The Greenrail Project Privacy Policy

The Greenrail Project respects your privacy. We collect information to provide services to you, update you on the impact of your contributions, and communicate about promotions or special services. The Greenrail Project recognizes that we must maintain and use your information responsibly.

Privacy Policy Overview
This policy describes what personal data we collect, how we use it, and your choices.
We collect information from you when you visit and take actions on our website. We use this information to provide the services you’ve requested. We may use cookies (such as Google Analytics, Mixpanel) to provide a better experience and improve our website and web beacons and similar technologies to track usage patterns and conduct marketing.

You can access your data, edit your preferences, download your data, or revoke consent by visiting your account. Except for the purposes outlined below, we will not trade, share, or sell your personal data with anyone. Refer to the policy for complete details.

Our Privacy Policy considers the requirements of the General Data Protection Regulation (“GDPR”). If you are based in the European Economic Area, we may transfer your personal data to the United States pursuant Standard contractual clauses for personal data transfer to third countries.

If you have any questions about our Privacy Policy, contact us at connect@greenrailproject.org

1.        Information We Collect
2.       Use of Information
3.       Disclosure of Personal Data
4. Cookies
5.       Information about Children
6.       Your Rights
7.        Retention
8.       Links to Other Websites
9.       Safeguarding Your Information
10.     Data Storage
11.      Transfer of Data
12.     Privacy Policy Updates
13.     Contact Us

By continuing to access or use www.greenrailproject.org (our ‘Website’), you agree to be legally bound by this Privacy Policy and the Terms of Service. These Terms and Supplementary Terms may be modified from time to time and the changes will be posted on our Website (we will notify you of these where appropriate).

This policy applies to information collected by The Ng Foundation and The Greenrail Project through all channels, including online and offline methods.

The Greenrail Project is an initiative of The Ng Foundation, a private operating foundation based in State of Delaware, United States, registered company number 5824642.

For the purposes of the applicable data protection law, including the GDPR, The Ng Foundation, whose principal office is at 21710 Stevens Creek Blvd., Suite 225, Cupertino, CA 95014, United States is the data controller for the processing of your personal data.

Information Collected from Website Visitors
As a visitor to our Website, The Greenrail Project’s servers automatically record certain information, such as your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Website), your operating system, your browser ID, your browsing activity on our site, and other information about how you interacted with our Website, which can be used to identify you. We may collect this information also through the use of cookies or other tracking technologies (please read the “Cookies” section below for more information).

You may choose to interact with our Website by entering data into form fields and providing personal data to The Greenrail Project, such as giving us your name, email address, and password when signing up for an account, filling out an application, making an inquiry, or creating an account to post comments on pages, projects, or our blog.

We only collect personal data that is reasonable or necessary to accomplish the purpose of your interaction with The Greenrail Project as a visitor to our Website. You may choose not to provide this information, but you need to understand that as a result, you may not be able to engage in certain activities on the Website. Any personal data provided by you as a visitor to the Website will be used only as described in this Privacy Policy.

Information Collected from Registered Users
We collect information when you create an account on our Website, edit your account information, participate in a project, be a partner, apply to join The Greenrail Project as an organization, as described below.

Creating an Account:
When you create an account on our Website, we collect basic information about you — your name and email address. You can choose to provide additional information, such as your mailing address, a photo, favorite projects, etc., if you create a profile.

Making a Donation:
When you make an online donation on the Website, we collect personal data such as your name, billing address, and email address, if you have not previously provided these details during a prior session. We collect information about your donation, including the project you are donating to and the amount of your donation. We also collect (but do not retain) credit card numbers which are processed by a third-party payment vendor subject to the Payment Card Industry Data Security Standards. If you use PayPal, Apple Pay, or a similar service, their use of your information is based on their terms of service and policies, not ours, so we encourage you to review those policies carefully.

We may also ask you to share a brief description about why you decided to donate to our initiatives, along with your name and general location. If you elect to provide this optional information, we may publicly share this information to inspire other visitors to follow your generous example.

Gift Cards
When you give a The Greenrail Project Gift Card, we collect payment and contact information from you, as well as the name, email address, and mailing address of your recipient. You may create a personal message to the recipient, which is stored on our servers. Except in the limited circumstances described below, we do not read or use your personal messages.

If you are the recipient of a The Greenrail Project Gift Card, we collect information from you when you redeem the Card to donate. Please note that we may share this information with the individual or entity who gave you the gift card.

Donations in Honor/Memory of Someone
When you make a donation in honor or memory of a loved one, we collect payment and contact information about you, as well as the name, email address, and mailing address of the recipient. You may create a personal message to the recipient, which is stored on our servers. Except in the limited circumstances described below, we do not read or use your personal messages.

Contests, Promotions, and Surveys
Periodically, The Greenrail Project may invite you to participate in events, take advantage of special promotions, and/or complete online surveys. If you have created a The Greenrail Project account or profile, information we collect from these contests, promotions, and surveys may be associated with you personally.

Information Obtained from Other Sources
We may obtain information about you from public records and from databases like OFAC when conducting due diligence on nonprofit organization or conducting fraud prevention checks on donations.

The Greenrail Project uses the personal data that you provide, or we obtain, and the technical information logged by our servers to process your donations, to:

• Process your donations, contact you regarding any questions related to your donation, mail gift cards related to your donation (if applicable). Use of this data is necessary for the performance of the contract between you and us in connection with your donation. If you do not provide the necessary data to us or our payment service provider, we will not be able to process your donation.
• Comply with our legal obligations (for example, we are required to pass relevant data to the competent authorities to comply with regulations).
• Send you updates on how your donation has been used, information about The Greenrail Project, and projects we think we think will be of interest to you. We will only send you this information by email if you consent to us doing so at the time you provide us with your personal data. You may opt out of receiving such emails by following the instructions contained in each email we send you.

As necessary for certain legitimate interests, which include the following:

• Notify your friends and family about your donation in their honor if you ask us to;Using the technical information logged by our servers when you visit our Website (described above) to improve your experience on our Website (such as remembering your name, the items in your Cart, or your preferences) and preventing fraudulent activity;
• If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing;
• We may anonymize the information that we collect and use such anonymized data for statistical and market research purposes, including sharing it with affiliates, business partners, and academic researchers;
• Operate the Website, market and advertise our services, and operate our activities; and
• Compile aggregate statistics that allow us to understand how visitors or registered users use our Website, and to make improvements in design and content to better serve youOther Networks.  If you choose to share Site Content to other apps or social networks such as Facebook, Google+, Tumblr or X, you will be sharing certain information with these apps or networks. In the case of Facebook, Google+, Tumblr or X, any Site Content that you share on our website will be shared to those networks and will be visible to your followers and friends on those networks.  We are not responsible for these other networks, so please make sure you only connect your account with apps or services that you trust.

For information on how to control the information that your share, and how to disconnect your account from other networks or apps, please see the “Your Rights and Choices” section below.

Aggregate or De-identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

Other. We also may use your information to manage our operations or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.

We will share your personal data with our agents, representatives, service providers and contractors to process your donations, offer you services in connection with our Website, communicate news and information about The Greenrail Project, provide customer service, mail gift cards, notify the project(s) you elect to support about your donation, marketing and advertising, and complete financial transactions. These service providers are authorized to use your personal data only to the extent necessary to serve these purposes, or as otherwise authorized by this policy.

Except for the purposes outlined herein, we will not trade, share, or sell a donor’s personal data with anyone else.

Unless you ask us not to, we share your personal data under the following circumstances:

• When you donate to a project, we share your name and contact information and the amount of your donation with the project leader and organization running that project.
• When you donate that is part of a campaign sponsored by your employer, and/or when your employer is being asked to match your donation, we will share your name, email address and the amount of you donation with your employer.
• When you decide to post a comment or share why you supported a cause, we will share and attribute your comment on our site publicly and with the project you have supported;
• Each time you donate, however, we will give you the opportunity to tell us not to share your personal data in the ways described above (except in the case of employer matched donations) by selecting to be “anonymous” during the checkout process.

If The Greenrail Project merges with, or becomes an affiliate of another organization, we will ensure the confidentiality of any personal data involved in such transactions and provide notice before personal data is transferred and becomes subject to a different privacy policy.

We may also be required to disclose your personal data in the following circumstances: (1) we need to respond to a subpoena, court order or legal process, including to meet national security or law enforcement requirements; (2) an emergency situation requires disclosure before your permission can be obtained (e.g., situations involving potential threats to personal safety), or; (3) we determine that disclosure is needed to protect our rights or property, or the rights or property of another person, in which case we will implement appropriate safeguards to ensure that your personal data continues to be protected.

We may share aggregated demographic and statistical information with our other partners. This is not linked to any personal data that can identify any individual person.

We may partner with third-party advertising networks and exchanges to manage and serve our advertising on other sites and may share personal information of visitors with them for this purpose. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our Cookie Policy.

Like most websites, our servers automatically collect certain technical information when you visit our Website, including your IP address, browser type, browser language, the date and time of your visit, the referring URL, and, if you have visited our Website before, one or more cookies that may uniquely identify your browser. We also collect information about your activities on the Website, such as the pages you access.

In order to collect this information, the Website places a cookie on your hard drive. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. We also use web beacons and other technologies to track usage patterns.

We use several tools to collect information about use of this Website. These tools collect information such as how often you visit this Website, what pages you visit when you do so, what elements you interact with, what other sites you used prior to coming to this Website, or 3rd-party audience data (such as age, gender and interests). We use the information we get from these tools to improve our Website, for website analysis and statistics and respond to service requests you make.

Where required by the law, when you first visit the Website, you will be asked to consent to the use of cookies on the Website, and if you accept, we will store cookies on your computer. For more details on our use of cookies and similar technologies, please refer to our Cookie Policy.

The Website is a general audience website and does not collect information about a visitor’s age. We do, from time to time, partner with other organizations to educate children about philanthropy in general and our work in particular. In those cases, we do not collect personal data from a visitor on pages specifically designed for children.

We do not knowingly collect or store any personal data about children under the age of 16 and we do not offer any of our products or services directly to children under the age of 13.

Emails: If you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request.  Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.

Cookies: You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.

GDPR Rights: If your personal information is protected by the GDPR, you have certain data protection rights described below with respect to the personal information collected and used by our website. These rights may only apply in certain circumstances and are subject to certain exemptions. You can exercise these rights using the contact details at the end of this Privacy Policy. The rights are as follows:

Right to access: You can access your account information or make changes or updates at any time by informing us. We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.
Upon request, we will provide you with a copy of the information that we have. User can submit the request to access a copy of their information.

Right to erasure: If you wish to delete your account or have you information removed from our system, you can do so by sending an email to connect@greenrailproject.org. For privacy and security, requests must come from the email address tied to your account.

Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we would tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your personal data with others, we would tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Upon request, we will provide you with a copy of the information that we have.
Right to object: 
You may ask us at any time to stop processing your personal data, and we will do so:

• If we are relying on a legitimate interest (described in this Privacy Policy) to process your personal data — unless we demonstrate compelling legitimate grounds for the processing; or
• If we are processing your personal data for direct marketing.

Right to withdraw consent: If we rely on your consent to process your personal data you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the Information Commissioner’s Office (ICO) (details on how to do so can be found on the ICO’s website) or other data protection authority that is authorized to hear those concerns.

In addition, when you create an account or profile on our Website, you can decide whether to make some or all of that information public or private. You can change your choices at any time using the My Profile page. Please note, however, that your preferences do not affect the disclosures to project leaders or fundraisers. So, for example, if you contribute to a project, we will share your name and contact information with the project leader. In each case we will give you the opportunity to tell us not to disclose your personal data with the project leader, or publish it on the website or in our annual report. You may ask us to change the anonymous settings on past donations by emailing us at connect@greenrailproject.org.

We will retain donor’s information for as long as donor’s account is active or as long as needed to provide our services. We may also retain and use your personal data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.

Other websites, including those of our partners (links to which appear on Website), have their own privacy policies. When you provide personal data at one of those sites, you are subject to the privacy policy of the operator of that site, not The Greenrail Project Privacy Policy. We encourage you to read that policy before submitting any personal data.

You should take additional steps to safeguard your personal data online. To learn more about how to protect yourself, visit the Federal Trade Commission website (US) or the Information Commissioner’s Office (UK).

The Greenrail Project understands the importance of keeping your information secure and confidential. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.

We follow industry best practices and standards for security. We use a variety of physical and technical measures, policies, and procedures (such as access control procedures, network firewalls, encrypting data at rest, encrypting data in transit, and physical security) designed to protect our systems and your Personal Information.

Your data will be stored on servers of our hosting service providers in the United States which is certified to the Privacy Shield. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and US and EEA data protection legislation.

Users Outside the USA
If you are an individual located in the European Union/European Economic Area (EU/EEA), the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations.

Data hosting within and outside your country of residence may be accessed by our employees.  The United States has not received an “adequacy decision” from the European Commission, which means that the data protection laws of the United States may not offer the same protections as the country in which you reside when you provide information to us.  By submitting your personal information to us and using our website, you understand that your personal data will be transferred to, processed, and stored in the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.  We take appropriate measures to ensure that any such transfers comply with applicable data protection laws and that your data remains protected to the standards described in this Policy.

California Disclosures

California Information-Sharing Disclosure. California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to connect@Azrekglobal.com with “California Privacy Rights” in the subject line.
Do Not Track. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.  More information about “do not track” is available at www.allaboutdnt.org concerning such information.

Third-Party Tracking. Third parties, other than our service providers (such as our website analytics provider), do not have our permission to track which websites you visited prior to and after visiting our website. That said, we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.

Data security. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Our Privacy Policy is regularly reviewed to make sure we continue to serve the privacy interests of our customers. If our information practices change materially, we will notify you of these policy changes by posting them on the privacy page of this website and we will ensure that these changes are brought to your attention

Individuals with inquiries or complaints regarding our Privacy Policy should contact us by using the “Contact Us” links on the footer of our Website or by sending an email to connect@greenrailproject.org. We try to reply promptly to every message we receive. This information is used to respond directly to your questions or comments. We also may file your comments and share them with our customer care team to improve our service in the future. The Greenrail Project commits to resolve complaints about our processing of your personal data.

For individuals in the European Union, pursuant to Article 27 of the General Data Protection Regulation (GDPR), you can contact EDPO regarding matters pertaining to the GDPR in writing to connect@greenrailproject.org.