1. Your Consent
Please read this Privacy Policy carefully; once you consent to this Policy's terms, it creates legal obligations on you and on Gift of Life. We ask you to consent to the terms of this Privacy Policy in different ways, depending on your relationship to the Site. The procedures for consenting to this Policy are (a) less formal if you are a Site Visitor or Patient seeking information, (b) more formal if you are a Financial Supporter, contributing through our Site, and (c) the most formal for Donors and Medical Professionals, using our Site for potential donation and matching activities.
1.1. Consent by Site Visitors and Prospective Patients. By accessing and using our Website as a Site Visitor or prospective Patient, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from using our Site.
1.2. Consent by Financial Supporters. As a Financial Supporter, you may submit contact information, and other information (including your comments), to us via the Website, and you may also choose to make a financial contribution to us through the Site. You may also use the Website to send various e-greetings. When you submit information to us to identify yourself as a potential Financial Supporter, to make a financial contribution, or to send e-greetings via our Site, you will be prompted to click an "I Accept" button linked to this Policy. Clicking "I accept" confirms your agreement to be bound by this Privacy Policy.
1.3. Consent by Donors and Medical Professionals. If you register as a Medical Professional for access privileges to our MatchQuestTM software and database, or if you register as a potential Donor, you will similarly be prompted to click an "I Accept" button linked to this Policy during the registration process. Clicking "I accept" confirms your agreement to be bound by this Privacy Policy.
2. Scope of Policy
This Privacy Policy applies (i) to anonymous information you provide to us while using our Site or while participating in our services, and (ii) to personally identifiable information you provide to us as part of the process of registering online as a Financial Supporter, Medical Professional, or Donor. Please note that Donors sign an offline Consent for Registry Participation, that governs the collection and use of information for determining a transplant match and for contacting the Donor in the event of a potential match (a "Registry Consent"). This Privacy Policy does not govern information collected under and governed by the Registry Consent, and the Registry consent governs all such information.
3. The Information We Collect, and Our Uses of This Information
We will not share personally identifiable information you provide via the Website with any third party, other than as expressly disclosed in this policy. By "personally identifiable information" we mean information that identifies you, such as your name, mailing address, or email address. We collect information from you at different points on our Website, and use this information as follows:
3.1 Privacy of Registry Information. In order to join the Gift of Life Marrow Registry, personal information is collected including, but not limited to, a person's name, date of birth, postal and email address and phone number. In order to be a prospective donor that is eligible to join the registry, health screening information is also collected, including history of cancer and other medical conditions. To be part of the registry, prospective donors must provide a sample of cells from inside their cheeks (a buccal swab) which is tested at a Gift of Life contract laboratory for specialized cell surface markers, Human Leukocyte Antigens (tissue typing), blood group and Cytomegalovirus status. Gift of Life only identifies prospective donors by proprietary donor identification number to maintain anonymity and privacy, and conducts compliance reviews with contract laboratories to ensure compliance with standards. Security measures are taken to ensure safety and privacy of all information as described in this Privacy Policy.
This information is accessible on a need to know basis by authorized personnel only, and protected as per Section 6 ("Security") of this Privacy Policy. Donor identity is also protected through the use of a proprietary donor identification number, and donors are identified anonymously using that number (for example, via donor search conducted by transplant centers). Should a donor elect to withdraw from the registry, Gift of Life will deactivate the donor's information in a manner that protects the individual's confidentiality and complies with applicable laws. While in the registry, donors can expect that Gift of Life will communicate with them using a variety of methods, including, but not limited to, telephone, email and text message (with approval) in connection with their membership in the registry. Donors can obtain access to their personal information or obtain details about Gift of Life’s privacy practices by contacting its Privacy Officer in writing at 5901 Broken Sound Parkway NW, Suite 600, Boca Raton, Florida 33487.
3.11 In the event you wish to contact us to review your personal information that may have been collected and/or correct any information, please call 1-800-9-MARROW or complete our contact page.
3.2 Processing Requests and Transactions. When you make a request of us via our Website, we will use any personally identifiable information that you provide in connection with that request for the purposes of processing that request. For example, Financial Supporters are able to send e-greetings via our Site. When you request an e-greeting, we use personally identifiable information you provide in connection with that request solely for purposes of transmitting the e-greeting. In each instance where you make a request under our Website, we use the information you provide to us solely for the purpose of fulfilling your request.
3.3 Information concerning Third Parties. If you are a prospective Donor, during our registration process we may ask for certain personally identifiable information concerning one or more of your relatives or close acquaintances (your "Additional Contacts"). We use this information in order to have further contact information for you on file, and in order to assist us in evaluating your eligibility for our Donor programs. We may verify certain information with your Additional Contacts, and discuss with them your interest in our Donor programs. By giving us contact information for these individuals, you are assuring us that they are willing to participate in this process, and that you are willing to allow them to participate.
3.4 Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, educational materials, marketing materials, or other information to you, and will use personally identifiable information to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 5.
3.5 Information Exchanges with Other Users. The Website may allow users (i) to provide and receive a range of information on topics related to transplants and other matters, and (ii) to engage in other activity that may include, at the option of the user, an exchange of personally identifiable information. In these instances, we use personally identifiable information you provide to us in connection with any such exchanges strictly for the purposes for which you submit the information. If you share personally identifiable information -- via our Website or related discussions -- with persons other than Gift of Life staff or healthcare entities involved in the donation process, you should treat the exchange as you would any other exchange with a third party, and use appropriate discretion and caution.
3.6 Anonymous, Aggregate Information. “Aggregate Information” is information that does not identify you, and may include statistical information that may range from statistical information and analyses concerning use of our Donor services, the number of successful matches coordinated through our Site or services, transplant-related information, and the pages on our Site that users visit most frequently. We use Aggregate Information to analyze the effectiveness of our services and our Site, to improve our services and our Website, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of (i) the general behavior and characteristics of users participating in our services, (ii) the effect of our programs on, and the behavior of our Donors, Financial Supporters, Medical Professionals, and Site Visitors, and (iii) the general characteristics of visitors at our Site and participants in our services. We may share these analyses and Aggregate Information with third parties. Rest assured, though, that Aggregate Information provided to third parties will not allow anyone to identify you, or determine anything personal about you. We may collect Aggregate Information through features of the software that supports our services, through cookies, and through other means described below. If you do not wish your non-identified information to be included in the aggregated information, please do not use this website. You may also contact us at 1-800-9MARROW with any concerns.
3.7 IP Addresses. Gift of Life may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer's name, the type and version of your web browser, referrer addresses and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used. None of this data contains personally identifiable information.
3.8 Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services.
3.9 Computer Configuration. In order to determine whether your computer is supported by our system, we may collect certain anonymous information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Website may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.
3.10 Extent of Information Collected. We do not collect any more personally identifiable information than reasonably necessary to provide our services, operate the Site, and respond to your requests.
4. We Do Not Disclose Information to Unaffiliated Third Parties; Limited Exceptions
4.1 Gift of Life Site Vendors. We may employ other companies to perform functions on our behalf, such as maintaining the Website, providing services related to the Site, collecting information, responding to and sending electronic mail, or other functions necessary to our business. We may need to share your personally identifiable information with these companies (collectively, "Site Vendors"). We will provide Site Vendors with only that information necessary to perform their functions, and we will not allow them to use your personally identifiable information for any other purpose.
4.2 Imminent Harm. We may reveal your personally identifiable information to attorneys, private investigator organizations or law enforcement agencies if we believe (a) that you are in risk of harm from another, or (b) that you are harming or interfering (or will imminently harm or interfere) with others or violating (either intentionally or unintentionally) our Terms and Conditions of Use or otherwise violating legal rights.
4.3 Legal. Gift of Life will reveal your personally identifiable information, to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of your personally identifiable information we will attempt to notify you via the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
4.4 Transfer of Site. Gift of Life shall be entitled to transfer to a third party information it collects, including any personally identifiable information, in connection with a sale or transfer of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard your personally identifiable information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy.
5. Changing or Removing Information; Opting Out
5.1 Discretionary Account Information. To allow appropriate control over personally identifiable information, you can contact us at the address provided in Section 11 to access the personally identifiable information you have provided to us via the Website or to change or update discretionary information that you have previously submitted.
5.2 Opt-Out. If we choose to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, we will provide you with the ability to decline -- or “opt-out of” – receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. Please understand that you will not be allowed to "opt–out" of formal notices concerning operation of this Website, and legal and other related notices concerning your relationship to the Site.
5.3 Deleting Information. Finally, if you request, unless you have registered as a Donor, we will remove your name and all other personally identifiable information from our databases. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of the Website and any associated services or information. You may not remove de-identified or Aggregate Information from our databases. Donor information is governed by the Registry Consent and may not be deleted, but may, at the Donor's request, be removed from the active registry list.
6. Security
We have put in place security systems designed to prevent unauthorized access to or disclosure of information you provide to us, and we take all reasonable steps to secure and safeguard this information. We store all personally identifiable information we receive on a separate system protected by firewalls, designed to be secure and isolated from direct connection to the Internet. All data exchange with the Internet is always encrypted via SSL employing certificates with at least 2048 bit encryption. Gift of Life employees (and employees of our Site Vendors) are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of personally identifiable information. Moreover, we provide access to our databases containing personally identifiable information on a need-to-know basis only. Access to our database is password protected and employs strict industry standard password policies including but not limited to
- password complexity
- limiting password reuse
- password life span
- one-way encryption
As an accredited member of the World Marrow Donor Association, Gift of Life must comply with recognized standards for electronic record keeping. Additionally, Gift of Life complies with FDA’s Title 21 CFR Part 11 that imposes standards on electronic records and electronic signatures.
Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, though, that we do not warrant as fail-proof the security of information provided by or submitted to Gift of Life. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
7. Notice of Security Incident
If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of personally identifiable information (an "Intrusion"), we will (i) notify effected users of the Intrusion if the information at issue is sensitive, in our discretion, (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each affected user that is current in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent applicable law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.
8. Privacy Protection for Children
Our Website is not directed at children, and we will not accept or request personally identifiable information from individuals we know to be under 13. In accordance with the Children’s Online Privacy Protection Act ("COPPA"), if we learn that a child under 13 has provided personally identifiable information, we will either (i) delete this information from our databases, in accordance with our deletion policy, set out in Section 5.3, or (ii) obtain verifiable parental consent, in accordance with COPPA.
9. Notification of Changes
From time to time, Gift of Life may change its Privacy Policy. If we make any changes regarding disclosure of personally identifiable information to third parties, we will attempt to contact you prior to the date the modified policy is scheduled to take effect. We will post notice of the new Policy from the privacy link on our Website. With respect to Site Visitors and Patients, your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed. With respect to Financial Supporters, Donors, and Medical Professionals, no such changes will take effect unless and until you have provided us with your consent to such changes, in accordance with Sections 1.2 or Section 1.3, above.
10. Relationships to Terms of Use and Other Contracts
This Privacy Policy must be read in conjunction with our Terms and Conditions of Use, and the provisions of our Terms and Conditions of Use are incorporated herein. To the extent the Terms and Conditions of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control. This Privacy Policy should also be read in connection with the Registry Consent (for Donors), and the MatchQuest™ License (for Medical Professionals).
11. Retargeting Policy
Cookies and Tracking
Campusambassador.org use "cookies" to enable you to sign in to our services and to track your traffic patterns. A cookie is a text file that is placed on your computer's hard drive. Cookies help us personalize and make improvements to Gift of Life Marrow Registry so that you can have a pleasant and productive experience. You can set your browser to send a warning message before accepting cookies or to refuse cookies. Check your browser for instructions on how to handle cookies. If you choose to decline cookies, you may not be able to use all of the features of Gift of Life Marrow Registry Sites.
Online Behavioral Advertising by Gift of Life Marrow Registry and Others
Gift of Life Marrow Registry also works with third party advertising and personalization partners that use cookies to help us display personalized content and appropriate advertising during your visits to Gift of Life Marrow Registry Sites and other websites. These cookies identify the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page. This also helps us measure the performance of our advertising campaigns.
Similarly, third parties use cookies to deliver advertising for companies other than Gift of Life Marrow Registry to you on the Internet, whether you are on Gift of Life Marrow Registry Sites or other websites, based on your visits to Gift of Life Marrow Registry Sites and other websites. These cookies assist the third parties in identifying the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page.
If you would like to opt out of this program, please visit the Network Advertising Initiative opt-out page located at http://www.networkadvertising.org/choices.
"Do Not Track" Signals
Please note that while you may have the ability to opt-out of targeted advertising through the http://www.networkadvertising.org/choices link above and you may be able to control the use of cookies through your web browser as described in the "Cookies and Tracking" section above, some web browsers may give you the ability to enable a "do not track" setting that sends a special signal to the websites you encounter while web browsing. This is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the "do not track" setting enabled still have the ability to accept cookies. Gift of Life Marrow Registry does not respond to web browser “do not track signals” at this time. If we do so in the future, we will describe how we do so in this Privacy Policy.
Advertising Opt Out Links
DAA: http://www.aboutads.info/
NAI: http://optout.networkadvertising.org/?c=1
Europe only EDAA: http://www.youronlinechoices.com/
12. Contact Us
If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Website, please contact us at:
Attention: Operations Manager
Phone: 1-800-962-7769
13. Effective Date
The effective date of this Privacy Policy is May 5, 2020.