TELEMAH - Privacy Policy

TELEMAH PRIVACY POLICY

Last updated April 30, 2025

This privacy notice for TELEMAH ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@telemah.org.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with TELEMAH and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law, particularly in relation to program participation (e.g., for youth beneficiaries).

Do we receive any information from third parties? We generally do not receive information from third-party data brokers, but may receive information from partners (like schools or payment processors) with your consent or as necessary to provide Services.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, such as service providers, payment processors, or legal authorities if required.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at contact@telemah.org. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS? (If applicable)
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? (If applicable)
  13. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? (If applicable)
  14. DO WE MAKE UPDATES TO THIS NOTICE?
  15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our programs and Services, when you participate in activities on the Services (such as making a donation, signing up for a newsletter, or applying for a program), or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the programs and features you use. The personal information we collect may include the following:

  • Names
  • Phone numbers
  • Email addresses
  • Mailing addresses
  • Usernames (if applicable)
  • Passwords (if applicable)
  • Contact preferences
  • Billing addresses (for donations)
  • Debit/credit card numbers (processed by our payment processor)
  • Information related to youth program participation (e.g., age, school, parental consent if minor)

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may process certain sensitive information. For our youth programs, this might include details relevant to participation, such as dietary needs for events or information to ensure program suitability. We aim to minimize collection of sensitive data.

Payment Data. We may collect data necessary to process your payment if you make donations, such as your payment instrument number (e.g., a credit card number), and the security code associated with your payment instrument. All payment data is stored and processed by our third-party payment processor(s) (e.g., Stripe, CharitySpurse). You may find their privacy notice link(s) on their respective websites.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many organizations, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy (if we have one, or refer to section 5 below).

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. (If applicable)
  • To deliver and facilitate delivery of services to the user. This includes managing our youth programs, processing donations, and providing requested information.
  • To respond to user inquiries/offer support to users.
  • To send administrative information to you. Such as information about changes to our terms, conditions, and policies.
  • To fulfill and manage your donations and event registrations.
  • To request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications (if you have opted-in). You can opt-out of our marketing emails at any time.
  • To protect our Services. This includes efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
  • For data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services, programs, marketing, and your experience.
  • To comply with our legal obligations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may need to share your personal information in the following situations:

  • Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts.
  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our organization by another entity.
  • Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • With Your Consent: We may disclose your personal information for any other purpose with your consent.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and similar tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice (if available, otherwise provide a general statement here).

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you. (This section is conditional on TELEMAH offering social logins).

Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us [or other relevant period, e.g., 7 years for financial records].

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We may collect data from minors (ages 15-17) with appropriate consent for participation in our youth programs. We do not knowingly solicit data from or market to children under 13 years of age without parental consent.

TELEMAH's programs are targeted at youth aged 15 to 21. For participants under the age of 18 (or the age of majority in their jurisdiction), we will seek parental or guardian consent before collecting personal information, where required by applicable law. If we learn that personal information from users less than 18 years of age (or applicable age of consent) has been collected without the requisite consent, we will take reasonable measures to delete such data from our records promptly.

If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent, please contact us at contact@telemah.org.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time (if applicable).

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. (This section is conditional on specific applicability to TELEMAH).

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

13. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information. (This section is conditional on specific applicability to TELEMAH).

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data include the right to:

  • Be informed whether or not we are processing your personal data
  • Access your personal data
  • Correct inaccuracies in your personal data
  • Request deletion of your personal data
  • Obtain a copy of the personal data you previously shared with us
  • Opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

TELEMAH does not currently "sell" personal data as defined by the CDPA, nor do we engage in targeted advertising or profiling that produces legal or similarly significant effects using personal data from consumers as defined by the CDPA.

To exercise any of your rights, please contact us at contact@telemah.org.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" or "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@telemah.org or by post to:

TELEMAH
North Carolina, United States
(Specific P.O. Box or address if available for official correspondence)

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at contact@telemah.org. We will respond to your request within a reasonable timeframe.