Privacy

MILL TOWN FOUNDATION PRIVACY NOTICE

1. INTRODUCTION

1.1 — This Privacy Notice provides information about how Mill Town Foundation, a Massachusetts with a business address of 100 West St. Pittsfield, MA 01201 (the “Company”, “we”, “our”, “us”) collects and processes the personal data of individuals (“you”, “your”) who visit and/or interact with our website milltownfoundation.org (the “Site”), and to all subsequent correspondence or communications with those people, whether by email, telephone or by post.

1.2 — We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the Site. We recommend that you check the Site often, referring to the date of the last modification listed at the top.

1.3 — It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data.

2. HOW WE COLLECT YOUR PERSONAL DATA

2.1 — We may receive your personal data through various means including Direct interactions:

You may give us your identity and contact data, profile data, transaction data and other information by creating and managing your user profile account, filling in website forms, sharing details about our services or by corresponding with us by mail, phone, email, SMS, social media or otherwise. This includes personal data you provide when you submit coursework, give us feedback or contact us.

2.2 — We may receive your personal data through various means including Automated technologies:

As you browse and interact with the Site, we collect browser data. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

2.3 — Cookies:

Cookies are text files that are downloaded to your device when you visit a website. Cookies perform many different functions and we use them for a variety of reasons, including, to learn what content is popular, improve site experience, provide efficient webpage navigation, save user preferences, understand how you may interact with our Site, and to serve you better ads on other sites. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier as well as the website name. Cookies may be set by the website you are visiting (“first party cookies”) or they may be set by other websites who run content on the page you are viewing (“third party cookies”).
Cookies have various purposes, including letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Most websites you visit will use cookies to improve your user experience by enabling that website to “remember” you, either for the duration of your visit or for repeat visits.
We employ commonly used third-party analytic services that may automatically collect and store information about visits to the Site. We do not have direct control over the tools these third-party analytic services use to collect data. We use this information to get a better sense of how our Site is being used over time so that we can improve them and make them more relevant to users and in ways described herein.

Please note that:

Many of the interactive functions offered by the Site are dependent on cookies and disabling or blocking cookies may impact the functionality of the Site or result in an inferior web experience.
If you’ve chosen to block third-party cookies on your browser, your cookie preferences won’t carry over from the Site and vice versa.
We have no access to or control over any cookies or other devices that are used by any third party advertisers or ad servers on the Site.
If your personally identifiable information changes, or if you no longer wish us to possess your information, you may request correction, updating, or deletion of your information by emailing us at siteadmin@milltowncapital.com

3. WHY WE PROCESS YOUR PERSONAL DATA

Subject to applicable law, your personal data may be stored and processed by us for purposes detailed in the following table:

Purpose for processing personal data

Categories of personal data

Marketing

To inform you of other programs and courses
To invite you to information sessions relevant about other courses and programs we provide
To carry out marketing analysis, for example we look at what you have viewed on our Site and what your preferences are to improve the relevance of our marketing
To provide statistical data to vendors

Your preferences in receiving marketing communications from us
If you would prefer that we do not send such communications to you, please follow the opt-out links on any marketing message or contact us using the contact details in this Privacy Notice.

Browser or device data

Internet protocol (IP) address used to connect your computer to the Internet
Your browser type and version
Time zone setting
Browser plug-in types and versions
Operating system and platform
How often you visit the Site
Site performance data
Related browser and device data

4. THIRD PARTY INFORMATION

4.1 — Other individuals’ personal data
Where you provide us with personal data relating to other people, you represent and warrant that you will only do so in accordance with applicable law, including data protection laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this privacy statement, the Terms of Use, and where necessary you will obtain their consent to our use of their information. You will provide anyone that you provide us with personal data about with a copy of this Privacy Notice. We may notify those individuals that you have provided their details to us.

4.2 — Information collected through third-party links and content
This Site may include links to other websites including vendors and other content from third party businesses and can offer direct interaction with external websites, networks or platforms that are outside our control. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. We do not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the security, privacy of the information collected by these third parties or the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit.

5. DISCLOSURE OF YOUR PERSONAL DATA

We reserve the right to disclose your personal data to third parties:

if we are under any legal or regulatory duty to do so;
to protect our rights or the safety of us, our personnel, users or others; and
to provide statistical data to vendors.

We also use third party service providers as our processors to only hold and use personal data on our behalf in order to provide us with a service. We may also disclose personal data to our professional advisors and experts in order to obtain their assistance in carrying out our services and our activities. We require these parties to keep your personal data confidential and secure and to protect it in accordance with the law. They are only permitted to process your personal data for the lawful purpose for which it has been shared and in accordance with our instructions. You are subject to and must comply with any additional Terms and Privacy Policy that may appear on portions of our Site or through links to third party websites.

6. SECURITY OF YOUR PERSONAL DATA

The Company is committed to maintaining the security of your personal data it processes. The Company maintains appropriate physical, procedural, organizational and technical security measures intended to prevent loss, misuse, unauthorised access, disclosure, or modification of your personal data under the Company’s control. We also limit access to your personal data within our organization and to third parties that need access to your information in providing service to us. They will only process your personal data on our instructions and are required to protect personal data. If you have reason to believe that your personal data is no longer secure, please contact us at siteadmin@milltowncapital.com immediately.

Please be aware that when you transmit information to us or to our service provider over the internet or another telecommunications network this can never be guaranteed to be 100% secure.

We cannot guarantee against any loss, misuse, unauthorised disclosure, alteration or destruction of data but we take reasonable steps to prevent this from happening. We have put in place measures to protect the security of your personal data and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. RETENTION OF YOUR PERSONAL DATA

We strive to ensure that personal data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. We generally retain personal data for as long as is required to satisfy the purpose for which it was collected. We are required to keep certain types of information for a specific period of time in order to comply with legal requirements. Some of your personal data may need to be retained because of circumstances such as a legal dispute or regulatory investigation, which would not normally be subject to retention.

8. UPDATING YOUR PERSONAL DATA

You are responsible for notifying us of any changes to your personal data that you provide to us.

9. CHILDREN

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site. If you are under 13, do not use this Site or Service or provide any information about yourself to us, including your name. If a parent or guardian is made aware that a child under the age of 13 has provided us with personally identifiable information through any point of contact, we ask to be contacted by email via the contact page and we will delete the information.

10. LOCATION OF THE SITE

This Site is hosted and operated in the United States and outside of the States of California and Virginia. Those who access or use the Site from jurisdictions outside the United States or within the States of California or Virginia do so at their own choice and risk and are solely responsible for compliance with local law. If you are not a resident of the United States or reside in California or Virginia, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction and that we may store your personal information in the United States and outside of the States of California and Virginia.

11. QUERIES AND COMPLAINTS

We hope this Notice answers all of your questions about our treatment and protection of your information, but to the extent you have further questions regarding this Notice, we invite you to contact us. If you have any questions or wish to exercise any of your rights please contact us by email at siteadmin@milltowncapital.com

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