We Are Family Foundation Global Privacy Policy
We Are Family Foundation (“WAFF” or “we”) is committed to protecting your privacy. We are pleased to provide this Privacy Policy to inform you of the personal data or personal information we may collect from you or other sources and how we may use and share that information. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at hello@wearefamilyfoundation.com.
This Privacy Policy describes the ways WAFF manages Personal Information (as defined below) that it receives in the course of its operations and from employees, vendors, visitors and guests, including in each such case on our website foundation, blogs, social media pages, mobile applications, and mobile site (collectively, the “Site”). All individuals who process Personal Information on behalf of WAFF are expected to protect Personal Information by adherence to this Privacy Policy.
For a description of the rights of California residents under the California Consumer Privacy Act, and our handling of Personal Information of California residents, please see the section titled “Privacy Rights for California Residents” below.
Personal Information Generally: “Personal Information” or “personal data” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Process” or “processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, acquisition, holding, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Collection and Use of Personal Information: The types of Personal Information we may collect (directly from you or from third parties) depend on the nature of the relationship you have with WAFF and the requirements of applicable law. Below are the legal bases and some of the ways we may collect and use Personal Information.
Program Participants: The data WAFF collects from or on behalf of its Program Participants include information such as title, name, address, phone number, email address, business or company affiliation, username and answer to a security question and password (if you have access to any of our secure online resources or mobile applications).
We process Personal Information about or on behalf of Program Participants for a variety of foundation purposes including but not limited to:
provide program services
generally manage Program Participant information
respond to questions and requests
provide access to certain areas and features of the Site
verify Program Participant identity
communicate about Program Participant accounts and activities on the Site and systems, and, in WAFF’s discretion, changes to any WAFF policy
tailor content, publications, advertisements and offers we believe may be of interest to Program Participants
process transactions and services utilized by Program Participants
improve the Site and systems
develop new services
further purposes disclosed at the time that Program Participants provide Personal Information, or otherwise with consent
Suppliers: The data WAFF collects from its Suppliers relate to the management of Supplier relationships and the exchange of requested products and services. They may include title, name, address, phone number, email address, invoicing and other payment information and agreements executed with WAFF.
We process personal information about Suppliers for a variety of business purposes, including but not limited to:
generally manage Supplier information
respond to questions and requests
provide access to certain areas and features of the Site
verify Supplier identity
communicate about Supplier accounts and activities on the Site and systems, and, in WAFF’s discretion, changes to any WAFF policy
process payment for products or services purchased by WAFF
improve the Site and systems
develop new products, processes and services
process applications and transactions
further purposes disclosed at the time Suppliers provide personal information or otherwise with consent
Other Personal Data Collection on the Site and through Electronic Communications: In general, you can visit the Site without providing us with Personal Information about yourself. However, in order to access certain information, services or features on the Site, you may be asked to provide Personal Information.
Where you have consented to WAFF’s processing of your Personal Information, subject to applicable legal obligations that may apply to us and to our lawful ability to enforce our rights or your obligations to us, you may withdraw that consent at any time and opt out.
Publications and Email Alerts: On the Site, you may choose to receive publications and email alerts from WAFF. If you elect to sign up, we may ask you for information such as your name, address, company, phone number, email address and publications of interest. We use the information you provide to send the requested communications and to communicate with you about other topics that we believe may be of interest to you. We offer you the option to decline these communications at no cost.
Blogs: You may subscribe on the Site to receive an RSS feed or email from WAFF blogs. We use this information to send you the requested communications and to communicate with you in connection with our blogs. You may also be able to submit comments to WAFF blogs that include Personal Information, such as your name and email address, with your comment. We may use your name to identify you as a commenter on our blogs.
Social Media: Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis and referral functions to share website content and tools with a friend or colleague. We may collect information that you make publicly available through social media resources. We may use this information for a variety of foundation purposes, including for foundation development. WAFF will comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.
Contact Us: You may communicate with us through the “Contact Us” link on our Site or the App. If you choose to contact us via the Site we may ask you for information such as your name, address, company, phone number and email address so we can respond to your questions and comments. We also may use the information you provide to communicate with you about topics that we believe may be of interest to you.
Email Communications: When you engage in email communications with any WAFF employees, we may retain records of your email address, along with other information that we collect, such as your name, title, address, phone number, email address, or company affiliation, as well as information about your engagement with emails, attachments, and/or links that we send to you. We may use this information for a variety of foundation purposes, including for business development.
Event Registration: You may register for WAFF-sponsored events. You may provide us with information such as your name, address, company, title, phone number and email address when registering for an event. We use this information to register you for the event and contact you about event updates. We also may use the information to communicate with you about other events and topics that we believe may be of interest to you.
Password-Protected Extranet: You may access parts of the Site that are password-protected in order, for example, to obtain access to documents in the course of WAFF providing you with legal services. You may provide us with information such as your name, address, company, title, phone number and email address when accessing password-protected parts of the Site. We will not use this information to market to you.
Aggregate Information: From time to time, we may collect and monitor other nonpersonal information about the use of the Site, such as the number and frequency of visitors to our Site. This information may include the websites that you access immediately before and after your visit to the Site, the browser and operating system you are using, your Internet protocol (IP) address, host name, device type, geographic data, and screen resolution. We collect this information in order to determine which areas of the Site are most popular and to help us develop and improve our Site. We may group this information into aggregate visitor data in order to describe the use of and preferences on the Site. However, this aggregate data does not personally identify you or any other visitors to the Site except as agreed by you.
Cookies and Other Tracking Technologies: When you visit our Site, we collect certain information by automated means to help us improve our Site and provide customized services and information. Like many companies, we collect this information through the use of “cookies” and other tracking technologies. Cookies are small text files that are downloaded to your computer’s memory and hard drive when you visit certain websites. Some cookies are automatically deleted when you close your browser or after a short period (“temporary cookies”), while others can be stored longer on your computer, sometimes until you delete them manually (“persistent cookies”). For example, we may use cookies to collect information about website activity or to tell us whether you are an existing or new visitor to our Site. Our Site utilizes both temporary and persistent cookies to enhance your online experience.
We require your affirmative consent before using cookies or other technologies that would track your personal data. If you wish to restrict, block, or delete the cookies that are set by our Site, you can do so using your browser settings. Most browsers allow you to control cookies, including whether to accept them and how to disable existing cookies. You may also set most browsers to notify you if you receive a new cookie. Please note that some features of the Site may not function properly or may be slower without cookies. To make full use of the Site, your computer or mobile device will need to accept cookies. For more information about cookies and how to remove them on your browser, you can visit these third-party websites:
You can also learn more about cookies here: www.allaboutcookies.org.
Other tracking technologies may record information such as your IP address, browser software and operating system, host name, referring site, clickstream data, device type, geographic data, and dates and times that our Site is accessed. An IP address is a number that your Internet service provider automatically assigns to the computer you are using. An IP address is identified and logged automatically whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. Our Site does not respond to "do not track" signals.
It is not our practice to link the information we record using cookies or other tracking technologies to any Personal Information you submit through the Site. However, we reserve the right to use cookies and other tracking technologies to identify a visitor. We may do so, for example, when we believe it is necessary to protect the Site, our visitors, Program Participants or other third parties, or to protect our rights or defend against a claim relating to us, or when we believe that the law requires it.
Third-Party Websites: For your convenience, our Site may contain links to websites owned and operated by third parties. Please note that WAFF does not control such third-party websites, the content of these sites, any products or services that may be offered through these sites, or any other use of the linked sites. These other websites may send their own cookies to visitors, collect data or solicit Personal Information, and the privacy policies of these other sites may be significantly different from this Privacy Policy. Your access to and use of such websites is governed by the terms of use and policies of those sites and shall be at your own risk. WAFF is not responsible for the privacy practices of these other sites and cannot guarantee the security of any information collected by any linked or other third-party website. WAFF encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their users’ Personal Information with WAFF; that sharing is governed by that company’s privacy policy, not this Privacy Policy.
Information from Third-Party Sources: WAFF may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify or supplement information that you have provided to WAFF and to enhance our ability to provide you with information about our business and services. WAFF’s agreements with these third parties typically limit how WAFF may use this supplemental information.
Sharing of Information: WAFF does not sell, rent, trade or otherwise disclose Personal Information, except as described in this Privacy Policy or as you explicitly consent. We may share your information among WAFF entities and affiliates. We also may share the information with third-party service providers we have retained to perform services on our behalf to help with our foundation activities. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.
We may disclose information about you (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation or arbitration; (iv) to enforce WAFF policies, contracts or other rights; (v) to collect amounts owed to WAFF; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if in good faith we believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Protection of Information: WAFF takes reasonable and appropriate steps to protect the Personal Information you share with us from unauthorized access or disclosure. For example, the Personal Information you provide through our Site is protected by a firewall (a combination of computer hardware and software that helps keep unauthorized visitors from accessing information within our computer network). While we strive to protect your Personal Information and privacy, WAFF cannot guarantee or warrant the security of any information disclosed or transmitted to us and cannot be responsible for the theft, destruction or inadvertent disclosure of your Personal Information.
Cross-Border Transfer: Your Personal Information may be stored and processed in any country where we have offices or servers or in which we engage service providers. Your Personal Information may be transferred to countries outside your country of residence, including the United States, which may have different data protection and data processing laws than those in your country. Our Privacy Policy requires all of our offices to at all times ensure a level of protection at least as protective as those mandated by the European Economic Area. Any such transfer shall take place only in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of Personal Information are likely to be different and in some cases may be weaker than those within your home jurisdiction. Regardless, in all events, we shall apply the provisions of this Privacy Policy to your Personal Information wherever it is located.
Children’s Privacy on the Site: The Site is not intended for use by children under the age of 13. We do not knowingly collect Personal Information from anyone under 13 years of age through the Site. If you are under 13, please do not submit any Personal Information on the Site.
Retention: WAFF will retain the Personal Information we receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services and products, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws and in accordance with our routine information storage policies.
Your Rights: To the extent required by law, we provide users with reasonable access to the Personal Information provided to WAFF, a portable copy of the information, and the ability to review, correct, delete, restrict or object to the processing of such information.
Although WAFF makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which WAFF is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the information is commercially proprietary. If WAFF determines that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, WAFF will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
If you would like to review or update your Personal Information or preferences, or have your information removed from our mailing lists, please let us know by emailing us at hello@wearefamilyfoundation.com or by writing us at:
United States: We Are Family Foundation, 163 Amsterdam Avenue, #1417, New York, NY 10023
United Kingdom: We Are Family Foundation, Elsley Court, 20-22 Great Titchfield Street,
London, UK W1W 8BE
Dispute Resolution: EU residents may report privacy complaints directly to their local data protection authorities. You may also contact us to be directed to the relevant authorities.
Privacy Rights for California Residents: California’s Consumer Privacy Act (CCPA) (Civil Code Sections 1798.100 – 1798.199) grants California residents certain rights regarding the use of their personal information. This section describes those rights and how California residents can exercise them. These rights pertain only to residents of the State of California.
(1) The right to notice that personal information will be collected:
You have the right to request certain information about our collection and use of consumers’ personal information over the past 12 months. The categories of information that we have collected from consumers in the past twelve months, and may collect from you, are listed below along with the purposes for which we collect it. We update this information at least once every 12 months.
Identifiers, such as a name, postal or email address, IP address, account name, Social Security number, driver's license number, or passport number: We collect Identifiers for a variety of business purposes, including but not limited to providing legal services, analyzing legal claims, managing Program Participant information, and responding to requests. The purposes for which we collect Identifiers may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Personal information categories are listed in Cal. Civ. Code § 1798.80(e). We collect some Personal Information for a variety of foundation purposes, including but not limited to: providing programs, generally managing Program Participant information, and responding to requests. The purposes for which we collect such information may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Protected classification characteristics under California or federal law, such as age, race, ancestry, citizenship, religion, marital status, medical condition, gender identity or expression, pregnancy or childbirth, sexual orientation, veteran or military status, or genetic information. We generally do not collect this type of information unless it directly relates to a specific program or service we provide to you. The purposes for which we collect such information may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Commercial information, such as products or services purchased or considered, or other purchasing or consuming histories or tendencies: We collect this information in order to provide program services to Program Participants or analyze legal claims, especially in the course of providing legal services related to real estate or trusts and estates. The purposes for which we collect such information may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Biometric information, such as fingerprints, faceprints, voiceprints, or other physical patterns, and sleep, health, or exercise data: We generally do not collect this information unless it directly relates to a legal claim or defense or a agreed upon service we provide to you.
Internet or other similar network activity, such as browsing history or a consumer’s interaction with a website, application, or advertisement: Please refer to the section above titled Cookies and Other Tracking Technologies.
Geolocation data, such as a person’s physical location or movements: As is true of most web sites, the Site server automatically recognizes the Internet URL from which you access the Site. An IP address may indicate the location of your computer on the Internet.
Sensory data, such as any audio, electronic, visual, thermal, or similar information: We may collect this information in order to provide program services to Program Participants, including depositions, hearings, trials, or other legal proceedings that are filmed or transcribed.
Professional or employment-related information, such as a job history or performance evaluations: We may collect this information for the purposes of considering applications for employment and recruitment or to provide services to Program Participants and manage the business of the foundation. The purposes for which we collect such information may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Non-public education information, such as grades, transcripts, student information, or disciplinary records: We may collect this information for the purposes of considering applications for employment and to provide program services, and not to market to you. The purposes for which we collect such information may vary based on our relationship with you. Please refer to the section above titled “Collection and Use of Personal Information” for a description of the purposes for which we collect Identifiers based on the types of interactions you have with us.
Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes: We may collect such information. To the extent this information is collected it is done only as part of providing services to Program Participants or analyzing services to be provided, and not for marketing purposes.
(2) The right to know what personal information has been collected, sold, or disclosed for a business purpose, and to whom it was sold or disclosed:
You have the right to request that we disclose what personal information we have collected about you in the past 12 months. Once we receive and confirm your verifiable request, we may disclose to you:
The categories of personal information we’ve collected about you.
The categories of sources for the personal information we’ve collected about you.
Our business or commercial purpose for collecting and/or selling that personal information.
The categories of third parties with whom we’ve shared that personal information.
The specific pieces of personal information we’ve collected about you.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
All sales of your personal information, identifying the categories of personal information that were sold and the categories of each third-party recipient who purchased that information; and
All disclosures of your personal information for a business purpose, identifying the categories of personal information that were disclosed and the categories of each third-party recipient who obtained that information.
We do not sell the personal information of any consumer. We also do not disclose for a business purpose the personal information of any consumer to any third party aside from certain vendors or service providers who process information as part of our business of providing legal services, including for example copying services, document processors, and legal filing services. Pursuant to the CCPA, WAFF may deny your request, in whole or in part, including, but not limited to, in order to comply with federal, state, or local laws; to comply with federal, state or local regulatory inquiries, investigations, subpoenas, or summonses; or to prevent disclosure of information that WAFF is otherwise legally prohibited from disclosing. In the event that WAFF denies your request, in whole or in part, WAFF will inform you of the basis for its denial (“Regulatory Exceptions”).
(3) The right to opt-out of the sale of personal information:
WAFF does not sell consumer data.
(4) The right to have your personal information deleted:
You have the right to request that we delete any of your personal information that we collected, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we may delete (and direct our service providers to delete) your personal information from our records, unless Regulatory Exceptions apply.
(5) The right to non-discrimination as a result of exercising these rights.
You have the right to be free from discrimination by any business, such as being charged different rates or denied services, as a result of exercising your rights under the CCPA. If you believe we have violated any of your rights under the CCPA, please contact us by sending an e-mail to hello@wearefamilyfoundtion.com or by writing us at:
United States: We Are Family Foundation, 163 Amsterdam Avenue, #1417, New York, NY 10023
Exercising your rights as a California resident:
Only residents of the State of California may exercise these rights under the CCPA. If you are a California resident and would like to make a request regarding your personal information, you may do so by contacting us. Alternatively, California residents may make the same requests by calling +1 212-397-4333 or by sending an e-mail to hello@wearefamilyfoundation.com.
In order to protect your personal information, we are required to verify that any person making a request under this section is in fact you or your authorized agent. In order to verify the identity of the person making a request, we may ask you to provide the following information: Full Name; Organization Name; Email Address; Mail Address; Phone Number; Your WAFF Contact. We will use this information only for the purposes of verifying that your request is authentic.
Pursuant to the CCPA, WAFF may deny your request, in whole or in part, including, but not limited to, in order to comply with federal, state, or local laws; to comply with federal, state, or local regulatory inquiries, investigations, subpoenas, or summonses; or to prevent disclosure of information that WAFF is otherwise legally prohibited from disclosing. In the event that WAFF denies your request, in whole or in part, WAFF will inform you of the basis for its denial.
Once we receive your request, we will respond within 10 days and inform you if we need any more information from you. We will provide a response to your request within 45 days, or within 90 days if your request is complicated or difficult to verify.
We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. Our response will also explain any reasons we cannot comply with a request.
Exercising the rights of a California resident as the resident’s authorized agent:
If you are a consumer and you would like to authorize an agent to submit requests on your behalf, in order to exercise your rights under the CCPA, please designate your authorized agent by contacting us. Alternatively, you may authorize an agent by calling +1 212-397-4333. We may require written and signed authorization from you before an agent may act on your behalf.
In order to verify your identity when you are authorizing an agent to act on your behalf, we may ask you to provide the following information: Full Name; Organization Name; Email Address; Mail Address; Phone Number; Your WAFF Contact. We will use this information only for the purposes of verifying that your request is authentic.
Changes to This Privacy Policy: We may update or change this Privacy Policy from time to time and without prior notice to you. We will post a “last modified” date for this Privacy Policy to indicate when it was most recently updated. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.
Last modified: July 7, 2020.