Israel’s Fallen Heroes Fund Online Privacy Notice

1. Personal Data We Collect And Use

We collect Personal Data about you directly from you, automatically from your devices, and from third parties. Where we collect data about you from one of these sources, we have outlined the purposes for its collection and the Personal Data collected for that purpose below. 

2. Cookies And Similar Technologies

When you visit our Sites or use our Services, we and our business partners and vendors may use cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”). Tracking Technologies are used to recognize you as a User and to customize your online experiences, the Services you use, serve you online content and advertising; measure the effectiveness of advertisements and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services.  Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

To learn more about cookies and how we use them, please read our Cookie Notice.

Do Not Track Signals.  Your browser settings may allow you to automatically transmit an opt-out preference signal or “Do Not Track” signal to online services you visit. Like many online services, we do not currently respond to Do Not Track signals.

Analytics and Advertising Tracking Technologies.  You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. 

3. Marketing Communications

If IFHF sends you marketing communications, you can opt out of receiving those and other communications from IFHF at any time by following the instructions provided in e-mails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other communications may continue. Even if you opt out of receiving promotional communications, IFHF may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or IFHF’s ongoing business relations. 

4. De-Identified and Aggregate Data

IFHF may de-identify and aggregate data for its business purposes, including but not limited to, to improve the features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. IFHF may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in de-identified form and not attempt to re-identify the data for any business purpose.  

5. How We Share Personal Data

We may share information about you to third parties as indicated below:

• With merchants with whom you transact on our Service: We may share Personal Data and payment information with the merchants with whom you transact on our Service.
• With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf.  These third-party service providers may, for example, provide you with Services, assist in processing transactions, allow us to send you advertisements for our Services, provide customer support, send email marketing on our behalf, etc. We do not sell your information to these third-party service providers.
• In aggregated, de-identified form to provide data to third parties for our benefit: We may provide aggregated statistical data to third-parties for our own analytics and business purposes.  This data will not personally identify you or provide information about your specific use of the Sites or Services.  We do not share your Personal Data with third parties for their marketing purposes without your consent.
• With the other parties to transactions when you use the Services, such as payment processors and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes payment processors and their service providers. The information might include:
  • Personal Data, payment information and account information necessary to facilitate and/or authenticate the transaction;
  • information to help resolve disputes and detect and prevent fraud; and
  • aggregated data and performance analytics to help us and our merchants better understand user behavior and to help us enhance user experiences. 
• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:
  • if we need to do so to comply with a law, legal process or regulations;
  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Us;
  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
  • to protect our property, Services and legal rights;
  • in connection with shipping, payment and related services for purchases made using a Service;
  • to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
  • to banking partners/payment processors as required by card association rules;
  • to credit reporting and collection agencies;
  • to companies that we plan to merge with or be acquired by; and
  • to support our audit, compliance, and corporate governance functions.
• With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account communication with a third-party account or platform. 
• Affiliates and Subsidiaries: We may share your Personal Data with our different affiliates and subsidiaries.  If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information. 
• Marketing: We may share your Personal Data to deliver marketing communications to you. Absent your consent (which may be by means of opt-in, or a third-party interaction described in the next bullet point), however, IFHF will not share your Personal Data with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with changes in business structure or ownership (defined below). 
• Social Media: Certain pages of our Websites might include social media features, such as the Facebook “Like” button, and widgets, as well as the ‎‎“Share This” button or interactive mini-programs that run on our Website‎. These features might require us to implement cookies, plug-ins, or application programming interfaces (APIs) provided by such social media platforms to facilitate the communications and features. When you provide us with information through these platforms, the information also becomes subject to their privacy statements. In addition, by choosing to use any third party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third party platforms. As a result, we cannot be responsible for any use of your information or content by a third party platform, which you disclose at your own risk. We encourage you to review the privacy statements of these platforms.
• Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements. 
• Changes in Business Structure/Ownership: We may disclose or transfer your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of IFHF’s business, assets, or ownership interest (including any bankruptcy or similar proceedings). 

We do not sell any individual’s Personal Data, including children’s Personal Data, nor do we share that Personal Data with third parties for those parties’ commercial use.  

6. Children’s Privacy

Our Services are not intended for use by anyone under the age of eighteen (18).  In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request or solicit Personal Data from anyone under the age of eighteen (18) nor will we knowingly allow anyone under the age of eighteen (18) to create a user account.  In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.  We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services. 

7. Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.  

8. How We Protect Your Personal Data

We strive to take appropriate security measures to help safeguard your Personal Data from unauthorized access and disclosure.  For example, only authorized employees are allowed to access Personal Data, and they may only access it for permitted business functions. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration.  The security measures include firewalls, data encryption, access controls to our data centers, and information access authorization controls.   

While we are dedicated to securing our systems and Services, we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it.  Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.

You are responsible for securing and maintaining the privacy of your password(s) and Account/profile information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account communication that you have authorized.

9. California Rights (Shine the Light Notice)

California residents have the following rights regarding disclosure of your Personal Data to third parties for their own direct marketing purposes:

We provide California residents with the option to opt-in to sharing of “Personal Data” as defined by California’s “Shine the Light” law with third parties, other than with our affiliates, for such third parties’ own direct marketing purposes. We do not share Personal Data with non-Affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-Affiliate third parties for their direct marketing purposes by contacting using the methods in the “Contact Us” section below. Requests must include “California Marketing Privacy Rights Request” in the first line of the description and include your name, email address, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address.

10. European Disclosures

This section of our Privacy Notice applies to individuals located in the European Economic Area (EEA) and the United Kingdom (UK).

International Data Transfers

IFHF primarily stores the Personal Data we collect in the United States.  To facilitate IFHF’s  global operations, staff who work for IFHF and/or our service providers may transfer and access such Personal Data from locations around the world.  This will involve transferring your Personal Data outside the EEA and the UK.  We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Notice.  Whenever we transfer your Personal Data out of the EEA or the UK, we will ensure one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission; or
• We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe; or
• We will ensure there is some other protection in place which has been approved by the European Commission as giving Personal Data the same protection it has in Europe.

Legal Bases for Processing

This section describes some of the legal bases we rely on to process your Personal Data. We may process your Personal Data for more than one legal basis depending on the specific purpose(s) for which we are using your Personal Data, including the following legal bases:

• Contracts.  Where we need to perform the contract we are about to enter into or have entered into with you, including to provide you with services.
• Legitimate Interests.  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where IFHF relies on legitimate interest to process Personal Data:

• IFHF has a legitimate interest in processing Personal Data relating to our existing customers in order to manage our business relationship and provide communications and information that may be of interest, including marketing communications.
• IFHF has a legitimate interest in using cookies as outlined in its Cookie Notice.
• Legal Obligations.  Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data.

Privacy Rights

Europe’s privacy laws require that we disclose to you the privacy rights that you have regarding Personal Data. We have defined the various privacy rights below. 

• Access:  You may have the right to access your Personal Data and to receive a copy of your information. 
• Data Portability:  You may have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Deletion:  You also may request that we erase your information. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will explain to you, if applicable, at the time we process your request.
• Object to Processing:  You may have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request Correction:  You may have the right to request correction of the Personal Data that we hold about you. This enables you to ask that we correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
• Restrict Use:  You may have the right to restrict the use of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Withdraw Consent:  You may have the right to withdraw consent where we collected or processed your Personal Data based on consent, and no other legal basis for processing exists. 

Right to Make a Complaint: 

If you are in the EEA, you have a right to complain to us about our Personal Data practices, and you can do so using one of the methods in the Contact Us section below.  We will evaluate your complaint and will contact you if we need further information to resolve it.  In addition, you may have the option of complaining to a government authority if you believe we have not processed your Personal Data in compliance with the laws and principles that apply in your home country.  If you would like to make a complaint to an authority, you may contact you country’s supervisory authority.

How to Make a Request:  If you would like to make a request, please use one of the methods in the “Contact Us” section of this Privacy Notice.  You will need to provide your first and last name, and your email address.      

11. Changes To This Notice

We reserve the right to change this Notice prospectively effective upon the posting of the revised Notice and your use of our websites indicates your acknowledgement of the Notice posted at the time of use. However, should we update this Notice, we will post a new version online, and will notify you if the Personal Data processed about you will be materially different than that which was represented to you at the time it was collected. To the extent any provision of this Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

12. Contact Us

For questions regarding this Privacy Notice or to make a request pursuant to this Notice related to your Personal Data, contact us using the email provided below:

Email: info@fallenh.org