Legal

Privacy Policy

Introduction

Welcome to The Tow Foundation’s (the “Foundation”, “us”, “we”, “our”) Privacy Policy (the “Policy”). In this Po­licy, we explain what personal data we collect, how we use and protect your personal data, with whom we may share it and the rights that you may have in connection with it. This Policy is incorporated into our Website Terms & Conditions. This Policy applies to personal data we collect, including through our website www.towfoundation.org (the “Website”), other websites we operate, our events and programs registrations, mobile applications, online portals, surveys, job applications, applications, and any other point of collection (collectively, the “sites”). In addition to applicable laws, additional policies disclosed to you at the time of collection may also apply (e.g., in connection with a specific event or program). By using our sites and/or by providing personal data to us (by any means, whether directly to us when applying for employment, grants, attending events or programs, on our website, or in any other interaction with the Foundation), you consent to our use of the personal data in accordance with this Policy. 

By visiting our Website, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website.

How to contact us

If you have any questions about this Policy or if you have a disability that prevents you from accessing this Policy electronically in this format and require it to be provided in an alternate format (e.g., audio, large print), you may contact us by sending an e-mail to legal@towfoundation.org or writing to:

The Tow Foundation, Inc.
50 Locust Avenue
1st Floor
New Canaan, CT 06840
ATTN: Legal Counsel

Subject to requirements under applicable laws, you may also contact us with questions about your personal data handled by us at legal@towfoundation.org with PRIVACY INQUIRY in the subject line.

Data we collect 

We collect personal data from you when you voluntarily provide it to us, and when you visit our sites, certain information is automatically collected from you (subject to applicable consent requirements). We collect personal data that you provide to us in various ways including online, via one of our portals, by telephone, and offline, including when you visit our facilities in person as a guest of the Foundation. The types of personal data we may collect from you are described below.

Data you provide directly to us

Contacting Us – When you contact us via phone, email or in person, for any reason including when you: submit a job inquiry; interact with us regarding applications, programs, activities or events; participate in surveys, panels or research; register for and participate in our programs, activities, initiatives and events; interact with our sites; or in conjunction with any other place where you knowingly volunteer information to us, we may collect the following types of data from you:

• Name, address, date of birth, email address and telephone number;
• Organization name, address, email address and telephone number;
• Survey responses;
• Demographic information
• Preferences, information about a disability or requests for accommodations to the extent disclosed to us; and
• Other information or content that you may choose to provide.

Website Visits – When you visit the Website, or sign up for our email newsletter via the Website, we may collect the following types of data from you:

• Name and email address; and
• Any other information that you may choose to provide.

Employment Applicants – If you apply for a position with the Foundation you may be asked to create an account with the Foundation or a portal managed by our recruiting firm and we may collect the following types of data during the application process:

• Name, address, email address, and telephone number;
• Resume, work history, work authorization status, education, skills, professional licenses, permits or certifications and references;
• Optional demographic information, such as gender identity, race/ethnicity, sexual orientation, religious affiliations; and
• Any other information you choose to provide during the application process.

If we offer you employment, you may be required to complete a background check and other screenings prior to beginning work, as permitted or required by applicable law.

Grant Applicants – If you apply for a grant from the Foundation, or if your employer or organization includes information about you in a grant application or annual report, we may collect the following types of data during the application process:

• Name, address, date of birth, email address, telephone number;
• Resume, work history, qualifications, education, skills, professional licenses, permits or certifications and references;
• Tax identification, bank account information for payments;
• Demographic information, such as gender identity, race/ethnicity, disability, sexual orientation; and
• Any other information you choose to provide during the application process.

Suppliers – If you are a third-party who provides products or services to the Foundation you may be asked to create a accounts on our portals and we may collect the following types of information from you:

• For individual suppliers: name, address, email address, telephone number, citizenship information, visa information, W-9, tax identification numbers, bank account information for payments.
• For organizations that are suppliers: organization name, address, email address and telephone number, W-9, tax identification numbers and bank account information for payments; and
• Other information that you may choose to provide.

Data automatically collected

When you interact with our sites, and subject to applicable consent requirements, we may automatically collect data that is linked to your computer or device, including:

• IP address, the type of browser or device that you are using, referring and exit pages, domain and other system settings and operating system; and
• Information regarding how you interact with the sites including the date and time of your visits, pages visited and links clicked. 

Consistent with most websites, and subject to applicable consent requirements for non-essential cookies, we use cookies and pixel tags to collect such activity information. Cookies are small text files used to collect information and pixels are transparent images that allow us to understand how users interact with our Website.

The cookies we use fall into three categories.

Type of Cookie	What it does
Necessary	Necessary cookies help make the site usable by enabling basic functions like page navigation and access to secure areas of the site. The site cannot function properly without these cookies.
Functional	Functional cookies record information about the choices you have made and allow us to tailor the site to you. These cookies mean that when you continue to use or come back to the site, we can provide you with our services as you have asked for them to be provided.
Analytics	Analytics cookies help us understand how our visitors use our sites. These cookies can provide us with information to help us understand which parts of the sites interest our visitors and if they experience any errors. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how visitors reach the sites. We may receive reports based on the use of these technologies.

Unless otherwise required by law, necessary cookies will be placed when you visit the sites and the other cookies will be placed where you provide opt-in consent. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If, however, you disable or refuse cookies, please note that some parts of the sites may become inaccessible or not function properly. Please note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

Information we receive from third parties

We may receive the following information from third parties:

• Information about your participation in programs, events, activities or social media (e.g., from event organizers providing services to us, event organizers unaffiliated with the Foundation, program leaders or participants, including in annual reports, videos and photographs);
• Information from publicly available sources;
• Service providers, consultants, or vendors providing services to the Foundation;
• Work and qualification information and/or contact information submitted by your employer or organization in connection with a grant application or reporting;
• Contact information submitted by your employer or organization in connection with their relationship to the Foundation;
• Employment verification (from your previous employer if you provide us with contact information on a grant application or in connection with applying for a position);
• Education information (from your previous academic institutions if you provide the names of institutions on a grant application or in connection with applying for a position); and
• Reference information (from any references you provided on a grant application or in connection with applying for a position).

How we use the data we collect

We may use the personal data you provide us:

• To send email newsletters;
• To process your grant applications;
• To administer or run programs, grants, or events;
• To disburse supplier payments;
• To disburse grant funds;
• To respond to your inquiries and/or requests;
• To improve our programs and the efficacy of our grantmaking and operations
• To recommend you or your organization for other grants, or other opportunities;
• To solicit grant applications;
• For compliance, fraud monitoring and security;
• To provide you information relevant to the programs, grants, or other activities we think might interest you or your organization;
• To process your employment application, including assessing your qualifications for a job, conducting reference checks, communicating with you about your application and conducting background checks if we offer you a position, as permitted or required by applicable law;
• To send you information regarding changes to our terms and policies; and
• For other purposes disclosed at the time of collection or otherwise compatible with our charitable purposes and applicable law.

We may use data that we collect automatically from our sites:

• To administer, maintain and improve our sites;
• To understand how you found out about us and what services and products may interest you so we can improve our products and services and deliver to you the type of content, features and promotions that you are most relevant to you;
• To understand the demographics of our site visitors;
• To perform data traffic, e-commerce and other trend analyses; and
• For fraud monitoring and prevention and other security purposes.

We may combine this information with data we receive from publicly available sources.

Additionally, we may use your information as we believe to be necessary or allowed: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity; and/or (i) other legitimate purposes such as conducting investigations or responding to governmental or other regulatory requests for information or investigations and for dispute management purposes.

It is always your choice whether to provide your personal data. However, some personal data must be provided to participate in certain programs, activities, or events (such as to sign up for a newsletter, apply for a job, or register to participate in one of our events), so the decision not to provide information might limit or eliminate such functions of our sites or your ability to participate in such programs, activities, or events. Please do not disclose more personal data than is requested.

To the extent required by applicable laws, we will seek your separate consent for collecting and processing your sensitive personal data. “Sensitive personal data” has different definitions under applicable law, but in general includes, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, social security number, driver’s license, or other government issued identification number, financial account, including credit card information. Please do not provide the Foundation any sensitive personal data unless specifically requested and necessary for your interactions with the Foundation.

Sharing your data

We do not sell your personal data. However, we may share your personal data in the following circumstances:

Within the Foundation: We may share your personal data within the Foundation..

• Our vendors and service providers: We use a variety of vendors and service providers that help us with our administrative, operational and logistical activities such as maintaining our sites, email and document management, shipping, payment processing, managing our institutional and individual relationships and facilitating programs or events. We require these companies and individuals to use your information only as necessary to provide the applicable services to us.
• Organizational and funding partners, grantees, co-sponsors, co-hosts: We may also occasionally share your personal data with our organizational and funding partners, grantees, or co-sponsors or co-hosts of our programs, activities, initiatives, and events from time to time. Although our treatment of your personal information is governed by this Policy, our partners’, grantees’, co-sponsors’, or co-hosts’ treatment of your personal information will be governed by their respective privacy practices.

• Legal requirements: We may also disclose your personal data when we reasonably believe it is required by law, subpoena or other legal process, including to meet national security or law enforcement requirements, as well as to honor user access rights, as applicable.
• Protection of rights: We may transfer personal information to protect our rights, privacy, safety or property, including our employees, contractors and agents, when we are required or permitted to do so by law.
• At your request: We may transfer information to a third party if you request us to do so.
• Fraud detection: We may disclose information when we believe in good faith that it is necessary to investigate fraud
• Marketing and Promotion: notwithstanding the above, your personal data, including mobile phone number, will not be shared with third parties for marketing or promotional purposes and your consent to use of such data will not be shared with third parties.