The AAKOMA Project Website Privacy Policy

The AAKOMA Project has created this privacy policy (the “Privacy Policy”) in order to demonstrate our firm commitment to your privacy and security. This Privacy Policy discloses our information collection policies and practices for this website: www.aakomaproject.org (the “Website”). This Website is owned and operated by The AAKOMA Project, Inc. (hereinafter referred to as “AAKOMA,” or “we,” or “us”). This Privacy Policy applies only to AAKOMA’s online information-gathering and sharing practices occurring on the Website, and does not apply to any of our practices conducted offline. By visiting this Website, you are accepting the practices and policies described in this Privacy Policy, and you are further indicating that you agree to be bound by the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy you should not visit this Website or use any of the “links” on this Website. We may update this Privacy Policy from time to time, so please check this Privacy Policy periodically for changes. The date this Privacy Policy was last updated is stated at the end of this document.

Summary:

Select Sections:

The Personal Information We Collect, How We Collect It, And How It Is Used:

The AAKOMA Web site does not collect any PII about our Website visitors, other than information that visitors freely enter.The one exception to this is that, like most web sites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, as further discussed below.You may freely visit our Website without being required to provide us with any personal information. However, some requests and features do require that you provide us with some personally identifying information as more particularly described below. Personal information is data that can be used to identify or contact you. Please do not send confidential information to us directly via the contact email addresses listed on this Website.

Forms:

Website visitors have the opportunity to freely submit information through the website using a form. Your information is then passed directly to a secure AAKOMA email account and entered into a secure database. A dedicated AAKOMA staff member will review the information submitted and respond using the contact information provided. Your contact information is not shared outside the AAKOMA organization without your expressed written consent.In some cases, the data users submit via forms may be collected and processed using software developed and maintained by third parties with whom we have contracted to provide services or collect donations for us. Examples include WordPress, Mailchimp, Monday.com, GoDaddy, Pledge.co, GoFundMe, and/or Google. For information about their privacy policies, please visit their websites. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any software vendor to ensure that they process PII appropriately and according to our legal and regulatory obligations.

Data submitted via forms may include:

Donor Privacy:

AAKOMA does not trade, share,or sell a donor’s personal information to third parties, nor do we send donor mailings on behalf of other organizations. This policy applies to all donors, online and offline.

If you make a donation online at our Website, you are required to enter personal contact information and credit card information. We use this information to process your donation and send you a confirmation receipt. This information will not be sold or shared with outside parties.

When you make a donation, we also add you to our donor database and/or mailing list, from which you may receive news updates or periodic fundraising appeals via e-mail.

If you wish to be removed from our mailing list, please contact us via e-mail atcontact@aakomaproject.org, by phone at 1-571-486-3382, or at the address below.

Non-Personal Information We Collect By Automated Means And How We Use It

We collect certain non-personal information (data in a form that does not support direct association with any specific person or individual) by automated means when you visit the Website. Much of this information is collected through the use of third-party tracking services, such as Google Analytics. When gathered, this data is used in the aggregate, and not in a manner that is intended to identify you personally. In addition to the third-party tracking services mentioned above, we also collect this information through various other means, including “cookies,” “web beacons” and IP addresses, as further explained below.

Cookies:

A “cookie ” is a small file that a Web site can place on your computer. Cookies are commonly used by Websites to improve the user experience. Many cookies last only through a single Website session, or visit. Others may have an expiration date, or may remain on your computer until you delete them. We may use “session cookies” in order to enhance the user experience and for other web-related purposes. These session cookies are not linked to PII. Most browsers will tell you how to stop accepting new cookie, how to be notified when you receive a new cookie, and how to disable existing cookies.If your Web browser is set to accept cookies, the AAKOMA Web site places cookies when you visit. Cookies are used to present you with a better experience and to remember your preferences. You can remove AAKOMA’s cookie at any time by following the directions provided in your Internet browser’s “Help ” file.

Clear Gifs (Web Beacons/Web Bugs):

We employ a software technology called clear gifs (a.k.a. Web beacons/Web bugs) in many of our e-newsletters and other e-mail communications that help us measure the effectiveness of our efforts. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track which users have opened which e-mail messages. It is possible for us to tie the information provided by clear gifs to your PII, though we do not routinely do so. We are primarily interested in the aggregate effectiveness of our various e-communication efforts.

Link Tracking:

Many links within e-mail communications you receive from us have a tracking ID at the end. This enables us to measure how often certain links are clicked on to gauge overall interest in the email campaign. From e-mails, it is possible for us to tie the information provided by tracking IDs to your PII, though we do not routinely do so. We are primarily interested in the aggregate effectiveness of our various online efforts.

IP Addresses:

When you visit and interact with the Website, third parties with whom we have contracted to provide services for us may collect Internet Protocol addresses (each an “IP Address”), as well as browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and page navigation. An IP Address is a unique identifier number that certain electronic devices used to identify and to communicate with each other on the Internet; your Internet Service Provider automatically assigns an IP Address to the computer that you are using. We gather this information to track Website visitor movement in the aggregate, and to gather broad demographic information for aggregate use. We may use this information to enhance our Website or for other lawful purposes.

Response To “Do-Not-Track” Signals:

Every time your computer sends or receives information over the Web, the request begins with some short pieces of information called “headers.” These headers include information like what browser you are using, what language your computer is set to, and other details. The Do Not Track technology provides individual users with the ability to include a simple, machine-readable header indicating that they don’t want to be tracked, and sends a signal to Websites’ visited requesting that the Website disable either its tracking or cross-site user tracking of an individual user. Currently, various browsers –including Internet Explorer, Google Chrome, Firefox, Opera and Safari –offer a “Do Not Track” option. Presently, there is no consensus on how Do Not Track should be interpreted, and no common or accepted industry standard for implementing. Consequently, we do not respond to Web browser “Do Not Track” signals.

How We Use The Information We Collect:

Except as otherwise stated in this Privacy Policy, AAKOMA does not share any PII about you with un-related third parties. You have the option to update, revise, or have deleted any personal information you have shared with AAKOMA, as further specified herein. For specific information about how information is used, please see the section above.

E-Newsletters:

If you subscribe to our e-newsletter, we will use your name and e-mail address to send it to you. We may occasionally send you information on special events, news, or opportunities. Out of respect for your privacy, we present the option to unsubscribe. Please use the “unsubscribe” option at the bottom of the email.

Service Requests

Visitors to our website can submit requests for AAKOMA’s services, such as Free Therapy, workshops,and consulting. All information provided by a user is provided voluntary and is used by AAKOMA to assess the service requested, our ability to provide the service, and to engage with the requestor to either decline or pursue an engagement to provide the service. If you would like to request a service listed on our website without submitting your information through a website form, you can email contact@aakomaproject.orgor call us at 571-486-3382.

Choice and Opt-Out:

Please contact AAKOMA directly if you wish to have your information removed from our databases:

contact@aakomaproject.org
571-486-3382
Webmaster
c/o AAKOMA
4201 Wilson Blvd.
Suite 300
Arlington, VA 22203

What Information We Share And With Whom:

PII that you provide AAKOMA will only be used internally by AAKOMA. This includes your name, age, phone number, e-mail address, information preferences, demographic information, and any other information you may voluntarily provide.

In the course of providing our services, AAKOMA relies on certain trusted business partners to perform certain tasks, such as handling mass mailings, delivering e-communications, processing payments, etc. This involves transferring information about you in paper or electronic form. AAKOMA makes every effort to ensure the trustworthiness and best business practices of these partners. These agents and third parties are prohibited from using your PII for any other purpose.

Except as stated in this Privacy Policy, we do not reveal PII about you to third parties for their independent use unless: (1) you expressly authorize AAKOMA to do so, (2) it is necessary to allow AAKOMA and its service providers or agents to provide services on AAKOMA’s behalf, (3) it is to provide products or services to you, (4) it is disclosed to entities that perform marketing or data aggregation services for AAKOMA, (5) it is necessary in connection with a sale of all or substantially all of the assets of AAKOMA or the merger of AAKOMA into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which AAKOMA is not the survivor, (6) AAKOMA is required or permitted to do so for any or all of the following reasons: (i) to comply with a subpoena, legal process, government request or any other legal obligation, (ii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Website or our network, and/or (iii) to protect the rights, privacy, property, business, or safety of AAKOMA, its partners and employees or the visitors to the Website.

Links To Other Sites:

This Website contains links to other sites that are not owned or controlled by AAKOMA. Please be aware that we, AAKOMA, are not responsible for the privacy practices of other such Websites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every Website that collects.

How We Protect The Information We Collect:

Browsers And Internet Security

Any time you enter or provide personal information on our Web site, we encrypt it using Secure Socket Layer (“SSL”) technology. SSL protects information as it crosses the Internet. To support this technology, you need an SSL-capable browser.

You can tell if you are visiting a secure area within a Web site by looking at the lock or key symbol in your browser address window. If the address of the page begins with “https:// “, it is secure. Occasionally, the page you enter data on may not be secure, but by submitting the information you activate a secure connection and thus your data is submitted securely.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100 percent secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

What If I Provide Information From Outside The United States?

Our Website is hosted in the United States and is governed by US law. Accordingly, by submitting any personal information to us you are transferring your personal information to the United States and you consent to such transfer. We do not represent or warrant that the Website, or any part thereof, is appropriate or available for use in any particular geographic location. If you choose to access our Website, you do so on your own initiative and at your own risk, and are responsible for complying with all local laws, rules, and regulations applicable in your jurisdiction. If you are visiting the Website from outside the United States, please be aware that your information will be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Website, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

The AAKOMA Project, Inc.’s homepage, website,and related documents are not specifically directed to children less than 13 years of age, but all users of The AAKOMA Project, Inc.’s homepage, website,and related documents are directed to this general privacy policy and all users should read this general privacy policy. In addition, whenever a child less than 13 years of age and has access to the internet, the parent and child must read The AAKOMA Project, Inc.’s special privacy policy regarding children as a condition of using The AAKOMA Project, Inc.’s services.

Use of Personal Information by Third Parties

The AAKOMA Project, Inc. has vendors and other third parties that are described in this general privacy policy. The third parties may collect personal information and that information may possibly be from a child less than 13 years of age. The AAKOMA Project, Inc. uses reasonable means to avoid that being done and it restricts use of personal information by its third-party vendors as described in this general privacy policy.

Collecting Age Information Before Collecting Personal Information

The AAKOMA Project, Inc. may collect age information, before collecting personal information regarding a child less than 13 years of age. If the child’s age is not verified or The AAKOMA Project, Inc. cannot verify that the child is 13 years of age or older, The AAKOMA Project, Inc. may require verifiable parental, legal guardian, or primary caregiver consent.

Parental, Legal Guardian, or Primary Caregiver Rights

There are parental, legal guardian, or primary caregiver rights under COPPA; These rights are:

To exercise their rights, the parent, legal guardian, or primary caregiver must notify The AAKOMA Project, Inc. in writing of the right it is exercising and mail that exercise of rights by means of the United States Postal Service.

The AAKOMA Project may occasionally seek to collect information about children under the age of 13 for the purposes of supporting them via our website. In the event, that we collect information from youth, this announcement serves as notification to parents, legal guardian, or primary caregiver of the following:

The AAKOMA Project will:

How Does a Parent, Legal Guardian, or Primary Caregiver Give Its Verifiable Consent Before The AAKOMA Project, Inc. Collects Personal Information from Her/His/Their Child.

The AAKOMA Project, Inc. may need to verify that the person is the parent, lawful guardian, or primary caregiver of the child. A parent, legal guardian, or primary caregiver, in order to give her/his/their child’s verifiable consent, must:

Rights Related to the European Union’s General Data Protection Regulation:

The following provisions applies only to users residing in the European Economic Area (EEA), Switzerland and the United Kingdom.

In May of 2018 a new data privacy law known as the EU General Data Protection Regulation (“GDPR”) went into effect. Pursuant to GDPR, we are required to provide those residing in the EEA, Switzerland and the United Kingdom (hereinafter, the “EU Users”) additional information and rights related to the Personal Information we collect about them. For the purposes of this GDPR Privacy Notice section, “Personal Information” means any information relating to an identified or identifiable person. We summarize such information and rights below.

How To Contact Us:

The AAKOMAProject, Inc. (the Data Controller) is the owner and operator of the Website. If you need to contact us for any reason related to this Privacy Policy or your use of the Website, please contact us at the following address:

The AAKOMAProject
4201 Wilson Blvd.
Suite 300
Arlington, VA 22203

Purpose For Information Collection:

As noted in this Privacy Policy, you may visit our Website without being required to provide us with any Personal Information. However, should you decide to provide such information, the information we collect will be used to meet your requests, or to provide you with the applicable information or service requested, and as further described herein.

Legal Grounds For Processing Personal Information

AAKOMA will process Personal Information that we receive from EU Users on the ground that it is in our legitimate interest for the effective administration of the Website, or to fulfill and/or address your requests.

Your Personal Information And Your Choices; Withdrawal Of Consent:

GDPR provides EU Users with additional rights in respect to the Personal Information we hold about you, including:

How To Access Your Information And Your Other Rights

We will respond to any such above requests within a reasonable timeframe.

Some of these rights may be in circumstances in which we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided in data protection legislation in general, and GDPR in particular, or where the Personal Information may be exempt from disclosure due the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations.

Please also note we may need to retain certain Personal Information for record keeping purposes, and there may also be residual Personal Information that will remain within our databases and other records, which will not be removed from such locations. Additionally, please note that we are not responsible for removing or deleting information from the databases of third parties (such as service providers) with whom we have shared information about you, but we will make the request on your behalf for such removal/deletion.