Harlem Children’s Zone Privacy Policy

This Policy covers individuals who visit our website; donors and prospective donors; people who register for or attend HCZ events and convenings; individuals who subscribe to our communications or sign up to receive text messages; and others who contact us or provide information to us. As noted above, the education records of Promise Academy scholars are governed separately.

Information you provide to us. Depending on how you interact with HCZ, this may include:
• Contact information — name, email address, telephone number, and mailing address.
• Donation information — the details needed to process and acknowledge your gift. Online card donations are processed through a secure third-party payment processor whose servers encrypt your card information for transmission.
• Event and convening information — information you submit to register for or participate in an HCZ event, such as your name, title, organization, and any accessibility or dietary needs, together with any optional information you choose to share through an event app.
• Communications — information you provide when you contact us, respond to an appeal, or sign up for updates or text messages.
Information we collect automatically. When you use our website, we and our service providers may automatically collect certain technical and usage information, such as your IP address, device and browser type, pages viewed, links clicked, and the dates and times of your visits. We collect this information using cookies and similar technologies, including analytics and advertising tools (see Section 4).
Information from third parties. We may receive information from payment processors, event and registration platforms, social media services you use to interact with us, and partner organizations, consistent with their own privacy practices.

We use personal information to:
• Process, acknowledge, and keep records of donations;
• Communicate with you, including sending program updates, event information, newsletters, and fundraising appeals;
• Register you for and administer events and convenings, including any optional event app;
• Respond to your inquiries and requests;
• Operate, maintain, secure, analyze, and improve our website and communications; and
• Comply with our legal, tax, audit, and regulatory obligations and protect the rights, safety, and property of HCZ and others.

Our website uses cookies, pixels, tags, and similar technologies, which fall into a few general categories:
• Essential technologies that are necessary for the site to function;
• Analytics technologies, such as Google Analytics and Google Tag Manager, that help us understand how visitors use our site; and
• Advertising and social media technologies, such as the Meta (Facebook) pixel, that help us measure and, where applicable, extend our outreach.
You can control cookies through your browser settings and, for many advertising and analytics tools, through the providers’ own controls, including Google’s ad settings, the Google Analytics opt-out, your Meta ad preferences, and the industry opt-out pages operated by the Network Advertising Initiative and the Digital Advertising Alliance. Because there is no common standard, we do not currently respond to browser “Do Not Track” signals.

Service providers. We share personal information with vendors that perform services on our behalf — such as payment processing, email and donor-management services, event registration and event-app platforms, and analytics and advertising providers — and that are permitted to use the information only to provide those services to us.
Within HCZ. We share information internally with the HCZ teams that need it to carry out the purposes described in this Policy, including our development (fundraising) and National Impact teams.
Legal and safety. We may disclose personal information:
• Where disclosure is required by law or regulation or is requested by a government agency;
• Where our records indicate that a person may be engaged in fraudulent or other deceptive practices that a government agency should be made aware of; and
• To appropriate persons, if a communication suggests possible harm to others.
We do not sell your personal information, and we do not rent, trade, or otherwise share donor or supporter contact information with third parties for those third parties’ own marketing purposes.
Some U.S. state privacy laws treat the use of third-party analytics and advertising technologies (such as the cookies and pixels described in Section 4) as “sharing” or even a “sale” of personal information. Although HCZ, as a nonprofit, is generally not a “business” subject to those laws, we describe these practices here for transparency, and Section 4 explains the browser, platform, and industry controls available to limit them.

Communications. You can opt out of our marketing and fundraising communications at any time by contacting us using the information in Section 14.
Cookies and tracking. You can manage cookies and tracking technologies as described in Section 4.
Reviewing your information. You may contact us to review or update the personal information we hold about you, or to ask a question about our privacy practices.
Donor recognition. You may ask that a gift be treated as anonymous or that your name not be listed in our published donor recognition (see Section 11).
Text messaging. We do not share or sell text-messaging opt-in data, consent, or related information with any third party, except as required by law.

If you are located in the European Economic Area (EEA) or the United Kingdom, the following additional information applies to our processing of your personal information.
Controller. HCZ is the controller of your personal information for the purposes described in this Policy.
Legal bases. We process personal information on the following bases:
• Performance of a contract — for example, to register you for and administer an event you have signed up to attend;
• Consent — for example, where you opt in to an event app or to text messages;
• Legitimate interests — to operate, secure, and improve our website and communications and to advance our charitable mission, including fundraising communications to existing supporters, balanced against your rights; and
• Legal obligation — to meet our tax, audit, and regulatory requirements.
Your rights. Subject to applicable law, you have the right to request access to, correction of, or erasure of your personal information; to request restriction of, or to object to, our processing; to request portability of certain information; and, where we rely on consent, to withdraw your consent at any time without affecting prior processing.
International transfers. HCZ is based in the United States, and the information we collect is processed and stored in the United States, which may not provide the same level of data protection as your home jurisdiction. Where required, we take steps to ensure appropriate safeguards are in place for such transfers.
Complaints. You have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to address your concerns first — please contact us as described in Section 14.

We keep personal information only as long as necessary for the purposes described in this Policy, after which we delete or de-identify it. Retention periods vary by the type of information:
• Donation records are retained as required by our tax, audit, and charitable-reporting obligations;
• Event and convening information is retained for administrative and follow-up purposes for a limited period following the event and is then securely deleted, unless you have an ongoing relationship with HCZ or you ask us to delete it sooner; and
• Subscription and communications information is retained until you unsubscribe or ask us to delete it.

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure, consistent with the New York SHIELD Act and other applicable law. Online card payments are processed through a payment processor whose secured servers encrypt your card information for transmission. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will provide notice as required by applicable law.

We are pleased when young people visit the HCZ website to learn about our organization. Our website is intended for a general audience and is not directed to children. HCZ does not knowingly solicit personal information from children or knowingly market to children online. The personal information of Promise Academy scholars is handled separately under FERPA, New York Education Law § 2-d, and the Promise Academy policies — see the HCZ Promise Academy Data Privacy and Security page. If you believe a child has provided us with personal information through this website, please contact us and we will take appropriate steps to delete it.

We are strongly committed to protecting the privacy of our donors. If you make a donation, online or offline, we request contact information (name, email, telephone number, and address) to facilitate and acknowledge your gift. During the year we may send you information about HCZ programs, events, or fundraising appeals. Under no circumstances do we sell, share, trade, or rent your personal information to others.
Where a donation is made in honor or in memory of an individual, we send an acknowledgment to the honoree or the honoree’s family. With the donor’s permission, the donor’s name is included. If the honoree or the family wishes to send a personal acknowledgment, we will provide the donor’s address, but only upon request and with the donor’s permission. The gift amount is never included.
Unless you specify that your gift should be anonymous or otherwise request that your name not be listed, we list the names of donors who give $10,000 and above in our biennial report to acknowledge your generosity publicly.

Our website may contain links to third-party websites and services, including social media platforms, partner organizations, and our payment processor. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to them. We encourage you to review their privacy policies.

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date above and post the updated Policy on this page. If we make material changes, we will provide additional notice as appropriate.

To review your personal information, opt out of future mailings, exercise any of the choices or rights described in this Policy, or ask a question about our privacy practices, please contact us at hczdevelopment@hcz.org or:
Harlem Children’s Zone, Inc. 35 East 125th Street, New York, NY 10035 Tel: (212) 360-3255