Partners in Torah Privacy Policy

(Revised June 8th, 2020)

Please read this Privacy Policy carefully. To protect your privacy and help you to make informed choices, this Privacy Policy explains our information practices, how you can choose how we use your data, and your rights regarding your data.  If you do not agree with our policies or practices, regarding our treatment or use of your information, your choice is not to use the PartnersinTorah.org website (“Site”). 

In summary, we will only use your information:

• To optimize our website performance;
• For our legitimate business purposes as set forth in our Terms of Service  [LINK] ; and
• With your consent

This is explained in more detail below.

By accessing or using this Site, and/or accepting our Terms of Service  [LINK] , you agree to this Privacy Policy. You must also agree to our Terms of Service  [LINK]  in order to use the Service provided by our Platform.  We may change this Privacy Policy from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you have any inquiries about this Privacy Policy or how we use your personal information, please contact us at  support@PartnersinTorah.org .

This Privacy Policy applies to the website and mobile applications owned and operated by Partners in Torah, Inc.  (“PIT”). We refer to these websites (the “Site”) and mobile applications (the “Apps”) collectively as the “Service,” “Services,” or “Platform” which includes the information, goods and/or services made available to users of the PIT Network, relevant news, content, applications, and sponsored programs, advertising, email or other communications, and discussion forums. References to “we” or “us” mean PIT.

Contents

1. About us
2. Children Under the Age of 13
3. What information we collect and how we collect it
4. How we collect Personal Information
5. How we use Personal Information
6. Why we use Personal Information
7. How we share Personal Information
8. International transfers
9. Data security
10. How long we keep Personal Information
11. Third party links
12. Accessing and correcting your information
13. Legal Disclosures
14. Changes to this policy or your data
15. Contacting Us
16. General Data Protection Regulation (“GDPR”) Addendum and California Consumer Privacy Act

1. About Us

This website PartnersInTorah.org/ (the “ Site “) is operated by Partners in Torah Inc® (also referred to as the “ PIT “, “ we “, “ us ” and “ our “), Partners in Torah is a company organized under the laws of the State of New Jersey and is a data controller.

The PIT Platform provides users with customizable one-on-one Torah-related mentoring, teaching and learning experience on their schedule. Our experience has shown us that such personalized learning leads to lifelong friendships and builds continuity within the Jewish community, expanding our connection with more than 3,700 years of Jewish culture.

If you do choose to use the Services, you must agree to the PIT’s Terms of Service (“ToS”)  [LINK]  and which together with our Privacy Policy form the contract between us and you. By accepting our Privacy Policy and ToS  [LINK] , you also confirm that you have read, understood and accepted this Privacy Policy. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States, and in Israel where we are located. Except as otherwise noted in this Privacy Policy, PIT is the data controller responsible for the processing of your personal information as described in this Privacy Policy.

PIT’s offices are located at:

Partners in Torah

228 Aycrigg Avenue

Passaic NJ 07055

You may contact us about any questions you have regarding this Privacy Policy at either our postal address above, or by e-mail directed to support@PartnersinTorah.org.

1. Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may use or direct any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13,  do not  use or provide any information on the Site, use any of its features, subscribe to our mailing list, use any of the interactive links or post anything on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.  If we learn we have collected or received personal information from a child under 13 without verified parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, in connection with the access or use of this Site, please contact us at  support@PartnersinTorah.org

1. What Information We Collect and How We Collect It.

The type of information we collect depends on how you use the Site and how you interact with us. “Personal Information” means any data which can be associated with you as an individual, either directly or indirectly, and is collected on a voluntary basis from you.

The Personal Information we collect via the Site may include:

• Identity information, such as your name, organization name and position, postal address, e-mail address, telephone number, biographical data, social media links, and/or any other identifier by which you may be contacted online or offline.
• Technical data, such as your internet protocol (IP) address, device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and/or platform, and other technology information relating to the devices you use to access or transact business with the Site.
• Usage data, which includes information about your use of the Site, and any communications we may receive from you.
• Marketing and communications data, including your preferences in terms of receiving marketing and other communications from us.
• Special Categories of Personal Information, PIT stores and transmits “special categories” of Personal Information, which may include pictures or multimedia recordings you submit, details about your age, gender, race or ethnicity, education, religious or philosophical beliefs, and political opinions. You understand and acknowledge that we must collect information under the “special categories” of personal information in order to provide you with the Services you signed up/are in the process of signing up for and we would not be able to perform these services without such information. You further expressly acknowledge and agree that PIT may store, transmit and use such information in the ordinary course of its business and mission to expand awareness of Jewish culture. You may request, subject to any legal requirements, that your Personal Information be deleted from our records at any time by contacting us at  support@partnersintorah.org . You understand and acknowledge that doing so might affect our ability to continue providing you with our services, as we might not have the information we need in order to do so.

1. How We Collect Personal Information

We collect information from you in two different ways.  

1. a) Personal Information you provide to us.

If you subscribe (sign up) to our mailing list, inform us of your marketing and communications preferences, or post or submit any text, comments, photo, video, communication, information, or other material (“User Content”) on or through the Site, you will provide us with your identity, contact information, and IP address. This data is collected through your voluntary submissions. You will also provide us with Personal Information when you correspond with us. We will track basic analytics (for example, open rates and click throughs) and may embed tracking codes in our regular daily email correspondence. 

1. b) Personal Information we collect automatically as you navigate the Site.

The Site may use third party advertising providers to display advertisements based on your visits to the Site and other web sites you have visited, which allows targeted advertisements to be delivered to you for products and services about which you may be interested. The Site also uses a third party traffic measurement service to analyze how visitors use the Site,  Third party advertising providers and advertisers (whose ads are displayed via the advertising provider) may use cookies, web beacons, embedded scripts (described below) or other similar mechanisms to automatically collect web site usage information, to, among other purposes, deliver advertisements, in which you might be interested, prevent you from seeing the same advertisements too many times, and to conduct research regarding the usefulness of certain advertisements to you. Cookies, web beacons and embedded scripts and other similar mechanisms used to collect web site usage information from advertising providers and advertisers, are governed by their respective privacy policy and not this Privacy Policy. We do not, however, share any Personal Information with these third parties in connection with the services they perform on the Site.

In addition, as you use the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Analytics to help us analyze user habits while visiting our Site. The data gathered from cookies may be transmitted to Google servers outside the United States. The information will be used by the analytics provider for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of PIT. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

We may use cookies individually or in combination, including but not limited to the following:

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, you can remove cookies from your computer through the browser settings. You may set most browsers to notify you if you receive a cookie, or to block cookies with your browser. Management of cookie settings varies from one browser to another, and the “Help” menu of your web browser should provide instructions on how to manage cookies. You may also prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/ . Please note however that doing so may affect, limit or degrade your ability to use of some features on the Site and other websites. 

1. c)  Information You Provide to Third Parties .  

If you use the Site’s interactive features to communicate with other users, or to access a third party site that is linked to the Site, the other user(s) or third party site may provide us, directly or indirectly with your Personal Information.  For example, another user may post your email address and name, or a third party website may report a purchase you made from that site.

1. d) Mobile Device Information 

The mobile version of the Platform (where and when available), may collect certain mobile device identifier information, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

1. How We Use Personal Information 

The specific uses of Personal Information we collect will depend on factors including the nature of the information, the purpose and context of the collection, and applicable law. Uses include:

• Providing our services and programs.
• Processing, evaluating, and responding to your requests, inquiries, and applications.
• Contacting you (such as by text message, email, phone calls, mail, push or messages on third-party platforms) about programs, products, services, companies and events, sponsored by us and others, that you have registered for or that we think might interest you.
• Determining appropriate advertising channels and venues and to place ads on such channels and venues, including placing advertising on social networking sites. Measuring and managing the effectiveness of our advertising and marketing.
• Conducting surveys, and performing market research and data analytics. 
• Creating aggregated or otherwise anonymized data, which we may use and disclose without restriction.
• Verifying your identity, protecting against and preventing fraud, unauthorized activity, claims and other liabilities, and managing risk exposure. 
• Complying with and enforcing applicable legal requirements, industry standards and our policies and terms, such as our terms of use and contract of carriage.
• Operating, evaluating, and improving our business in other ways.
• Keeping our records up to date through your identity, contact and usage information.
• Use of your technical information to 
  • Make the Site available, to improve it, to conduct system maintenance, support, troubleshooting, reporting and to host data;
  • Ensure that the Site is secure;
  • Analyze how users interact with the Site; and
  • Address technical issues you may experience with the Site.

Investigations . We may use your information to detect, investigate and defend against fraudulent or unlawful activity and violations of our Terms of Service  [LINK]

1. Why We Use Personal Information

1. a)  You have given us permission to do so.

     If you subscribe to our mailing list, we will send you updates and  marketing information  that you have consented to receive. Similarly, if you contact us with a question or comment, we may need your contact, identity, technical and/or usage information to respond.

1. b)  We have a legitimate interest (reasonable business purpose) for doing so.

We will use your information for our legitimate business reasons where doing so will not unduly affect your rights, including the use of cookies and personal data we collect through account registration (email, phone number, address) to improve the website and for marketing and advertising services. This includes but may not be limited to email, text, SMS, social media, and programmatic advertising. We may also use any or all of the information above to administer and manage our business in general as required by law, regulation, or best business practices. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

1. d)  We need to comply with legal or regulatory obligations.

In certain circumstances, we may need to retain or use your data to comply with laws or regulations.

1. How We Share Personal Information

1. We may share your information with our trusted third party service providers (including information technology providers such as website and mailing list hosts). We may provide your account information to companies that help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. When we share your information with our service providers, we will take commercially reasonable steps to help ensure that your data is kept secure and used only in accordance with this notice.
2. We may share Personal Information when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government investigation or inquiry), to detect, investigate and defend against fraudulent or unlawful activity and violations of PIT’s Terms of Service   [LINK] , to enforce or apply our Terms of Service   [LINK] or other agreements, in the context of a reorganization, or to protect the rights, property, or safety of PIT, our employees, users, or others.
3. We will also share some personal data with third party partners to assist with improving the user experience and marketing purposes (Salesforce, Google, Facebook, Twitter, etc.).
4. When you contribute to a public area or feature of our Sites, the information that you submit or post will be made available to the general public.
5. We may transfer personal data in connection with a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation or reorganization, or as part of pre-transaction review in relation to these transactions.  Whether the recipient of data in these cases will handle the data pursuant to this Privacy Policy depends on applicable law and other factors. 
6. Some third parties’ embedded content or plugins on Sites may allow their operators to learn that you have visited or interacted with us, and they may combine this information with other, identifiable information they have collected about your visits to other websites or online services. These third parties may handle this information, and other information they directly collect through their content and plugins, pursuant to their own privacy policies.
7. Your Personal Information may be shared with other organizations that have the same or similar mission to PIT, but only if you were referred to our services by such organizations . The Personal Information shared with such organizations, will be handled by them in accordance with their own terms and policies. If applicable to you, you are encouraged to review the terms of the relevant organization.

1. International transfers

This Site is hosted on servers located in the United States and Israel. PIT will endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR,” when and as applicable) to which we may be subject.

General Data Protection Regulation

General Data Protection Regulation (“ GDPR ”) was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”).  Its purpose, with certain limitations and exceptions, is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the:

• Right of access: Individuals can ask for a copy of the Personal Information retained about them and an explanation of how it is being used.
• Right to rectification: Individuals have the right to correct, revise or remove any of the Personal Information retained about them at any time.
• Right to be forgotten: Individuals can ask to delete their Personal Information.  At your request, we will remove your contact information from the system, and we will not intentionally contact you again.
• Right to restrict processing: If an individual believes, for example, that their Personal Information is inaccurate or collected unlawfully, the individual may request limited use of their Personal Information.
• Right of portability: Individuals have the right to receive their Personal Information in a structured, commonly used and machine-readable format.
• Right to object: Where an individual decides that they no longer wish to allow their Personal Information to be included in analytics or to receive direct marketing emails or other personalized (targeted) marketing content at any time, the individual may opt out of use of their data for these purposes.

If you are a data subject falling under the scope of the GDPR, you can exercise the above rights. Please note that these rights are not absolute, and limitations/exceptions may apply in some cases.

In respect of transfers outside of the country, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your Personal Information; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield.

You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.

1. Data Security

The safety of your Personal Information is important to us, and we use various technical and organization measures to secure it.

We employ commercially reasonable encryption (TLS technology), data security, and intrusion prevention technologies to protect and secure all personal information in our possession. However, the transmission of information via the Internet is not completely secure, and unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Although we take commercially reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You acknowledge and agree that you are solely responsible for maintaining the security and confidentiality of your account username and password.

1. How Long We Keep Personal Information

We will retain your Personal Information only for as long as it is necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we processed the data and whether we those purposes may be achieved by another means, and the applicable legal requirements

1. Third Party Links

This Site may contain links to other websites whose information practices may be different than ours. Please consult all third party Sites’ privacy notices. We have no control over third party websites, and disclaim any and all responsibility and liability in connection with any information that you submit to, or permit to be collected by, such third party websites.

1. Accessing or Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page, or by sending an email to us at support@PartnersinTorah.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Service [LINK]. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

1. Legal Disclosures

We may need to share your data when we believe it is required by law or to help protect the rights and safety of you, of us or of others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations. In such circumstances, our only obligation to you is as follows: We will attempt to notify you through the contact information you have provided to us about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. Notwithstanding the foregoing, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

1. Changes to this Privacy Policy or Your Data

We may amend this Privacy Policy from time to time. We will post any update to this Privacy Policy on the Site. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during our relationship.  We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

1. Contacting Us

If you have general questions about your account or the Services, contact us at support@PartnersInTorah.org. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at support@PartnersinTorah.org or at the following address:

Partners in Torah

228 Aycrigg Avenue

Passaic NJ 07055

1. General Data Protection Regulation (“GDPR”) Addendum and California Consumer Privacy Act

If you are in the European Economic Area, and in addition to PIT’s Privacy Policy, you consent to our General Data Protection Regulation, (“GDPR”) policy shall apply in connection with our collection, use and processing of your Personal Information (as defined by the GDPR) that you provide to us in connection with your use of the PartnersinTorah.org web site (“Site”). 

Designated Countries. By visiting the Site and/or providing us with information, you acknowledge, agree and consent that your Personal Information (also referred to as “Personal Data”) may be processed for the purposes identified in the Privacy Policy and in this GDPR Addendum. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your information, you consent to such transfer. If you reside in the “Designated Countries,” as defined in the GDPR we will be the controller of your Personal Information provided to, collected by or for, or processed in connection with your engagement. We use the term “Designated Countries” to refer to countries in the European Union (EU), the European Economic Area (EEA), and Switzerland.

For purposes of our Terms of Service  [LINK] , Privacy Policy, and GDPR consent, “Personal Information” means information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information.

Clicking “I Agree” below, confirms your express consent to the processing of the Personal Information you provide to us for the purposes stated below. The central nature of our business is providing a platform for customizable one-on-one Torah-related mentoring, teaching and learning experience on users’ schedules. 

Accordingly, in order for you to register with us and use the Platform or the Site, you hereby acknowledge and agree that to the uses described above and the collection and processing of your Personal Information provided by you to us or to our data processor. 

How We Use Your Personal Information

We may use your Personal Information to provide you with Services as set forth in the Terms of Service and Privacy Policy, including personalizing the Services for you;

• Market our products and services to you that we believe may be of interest to you. For example, we allow advertisers to choose the characteristics of users who will see their advertisements and we may use the attributes we have collected to select the appropriate audience for those advertisements;
• Respond to your requests, resolve disputes and/or troubleshoot problems;
• Improve the quality of the Site and the Services; and
• Communicate with you about the Site and the Services.

We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.

Right to Withdraw

If you reside in, or are a citizen of a Designated Country (as defined above), you have the right to withdraw your consent at any time; provided that if such consent interferes with or causes us to violate a contract involving you, you agree to indemnify us for any damage or financial penalty incurred as a result of the withdrawal of our consent.

Right to Access

You have the right to access the Personal Information that we may hold about you and the purposes for which we are using it in a structured, commonly used and machine readable format. We may ask for proof of your identity. On receipt of such a request, we will endeavor to respond to you as soon as possible, at most within one calendar month.

Right to Restrict or Transfer

You have the right, under certain circumstances, to require that we restrict the processing of information that we have about you. You also have the right to request that your Personal Information be sent to a third party.

Right to Rectification

You have the right to request that we amend any Personal Information which is incorrect or requires updating.

Erasure

You have the right to request that we delete any Personal Information pertaining to you, subject to any legally imposed retention requirements to which we may be subject. We will assess any deletion request on a case by case basis and will endeavor to respond to you as soon as possible, at most within one calendar month. If you have authored any content on the Site, and would like this to be deleted, please let us know.

How We Use Your Information and Data

We will use your Personal Information insofar as it is regulated by the GDPR to conduct our business, specifically: pre-market and marketing, reference content, applications, sponsored programs, advertising, email communications, and discussion forums in connection with the purchase and sale of mobile devices and related goods and services.

California Consumer Privacy Act of 2018

PIT will endeavor to comply with the California Consumer Privacy Act of 2018, as effective January 1, 2020, as applicable.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“UK-ICO”), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavor to deal with your concerns directly.

If you would like to exercise any of these rights or are concerned with the manner in which we have collected or used your Personal Information, please contact us at the following address and provide the following details: 

If you are wish to exercise any of these rights, please contact us at support@PartnersInTorah.org,

or by postal mail at:

Partners in Torah

228 Aycrigg Avenue

Passaic NJ 07055