Effective Date: July 13 2021

This Privacy Policy describes the personal data handling policies of Million Children Empowerment Initiative (“MCEI”) as a controller in connection with its services and website at https://mciempower.org/ (the “Website”; the Website collectively with our services, the “Services”).  

This Privacy Policy describes the following:

· What personal data we collect from Users; 

· How we use the data;

· With whom we may share the personal data;

· Legal basis for processing the data;

· Storage and security of your data;

· Your Privacy Rights, Choices and Disclosures, including those for Europe and California;

· Users outside the United States; and

· Third Party Sites, Privacy Policy updates and Contact Information.[ 2] 

We collect information that you provide directly to us, including when you sign up to donate, receive newsletters, announcements and invitations, contact us by email, apply for employment, or purchase products. We may collect the following:

· First name (required field)

· Last name (required field)

· Email (mandatory field)

· Phone number (optional)

· Physical Address (optional)

· Username and password (required for account holders)[ 3] 

· Payment card information if you want to donate or purchase products

The Website collects some information using background storage technologies (“cookies”). [ 4] 

We use Google Analytics, a web analytics service of Google Inc. (“Google”)[ 5] which uses cookies to identify the frequency of use of certain areas of our Website and to identify preferences. For more information regarding how Google collects, uses, and shares your information, please visit their website at http://www.google.com/policies/privacy/partners/. The information regarding your use of the Website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Website, compile reports on activity for us, and perform further services associated with Website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en 

We do not knowingly collect information from users of our Website under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services.  

We use the personal data we collect to communicate with our donors and registrants[ 6] , respond to your inquiries, complete transactions you initiate, provide or enhance the Website, perform our contractual obligations, provide updates and other important information related to your activity on and with the Website, inform you of new services or changes in services, administer the Website and our services, enter into contracts for services, fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes. You may opt out of any electronic marketing communications you may receive from us by contacting us at mcempower@gmail.com [or clicking the unsubscribe link at the bottom of the communication].[ 7] 

MCEI shares your personal data with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our Website hosting providers, payment processor, technology service providers, providers of the goods and services offered on the Website and professional advisors. [ 8] 

We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us. 

Your information may be transferred to another entity (within or outside your country of residence) in connection with a merger or in the event that our business is acquired in whole or part by another entity. 

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes. 

MCEI may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them. 

We rely on the following legal grounds to process your personal information:

Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent, such as marketing email communications. You may unsubscribe from any marketing communications. You may also refrain from providing, or withdraw, your consent for cookies via your browser settings.

Performance of a contract. We may need to collect and use your personal information to enter into a contract with you, to perform services you request or fulfill orders for products. 

Legitimate Interests. We may use your personal information for our legitimate interests to provide our Website and goods and services and to improve our Website and the content contained thereon.  We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law. 

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses until you request to be unsubscribed or remove yourself through any self-service tools offered through the Website or in the communication. 

We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with reasonable safeguards. [ 10] 

As for payment cards, MCEI does not retain payment card numbers. Rather MCEI retains non-sensitive payment data, such as customer contact information, details of the subscriptions and services purchased, and sufficient records of authorized credit transactions to verify that a subscription is in good standing. [ 11] 

No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us via email or over the Internet. 

You may opt out of receiving electronic marketing communications from us by[ 12]  contacting us at mcempower@gmail.com. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority. 

You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en[ 13] 

2. Your European Privacy Rights and Choices.  If you reside or otherwise find yourself in the territory of Europe, your privacy rights under the European data protection law include:

· Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.

· Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. 

· Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time. 

· Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal and contractual requirements. 

· Right to data portability. You have the right to data portability of your own personal data by contacting us.

· Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.

· Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

3. California Disclosures

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to mcempower@gmail.com with “California Shine The Light Rights” in the subject line. 

California Do Not Track Disclosure: The Website does not recognize Do Not Track browser signals. [ 14] 

California Consumer Privacy Act Disclosures[ 15] . MCEI is a non-profit entity and therefore not a “business” under the CCPA. 

The Website is controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may process the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States. 

Our Website may contain links to other websites (“Linked Sites”) for your convenience or information. Linked Sites are operated by companies or organizations unaffiliated with MCEI, and we are not responsible for the content or privacy practices of those sites. Linked Sites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites. 

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on our home page.[ 16]  The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy. 

Questions and Contact Information

Please contact us if you have any questions about our Privacy Policy. You may contact us by sending correspondence to the address below or by emailing us at mcempower@gmail.com. 

Million Children Empowerment Initiative

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United States