Privacy Policy

Effective: June 2017

GENERAL STATEMENT OF PRIVACY

MyPath respects the privacy of its clients and of those who visit the www.MyPathUS.org website at www.MyPathUs.org (including any subpages or mobile versions thereof) Site (“Site(s)”) owned and operated by MyPath. This Privacy Policy (“Privacy Policy” or “Policy”) describes how MyPath protects the privacy and security of personal information (“Personal Information”) of users of this Site.

ACCEPTANCE OF PRIVACY POLICY

By using this Site, you signify your acceptance of this Privacy Policy. Your continued use of the Site means you consent to the terms of this Privacy Policy.

This Policy is incorporated into our MyPath Money Terms of Use and may include terms that are defined in our other additional agreements. In the event of a conflict between this Policy and terms in the additional agreements, the additional agreement will control. You may arrive at a third-party site or service when using our Site, in which case this Policy does not apply. Please review the policies of any third party to learn how they may treat your Personal Information.

UPDATES

This Policy may change from time to time. We will post the most current version of this Policy on our Site with the effective date.

HOW WE COLLECT AND USE INFORMATION:

This Privacy Policy covers how MyPath treats personal information that you submit to us and information is collected through your use of this Site. Personal information is information may include your name, address, e-mail address, payment information, phone number, and any information that identifies you as an individual or relates to an individual linked to such identifying information.

When You Provide Us Information

Except as described in this Privacy Policy, MyPath only collects your Personal Information through this Site when you choose to provide such information, such as when you use the “Contact Us” feature, make a Donation, provide a Testimonial or submit applications related to MyPath’s programs and services. For example, if you fill out the form for our updates or more information, MyPath will collect such information.

Automatically Collected Information

MyPath collects aggregate queries for internal reporting and may also count, track, and/or aggregate visitors’ activity into MyPath’s analysis of general traffic-flow at the Site. To these ends, MyPath may merge information about you into aggregated group data. In some cases, MyPath may remove personal identifiers from Personal Information and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with MyPath’s affiliates, business partners, service providers and/or vendors; if it does so, MyPath will not disclose your individual identity.

Web Server Logs and IP Addresses.
An Internet Protocol (“IP”) address is a number that automatically identifies the computer/machine you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. MyPath may use IP addresses to conduct Site analyses and performance reviews and to administer the Site.
Cookies and Web Beacons.
Cookies are pieces of information that a Site transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Many Sites use cookies as a standard practice to provide useful features when a user visits the Site and most web browsers are set up to accept cookies. MyPath uses cookies to improve your online experience when visiting the Site. You can set your browser to refuse cookies, but some portions of the Site may not work properly if you refuse cookies. Some of the Site’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about Site usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of Sites. Some web beacons may be unusable if you elect to reject their associated cookies. We may also use clear GIFs (or similar technology) in our e-mail communications to document who has opened or responded to our communications.

HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following general purposes: to provide, administer and improve our services, (ii) to better understand your needs and interests, (iii) to fulfill requests you may make, (iv) to personalize your experience, (v) to provide program and service announcements, (vi) to provide you with further information and offers from MyPath and our affiliates, (vii) apply for financial grants, receiving donation and reporting to current and prospective donors, or (viii)to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

Donations

If you donate money to use from our Site, we request that you provide your name, email address, billing address, credit card information, telephone number and other information necessary to complete the transaction. We do not collect or store your full credit card information (although we may store the last four digits for verification purposes). The service provider who manages our donations (or credit card processing service provider) may collect and store full payment card information from you to process your donations.

Testimonials

We display personal testimonials from participants in our programs, in addition to other endorsements. With your consent we may post your testimonial along with your name and image. If you wish to update or delete your testimonial, please contact us at webmaster@MyPathUS.org. If you provide us with comments or feedback we may collect your name and e-mail address, as well as any other content included in the e-mail to send you a reply and improve our service.

Demographic Information

MyPath recognizes that certain User Information of a key demographic nature (e.g., race, age, gender, national origin, income), while not Personal Information, is still of a sensitive nature to users. As a general matter, MyPath does not collect such information about you through the Site. However, in recognition of the sensitive nature of such information, in the event MyPath comes into possession of such information, whether through your voluntary submission of such information in response to a special feature on the Site or by receiving such information from any of our business partners, such information shall, when coupled with any of your Personal Information, itself be deemed to be Personal Information and treated MyPath as such.

HOW WE SHARE YOUR INFORMATION

Third party sites and services

MyPath may share your Personal Information under confidentiality agreements with other companies or organizations that work with, or on behalf of, MyPath to provide products and services. These companies may use your Personal Information to assist MyPath in its operations. These companies or organizations do not, however, have any independent right to share this information. You will always have the ability to opt out from receiving information from MyPath as well as from said third parties.

Social Media Widgets

Our Site may include social media features, such as the Facebook “like” button and widgets, such as the “share this” button. These features may collect your Personal Information and track your use of the Site. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the Privacy Policy of the company providing such functionality.

Disclosures Under Special Circumstances

MyPath may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Business Transfers

If another organization acquires our organization or our assets, that organization will thereafter possess the personal information collected by us, and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

HOW WE SECURE PERSONAL INFORMATION

MyPath understands that storing our data in a secure manner is essential. MyPath stores Personal Information and other data using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Please note, however, that while MyPath has endeavored to create a secure and reliable Site for users, the confidentiality of any communication or material transmitted to/from this Site or via e-mail cannot be guaranteed.

CHILDREN’s PRIVACY PROTECTION

Under Age 13
MyPath understands the importance of protecting children’s privacy in the interactive online world. This Site is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any Personal Information to MyPath and/or the Site.

Under Age 18
Minors under 18 years of age may have the Personal Information that they have provided to MyPath while using this Site deleted by sending an e-mail to webmaster@MyPathUS.org requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your Personal Information does not ensure complete and comprehensive removal of that data from all systems.

RESPONSE TO “DO NOT TRACK” SIGNALS

Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, MyPath does not process or respond to “Do Not Track” signals

HOW TO CONTACT US: OPT-OUT, CORRECTING, UPDATING OR DELETING INFORMATION

You may, to the extent such information is shared, opt out of sharing your information with third parties for marketing or other commercial purposes, as well as opt out of additional communication from us by contacting us at webmaster@MyPathUS.org. or at our mailing address.

You may review and request changes to your Personal Information that MyPath has collected, including the removal of your Personal Information from MyPath’s databases in order to prevent receipt of future communications or to halt receipt of our Site services, using the following options:
You can send your request via e-mail to: webmaster@MyPathUS.org

You can mail your request to the following postal address:

MyPath
2430 Mission Street
San Francisco, CA 94110

QUESTIONS?

If you have any questions about this Privacy Policy or about MyPath’s handling of your information, please contact webmaster@MyPathUS.org.

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers how MyPath treats PII that it collects and receives through this Website. PII is information about you that is personally identifiable (e.g., your name, address, e-mail address, credit card information and phone number) and not otherwise publicly available.

PERSONALLY IDENTIFIABLE INFORMATION PROVIDED BY YOU

Except as described in this Privacy Policy, MyPath only collects your PII through this Website when you choose to provide such information, such as when you sign up as a Website user, use the “Contact Us” feature or submit applications related to MyPath’s programs and services.

We may use your PII and related data for the following general purposes: (i) to provide, administer and improve our Website(s) and our services, (ii) to better understand your needs and interests, (iii) to fulfill requests you may make, (iv) to personalize your experience, (v) to provide program and service announcements, (vi) to provide you with further information and offers from MyPath and our affiliates, (vii) apply for financial grants, receiving donation and reporting to current and prospective donors, and (viii) to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

Disclosures to Certain Third Parties

MyPath may share your PII and related data under confidentiality agreements with other companies that work with, or on behalf of, MyPath to provide products and services. These companies may use your PII to assist MyPath in its operations, and to evaluate the MyPath services. These companies may share your information with third parties as required to provide you with the products and services you request (e.g. with the financial institution with whom you apply for an account in connection with a MyPath program). These companies do not, however, have any independent right to share this information. You will always have the ability to opt out from receiving information from MyPath as well as from said third parties.

Disclosures Under Special Circumstances

Business Transfers

DATA RECEIVED FROM THIRD PARTIES

In connection with your use of the MyPath Website, we may receive information about you from third parties, such as our community partners and financial partners. This information may not refer to you personally (i.e. it may be anonymized using an id number), or it may include personally identifiable information about you. This information may include your contact and registration information, demographic information, and your financial information (for example your deposit and withdrawal history and your purchase and use of financial products). We may combine your PII with this data for use as set forth in this Privacy Policy.

AUTOMATICALLY COLLECTED INFORMATION AND ANONYMOUS INFORMATION

Aggregated and Anonymized Data.

MyPath collects aggregate data regarding the use of our Website and associated services, and may also count, track, and/or aggregate visitors’ activity into MyPath’s analysis of general traffic-flow at the Website. To these ends, MyPath may merge information about you into aggregated group data. In some cases, MyPath may remove personal identifiers from PII and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with MyPath’s affiliates, business partners, service providers and/or vendors, and may be published as part of our, and our partners, research findings; if it does so, MyPath will not disclose your individual identity (except as you otherwise consent).

MyPath may also collect, use and disclose other non-personally identifying information that you provide (e.g. your expenses, purchases, income, savings goals and descriptions of your experiences with our community and financial partners and the MyPath program). We will take reasonable steps to ensure that such information is aggregated or anonymized so that your identity is not revealed. If this information is combined with your PII it will be used solely as set forth in this Privacy Policy.

Web Server Logs and IP Addresses.

An Internet Protocol (“IP”) address is a number that automatically identifies the computer/machine you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. MyPath may use IP addresses to conduct website analyses and performance reviews and to administer the Website.

Cookies and Web Beacons.

Cookies are pieces of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Many websites use cookies as a standard practice to provide useful features when a user visits the website and most web browsers are set up to accept cookies. MyPath uses cookies to improve your online experience when visiting the Website. You can set your browser to refuse cookies, but some portions of the Website may not work properly if you refuse cookies. Some of the Website’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of websites. Some web beacons may be unusable if you elect to reject their associated cookies. We may also use clear GIFs (or similar technology) in our e-mail communications to document who has opened or responded to our communications.

Demographic Information.

MyPath recognizes that certain User Information of a key demographic nature (e.g., race, age, gender, national origin, income), while not PII, is still of a sensitive nature to users. As a general matter, MyPath does not collect such information about you through the Website. However, we, or our community partner, may collect such information from you when you register for a MyPath program. In recognition of the sensitive nature of such information, in the event MyPath comes into possession of such information, whether through your voluntary submission of such information in response to a special feature on the Website or by receiving such information from any of our business partners, such information shall, when coupled with any of your PII, itself be deemed to be PII and treated MyPath as such.

SECURITY

MyPath understands that storing our data in a secure manner is essential. MyPath stores personal information and other data using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Please note, however, that while MyPath has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from this Website or via e- mail cannot be guaranteed.

DONATIONS

If you donate money to use from our Website, we request that you provide your name, email address, billing address, credit card information, telephone number and other information necessary to complete the transaction. We do not collect or store your full credit card information (although we may store the last four digits for verification purposes). The service provider who manages our donations (or credit card processing service provider) may collect and store full payment card information from you to process your donations.

TESTIMONIALS

LINKS TO OTHER WEBSITES

You may be able to access certain information related to third parties at the Website, or via links, banner ads or clickthroughs from the Website, including certain links to co-branded or other affiliated sites. Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including such sites’ use of any information. MyPath recommends reviewing those websites’ privacy policies individually.

SOCIAL MEDIA WIDGETS

Our Website may include social media features, such as the Facebook “like” button and widgets, such as the “share this” button. These features may collect your PII and track your use of the Website. These social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing such functionality.

CHILDREN’s PRIVACY PROTECTION

Under Age 13

MyPath understands the importance of protecting children’s privacy in the interactive online world. This Website is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any PII to MyPath and/or the Website.

Under Age 18

Minors under 18 years of age may have the PII that they have provided to MyPath while using this Website deleted by sending an e-mail to webmaster@MyPathUS.org requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your PII does not ensure complete and comprehensive removal of that data from all systems.

RESPONSE TO “DO NOT TRACK” SIGNALS

CORRECTING, UPDATING OR DELETING INFORMATION

You may review and request changes to your PII that MyPath has collected, including the removal of your PII from MyPath’s databases in order to prevent receipt of future communications or to halt receipt of our Website services, using the following options:

You can send your request via e-mail to: webmaster@MyPathUS.org

You can mail your request to the following postal address:

MyPath
2430 Mission Street
San Francisco, CA 94110

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on this Website or in such other manner as we deem reasonably likely to reach you. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. You assume the responsibility of periodically reviewing this Privacy Policy and MyPath encourages you to refer to this Privacy Policy on an ongoing basis so that you understand the current Privacy Policy. Unless stated otherwise, the most current Privacy Policy applies.

QUESTIONS?

If you have any questions about this Privacy Policy or about MyPath’s handling of your information, please contact webmaster@MyPathUS.org.