Collection, Use, and Security of Personal Information
A. CTFC Collection of Personal Information
1. The CTFC will collect Personal Information on an individual only if the individual provides the information to the CTFC. The CTFC also may collect information about a person who has been referred to the website to send them emails regarding CTFC's efforts or a person to whom the CTFC has been asked to send emails regarding CTFC's programs or efforts. If a person donates to the CTFC, the CTFC may collect sensitive Personal Information such as the donor's credit card number, card type, expiration date, and keep a record of the financial transaction.
The CTFC may collect Demographic Information it obtains from individuals and third parties for fund raising purposes and to notify persons of CTFC programs, events, educational opportunities, and upcoming meetings.
The CTFC may collect Aggregate and Transactional Information and add to its database every time a person visits a CTFC Web Site.
2. Types of information: "Personal Information" is "Demographic Information" which identifies a specific individual with a minimal degree of effort. Demographic Information includes name, address, city, and other similar information. Transactional Information is data collected on an individual based on the individuals' interactions with the CTFC, which may include sensitive information such as credit card information. Aggregate Information is information presented in summary or statistical form which does not contain data that would permit the identification of a specific individual without extraordinary effort.
B. CTFC Use of Personal Information
1. When an individual provides Personal Information to the CTFC, the CTFC may use the Personal Information for its programs and fund raising.
2. The CTFC uses Transactional Information for research purposes for the development or implementation of its programs, products, and services. The presumption is that, since Transactional Information is highly proprietary, it will not be disclosed to third parties.
3. The CTFC will disclose all information as required by law.
4. The CTFC will make every effort to discontinue the use of an individual's Personal Information as soon as practicable if requested by that individual. The CTFC may need to retain Information in its archives and records to comply with law, resolve disputes, analyze problems, assist with any investigations, enforce CTFC's User Agreement, and other policies, and take other actions otherwise permitted or required by law.
C. Specific Requirements
a. The CTFC will take reasonable and appropriate measures to keep Personal Information confidential and in a secure environment, including taking appropriate action in the event of unauthorized disclosure.
b. Access to Personal Information will be restricted to only those personnel with a legitimate business purpose.
c. The CTFC owns all Personal Information provided to it by individuals and collected in accordance with this Policy.
2. Third Party Disclosure
a. Permission is required before the CTFC discloses Personal Information to a third party. It is the policy of the CTFC not to disclose Demographic or Transactional Information to any third party.
b. No permission is necessary for Aggregate Information, since Aggregate Information does not identify a specific individual.
c. From time to time, there is a benefit in allowing a third party to use collected Personal Information on individuals. However, unless an individual gives permission, the CTFC will not disclose Personal Information collected by the CTFC to any third party. If the CTFC engages a third party to provide certain operational services to the CTFC or on its behalf, then the CTFC may disclose Personal Information to those third parties on a "need to know" basis under a written contract.