overridden by your rights, or to comply with law. Individual Rights. If you are an EU national and reside in the EU, or are a non-EU national residing in the EU, you may have the following rights under data protection laws with respect to the personal data you provide to us.  

• To request access to or correct your personal data.  

• To request your personal data be erased if it is no longer necessary for the purposes for which it was processed; you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it; or you consider it has been unlawfully processed.  

• To request that processing of your personal data be restricted if you contest the data’s accuracy, its processing is unlawful, or you have objected to its processing and await verification of our legitimate grounds for processing it. 

• To request transfer of your personal data to another company under certain circumstances.  

• To lodge a complaint with your national data protection regulator if you feel that your personal data has been unlawfully processed. If you wish to exercise any of the rights set out above, please contact us by visiting https://www.kounsfamilyfoundation.org and use the Contact page of the website. Attention: Privacy Policy.  

If you are an EU national and reside in the EU, or are a non-EU national residing in the EU, the data controller (as defined under EU data protection law) will be The Kouns Family Foundation. Third-party Links This Website may include links to other sites operated by third parties. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy and terms of use of every website you visit. Do Not Track We do not track your activities across websites and do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

Minors 

This Website is directed solely at adults. If you are under the age of thirteen (or if being a ‘minor’ is defined as a younger age in your relevant jurisdiction, that relevant age), please do not provide us with any of your personal data, including your email address. Any questions or comments about this Policy can be sent to the Foundation by visiting https://www.kounsfamilyfoundation.org and using the Contact page of the website. Attention: Privacy Policy.