Effective Date: October 18, 2019

ICONNEL Catholic Foundation Inc. ("ICONNEL," "we," "us," or "our") respects your privacy and is committed to protecting your personal information in compliance with New York laws, including the SHIELD Act (N.Y. Gen. Bus. Law § 899-bb) for data security and breach notification, and Attorney General guidance on website privacy controls. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website https://iconnel.org/ (the "Site") or use our Services. As a 501(c)(3) charitable organization, we handle data in alignment with our mission to provide compassionate care and preserve Polish Catholic culture, while adhering to New York consumer protection laws.

By using the Site or Services, you consent to the practices described herein. If you do not agree, please do not use the Site. All disclosures are made in plain language for clarity.

1. Information We Collect

We collect information to facilitate our Services, improve user experience, and fulfill our charitable mission. Types of information include:

• Personal Information: Name, email address, phone number, address, payment details (for fees), job application details (e.g., resume, references), and background check consents. Collected via contact forms, job registrations, online hiring, or phone/email inquiries.

• Sensitive Information: Health or care needs (for senior services), religious affiliation (relevant to our Catholic mission), or financial data for donations/placements. We only collect what's necessary and with explicit consent, in line with New York privacy principles.

• Usage Data: IP address, browser type, pages visited, time/date of access, and referral sources (via cookies and analytics tools like Google Analytics). We disclose tracking technologies below.

• Donation/Volunteer Data: If you donate or volunteer, we may collect payment info or availability preferences.

We do not collect information from children under 13 without parental consent, in compliance with COPPA and New York child privacy protections.

2. How We Collect Information

• Directly from You: Forms, registrations, emails, or phone calls.

• Automatically: Cookies, web beacons, and server logs. You can manage cookies via browser settings.

• From Third Parties: Background check providers (with consent) or payment processors (e.g., Stripe, PayPal).

3. How We Use Information

We use your information for:

• Providing Services (e.g., matching caregivers, processing payments, arranging housing).

• Communicating with you (e.g., updates, confirmations, newsletters—opt-out available via unsubscribe links).

• Improving the Site (e.g., analytics for user trends).

• Charitable Purposes: Internal records for tax-exempt compliance, grant reporting, or mission-aligned activities (e.g., counseling referrals), consistent with Executive Law Article 7-A.

• Legal Compliance: Responding to subpoenas or protecting rights/safety.

We do not sell your personal information and process it only with a legitimate purpose.

4. How We Share Information

We share information only as necessary and with safeguards:

• Service Providers: Third parties for payments, background checks, hosting (e.g., Google), or email services (e.g., Mailchimp). They are bound by confidentiality agreements compliant with the SHIELD Act and must maintain reasonable security.

• Legal Requirements: To comply with New York laws, court orders, or protect against fraud/abuse, including breach notifications under the SHIELD Act.

• Business Transfers: In a merger or asset sale, with notice to you.

• With Consent: For specific sharing (e.g., caregiver references).

For international users, data may be transferred to the U.S.; we ensure adequate protections, including for New York residents' private information.

5. Data Security and SHIELD Act Compliance

In compliance with the New York SHIELD Act, we implement and maintain reasonable administrative, technical, and physical safeguards (e.g., encryption for payment data, access controls, employee training, and regular audits) to protect the security, confidentiality, and integrity of private information belonging to New York residents. This includes biometric information, if collected. Our program is designed to detect, prevent, and respond to threats.

Data Breach Notification: If we experience a breach of New York residents' private information, we will notify affected individuals without unreasonable delay (no later than 30 days in certain cases), the New York Attorney General, and the Department of State, as required by the SHIELD Act. Notices will include details on the breach, affected data, and mitigation steps. However, no system is completely secure; we cannot guarantee absolute security.

6. Cookies, Tracking, and Privacy Controls

We use cookies for functionality (essential, e.g., session management) and analytics (non-essential, e.g., Google Analytics). Third-party tools may set cookies for advertising or measurement. In compliance with New York Attorney General guidance:

• We provide truthful disclosures about tracking (e.g., no undisclosed data sales).

• Consent mechanisms (e.g., cookie banners) offer equal prominence for "Accept" and "Decline" options.

• Opt-out is available and honored; we do not respond to "Do Not Track" signals but provide manual opt-outs. For details, review our Cookie Notice (linked on the Site) or contact us. You can disable cookies in your browser, though this may limit functionality.

7. Your Rights and Choices

• Access/Update/Delete: New York residents may request access, correction, or deletion of their private information (subject to legal exceptions, e.g., service records). Submit requests to info@iconnel.org; we respond within 45 days.

• Opt-Out: Unsubscribe from emails via links or by contacting us. Decline non-essential tracking at any time.

• New York-Specific Rights: Under the SHIELD Act, you have rights to breach notifications and data security protections. For charitable data, review our financial disclosures per Executive Law § 174-b. Retention: We keep data as long as needed for Services or legal purposes (e.g., 7 years for financial records under IRS and New York rules), then securely delete or anonymize it.

8. Changes to This Policy

We may update this Policy by posting the revised version on the Site with notice of material changes (e.g., via email or banner). Significant changes will not apply retroactively without consent where required by law. Continued use constitutes acceptance.

9. Contact Us

For privacy questions, requests, or complaints, email info@iconnel.org, call 646-415-8818, or write to: ICONNEL Catholic Foundation Inc. 1120 Avenue of the Americas, 4th Floor New York, NY 10036

You may also file complaints with the New York Attorney General's Bureau of Consumer Frauds and Protection. Thank you for supporting our mission of compassion and cultural preservation.

Privacy Policy