Privacy Policy
PRIVACY NOTICE
Last updated August 1, 2025
This Privacy Notice (this “Privacy Notice”) for the John Simon Guggenheim Memorial Foundation and its affiliates (including Fund for the Guggenheim Fellowships) and their respective successors and assigns (collectively, “we,” “us,” or “our”), describes how and why we might access, collect, store, use, share or otherwise process (“Process”) personal information[1] regarding individuals who access or use our services, including when such individuals access our website at https://www.gf.org (or any website of ours that links to this Privacy Notice) or interact with us in other related activities, including applying to our fellowship program, making donations or other contributions to us and participating in any sales, marketing, events or other activities we engage in (such websites, services and activities, our “Services” and such individuals, “you” or “your”).
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is Processed by us or on our behalf. If you do not agree with our policies and practices, please do not provide us with your personal information or access or use our Services. If you still have any questions or concerns, please contact us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we Process? When you access or use our Services, we may Process personal information depending on how you interact with us and our Services, the choices you make, the Services you use and the personal information you or third parties provide to us. Learn more about personal information you provide to us or that we otherwise may collect about you.
Do we Process any sensitive personal information? Certain types of personal information may be considered “special” or “sensitive” in certain jurisdictions, including, for example, your racial or ethnic origins, sexual orientation, and religious beliefs. Although we do not request or require such sensitive personal information to provide, improve, and administer our Services, we may collect such information to the extent you choose to provide such information to us, including through any application forms (including unfinished application forms and related materials saved on our servers prior to final submission) or any other written, telephonic, videoconference or other electronic means. We also may Process your social security number for tax reporting purposes. We otherwise do not Process sensitive personal information.
Do we collect any personal information from third parties? We may collect personal information from third parties, such as our partners, service providers, vendors, publicly available sources such as websites and social media accounts and any third-party tracking technologies that we use in connection with our Services. Learn more about personal information you provide to us or that we otherwise may collect about you.
How do we Process personal information? We Process your personal information, among other ways, to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We also may Process your personal information for other purposes with your consent. Learn more about how we Process your personal information.
In what situations and with which parties do we share personal information? We may share personal information in specific situations and with specific third parties, including, among other third parties, our vendors, service providers, fundraising partners and donors. Learn more about when and with whom we share your personal information.
How do we aim to keep personal information safe? We have physical, organizational and technical processes and procedures in place designed to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat or circumvent our security and improperly Process your personal information. Learn more about how we aim to keep personal information safe.
What are your rights with respect to your personal information? Depending on where you are located geographically, applicable privacy laws and regulations may provide you with certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below. We will consider and act upon any request in accordance with applicable privacy laws and regulations.
TABLE OF CONTENTS
Page
1......... WHAT PERSONAL INFORMATION DO WE COLLECT?................................. 1
2......... HOW DO WE PROCESS YOUR PERSONAL INFORMATION?....................... 4
3......... WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? 5
4......... WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 7
5......... DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?........... 9
6......... HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?................. 10
7......... HOW DO WE AIM TO KEEP YOUR PERSONAL INFORMATION SAFE?... 11
8......... DO WE COLLECT PERSONAL INFORMATION FROM MINORS?.............. 11
10....... HOW DO YOU EXERCISE YOUR RIGHTS?.................................................... 14
11....... CONTROLS FOR DO-NOT-TRACK FEATURES.............................................. 15
12....... DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?............................... 15
13....... HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?............. 16
1. WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal Information You Provide
In Short: We collect personal information that you voluntarily provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you access or use our Services, or otherwise when you contact or interact with us. The personal information that we collect depends on the context of your interactions with us or our Services, the choices you make, and the Services you use.
The personal information we collect may include, for example, the following:
· basic personal details, including, for example, your name, billing address, mailing address, phone number, email addresses and any other contact details you may provide;
· personal characteristics, including, for example, your signature, physical characteristics, gender, preferred pronouns, language fluencies, description or biographical information;
· information you provide to us about other individuals associated with you (including your emergency contacts and your personal and professional references);
· details of any institutions or organizations you are or were associated with (including any position or title you may hold or have held at such institutions or organizations);
· employment and educational history;
· citizenship and other related information you may provide;
· any work product you may provide;
· photos, videos and/or audio recordings of you;
· opinions, statements or other personal information provided by you;
· social security numbers (or equivalent) and other tax reporting information;
· payment, banking or other financial information, including, for example, payment instrument numbers (and any associated security codes) and account statements; and/or
· details of your interactions with us or in connection with our Services, including, for example, any application forms (including unfinished application forms and related materials saved on our servers prior to final submission) and other written, telephonic, videoconference or electronic contacts.
You are solely responsible for ensuring that all information that you provide to us is true, complete, and accurate and that you have the right to provide it to us. You must notify us of any changes to your personal information. We are not responsible for any errors or omissions in any information that you provide to us.
We, or our third-party vendors, may collect personal information necessary to Process your payment if you choose to make donations or purchases, such as your payment instrument number, and the security code associated with your payment instrument. Unless you choose to submit such information directly to us, such as through a check or a wire transfer, all such payment data is Processed by Blackbaud. You may find their privacy notice link(s) here: https://www.blackbaud.com/company/privacy-policy/north-america.
Although we do not request or require sensitive personal information other than as described herein to provide, improve, and administer our Services, we may collect such information to the extent you choose to provide such information to us, including through any application forms (including unfinished application forms and related materials saved on our servers prior to final submission) or any other written, telephonic, videoconference or other electronic means. We otherwise do not Process sensitive personal information.
Personal Information Automatically Collected
In Short: Some personal information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you access or use certain of our Services (or certain features or functionalities thereof).
We automatically collect certain personal information when you access or use certain of our Services (or certain features or functionalities thereof). This personal information may not necessarily reveal details such as your name or contact information but may include device and usage information, including, for example, your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you access or use our Services, and other technical information.
Like many businesses, we also collect personal information through cookies and similar technologies, including personal information collected from Google APIs. For more information, see “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?”
The information we automatically collect may include, for example:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log and usage data may include your IP address, device information, browser type, and settings and information about your activity in our Services (such as the date/time stamps associated with your access or usage, pages and files viewed, searches, and other actions you take such as which features you access or use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access or use our Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much location data we collect depends on the type and settings of the device you use to access or use our Services. For example, we may use your IP address or other geolocation data that tells us your current location. You can opt out of allowing us to collect this information by modifying the settings on your device. However, if you choose to opt out, you may not be able to access or use certain aspects of our Services (or certain features or functionalities thereof).
Personal Information from Third Parties
We may collect or receive personal information from third parties, such as our partners, service providers, vendors, publicly available sources such as websites and social media accounts and any third-party tracking technologies that we use in connection with our Services. For more information on such third-party tracking technologies, see “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?”
We also may collect personal information about you from any individuals, institutions or organizations that you reference (such as designating such individuals, institutions or organizations as a personal reference) when submitting any applications, work product or other correspondence to us. We are not responsible for any errors or omissions in any information provided by such individuals, institutions or organizations to us.
Consequences of Failing to Provide Personal Information
Providing your personal information is voluntary. If you do not agree with our Processing of your personal information as set forth in this Privacy Notice, you should not submit your personal information to us. However, where personal information is required to satisfy an obligation to comply with applicable laws or regulations or a contractual requirement, participate in an event or access or use a Service (or certain features or functionalities thereof) failure to provide such personal information may result in your inability to access or use our Services (or certain features or functionalities thereof). Further, if you exercise your rights in such a manner to prevent us from Processing your personal information, please note that we may not be able to perform some of the tasks we need in order to provide certain Services (or certain features or functionalities thereof) to you.
2. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?
In Short: We Process your personal information, among other purposes, to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We also may Process your personal information for other purposes with your consent.
We may Process your personal information for a variety of reasons, depending on how you access or use our Services or otherwise interact with us, including, for example, the following:
· to provide our Services and other information that you have requested or indicated interest in (including, for example, in connection with any application or work product you submit to us or otherwise save on our servers);
· to contact you for fundraising and administrative purposes;
· to troubleshoot, improve or personalize our Services, including, for example, enhancing your browsing experience of our websites, serving personalized advertising or content and analyzing traffic;
· to determine your eligibility or candidacy to access or use any of our Services, including, for example, any fellowships or other awards we offer;
· to understand and analyze the demographics, behavior and preferences of individuals who access or use our Services;
· to confirm your identity;
· to detect and prevent misuse or abuse of our Services;
· to collect and process payments;
· to publish content in, or otherwise contribute content to, our or third-party social media, websites, podcasts, books, magazines or any other form or format of media now known or hereafter devised;
· to display as part of historical or cultural exhibits or exhibitions;
· to further our promotional and fundraising activities;
· to fulfill our contractual obligations to other third parties to whom you have provided you personal information;
· to operate our websites and information technology systems and safeguard their security and fraud prevention;
· for our internal business administration, analytics, reporting, archival, recordkeeping and security purposes;
· for legal and regulatory compliance purposes, including, for example, as necessary to respond to governmental, regulatory or law enforcement agency requests or comply with requirements relating to tax, anti-money laundering, politically exposed persons and sanctions checks;
· to provide information as may be necessary in connection with corporate transactions, including, for example, financings, restructuring, asset sales, mergers or acquisitions; and/or
· to save or protect an individual’s vital interest, such as to prevent harm.
From time to time, we will provide you with information on our Services and other activities we engage in, including our fundraising activities, content that we publish or other events sponsored by us. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate reports on your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing messages or at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
We may aggregate, anonymize or otherwise de-identify your personal information and use it for any purpose permitted by applicable laws and regulations, and we may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws and regulations. We also may use your personal information for any other purposes disclosed to you at the time of collection, that you have previously authorized, or with respect to which you subsequently provide your consent.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
The following section applies only if you are a resident of the European Economic Area (including Switzerland for the purposes of this Privacy Notice, “EEA”) or the United Kingdom (“UK”):
In Short: We only Process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable laws and regulations, such as with your consent, to comply with laws and regulations, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate interests.
Residents of the EEA and the UK (“EEA/UK Residents”) have certain rights with respect to their personal information pursuant to the General Data Protection Regulation (including its Swiss equivalent for the purposes of this Privacy Notice, the “GDPR”) and UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), as applicable and as further described in this section.
To the extent applicable, the GDPR and the UK GDPR require us to explain the valid legal bases we rely on in order to Process your personal information. As such, we may rely on the following legal bases to Process your personal information:
Consent. We may Process your personal information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Legal Obligations. We may Process your personal information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body, governmental entity or regulatory agency; establish, exercise or defend our legal rights or in connection with litigation, inquiries or other proceedings in which we are involved.
Contractual Obligations. We may Process your personal information where we believe it is necessary for the performance of a contract with you for provision of our Services or to take steps at your request prior to entering into such a contract.
Legitimate Interests. We may Process your personal information where we believe it is necessary for our legitimate interests.
Vital Interests. We may Process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
The following section applies only if you are a resident of Canada:
We may Process your personal information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, in situations where your permission can be inferred (i.e., implied consent), or otherwise where required or permitted under applicable law. You can withdraw your consent at any time by contacting us by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share your personal information to third parties as described in this section.
We do not disclose your personal information except as detailed in this Privacy Notice. We may share your personal information to the following categories of third parties:
· vendors and service providers in order for them to provide us with certain services, including, for example: (i) legal counsel, (ii) accountants, (iii) audit firms, (iv) banks, (v) tax consultants and preparers, (vi) fundraising consultants, (vii) financial advisors, (viii) vendors or service providers supporting our IT systems, (ix) payment processors, (x) event organizers and (xi) other contractors or consultants;
· third parties for purposes of complying with various legal and regulatory reporting obligations;
· third parties for business, fundraising or marketing purposes, such as sharing application, engagement and donation data with our partners;
· third parties, such as other individuals participating in events we organize or otherwise accessing or using our Services, for purposes of facilitating, or otherwise in connection with, your access or use of our Services;
· third parties who subscribe to or otherwise access our content published in, or otherwise contributed to, blogs, social media, websites, podcasts and other mediums (to the extent your personal information is included therein);
· law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. or of other countries who request or require such information;
· any person or entity, including, for example, any governmental agency, regulatory authority (e.g., the U.S. Securities and Exchange Commission) or self-regulatory organization having jurisdiction over us, if (i) we determine in our discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non U.S., law, rule, regulation, executive order or policy, including, for example, any anti-money laundering law, the USA PATRIOT Act of 2001 or any subpoena, court order or judicial process, and (ii) such disclosure is not otherwise prohibited by applicable law, rule, regulation, executive order or policy;
· future or potential purchasers or merger partners (i) for due diligence purposes on a need to know basis, (ii) as necessary for pre-closing integration planning, or (iii) in connection with the consummation of a asset sale, merger or acquisition; and/or
· current, future or potential lenders or other relevant persons as necessary in connection with other corporate transactions, such as financings or restructurings.
In addition, we may disclose personal information directly to law enforcement, regulators or competent authorities, or indirectly to our advisers or service providers who may make such filings or disclosures on our behalf, as follows:
· if we reasonably consider that such disclosure is necessary or advisable to help prevent or detect fraud or other crimes or to protect our rights, property or safety, or that of our business partners, event participants or others; or
· if we are under a duty to disclose or share your personal information with tax authorities, who may transfer your personal information to the government or the tax authorities in another country where you may be subject to tax.
We may share your personal information with our affiliates that are subject to this Privacy Notice.
If you reside in Canada, please note that we and our service providers may access, store and otherwise process personal information outside your province and outside Canada. For more information about our use of service providers outside Canada, please contact us as set out under “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
The following section applies only if you are an EEA/UK Resident:
For purposes of the GDPR and the UK GDPR, we are a “controller” of EEA/UK Residents’ personal information, which we may transfer outside of the EEA or the UK to the U.S. and certain other destination countries. The laws and regulations of such destination countries may not offer the same standard of protection for personal information as countries with the EEA or the UK. We Process personal information primarily in the United States (and may do so in certain other countries), and EEA/UK Residents’ personal information also may be Processed by personnel operating outside the EEA or the UK on our behalf.
In cases of cross-border transfers to destination countries outside of the EEA or the UK, as applicable, if your personal information will be Processed in a country with laws and regulations that may not be equivalent to, or as protective as, the laws and regulations of your home country, we will take appropriate steps, in accordance with applicable laws and regulations, to require or maintain an adequate level of protection and security for your personal information.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to Process your personal information.
We may use cookies and other tracking technologies (like web beacons and pixels) to gather personal information when you access or use our Services. Most Web browsers are set to accept cookies by default and permit you to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain Services (or certain features or functionalities thereof).
Cookies and other tracking technologies help us enhance your browsing experience of our websites, serve personalized advertising or content, analyze traffic, maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic website functions.
We also may permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertising or content or to tailor content to your interests. The third parties and service providers use their technology to provide advertising or content about products and services tailored to your interests which may appear either on our Services or on other websites.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in the Cookie Consent Preferences found on our website at https://www.gf.org.
Google Analytics
We may Process your personal information with Google Analytics to track and analyze the use of our Services. To opt out of being tracked by Google Analytics across our Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
The following applies only if you are a resident of Canada:
Opting-out of Interest-Based Advertising: To adjust your preferences or exercise control over the third parties who collect personal information on our website at https://www.gf.org for interest-based advertising purposes, please click the “Cookie Preferences” icon that is available in the footer of such website. For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
· Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect personal information for other purposes including analytics and you may still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
· To successfully opt-out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt-out, if you delete your browser’s saved cookies, you will need to opt-out again.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In Short: We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
We will keep your personal information for at least as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, regulatory or other legal requirements). When determining relevant retention periods, we take into account factors, including, for example, the following:
· the purposes for which such personal information was collected;
· our contractual and business relationships with you;
· compliance obligations under applicable laws and regulations to retain personal information for a certain period of time;
· the amount, nature and sensitivity of your personal information;
· the potential risk of harm from unauthorized processing of your personal information;
· statutes of limitation under applicable laws;
· active or potential disputes; and
· guidelines issued by relevant supervisory authorities.
7. HOW DO WE AIM TO KEEP YOUR PERSONAL INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of physical, organizational and technical security measures.
We have physical, organizational and technical processes and procedures in place designed to protect your personal information, including a privacy governance framework designed to ensure compliance with legal obligations (including with respect to the retention and destruction of personal information) and guide our employees with respect to the treatment of personal information throughout the lifecycle of such personal information. However, despite our safeguards and efforts to secure your personal information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat or circumvent our security and improperly Process your personal information. Although we will aim to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access and use our Services within a secure environment.
In the course of your access or use of our Services or your interactions with us, you may access or use services, websites, content or platforms provided by, or otherwise interact with, third parties (“Third-Party Services”), which are provided for your convenience only. This Privacy Notice does not apply to or govern the practices of third parties that we do not own or control. We encourage you to read the terms of use, privacy policies and notices applicable thereto, which may differ from ours. Our links to or displays of any advertisements for Third-Party Services do not mean we endorse any Third-Party Services, the terms of use, privacy policies or notices applicable thereto, or the privacy or security practices of the relevant third parties. We expressly disclaim responsibility or liability for any Third-Party Services or for the policies and practices followed by any third parties and accept no responsibility therefor or any loss or damage that may arise therefrom. If you decide to access or use any Third-Party Services, you do so entirely at your own risk and subject to the terms of use, privacy policies and notices applicable thereto.
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
In Short: We do not knowingly collect personal information from or market to minors under 18 years of age.
We do not knowingly allow minors under 18 years of age to use our Services, and we do not knowingly collect, solicit data from, or market to minors under 18 years of age. By accessing or using our Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such minor and consent to such minor’s access and use of our Services. If you are under 18 years of age or are not the parent or guardian of such minor, then please do not provide us with such minor’s personal information at any time or in any manner. If we learn that we have collected personal information from persons under 18 years of age and without verifiable parental consent, then we will take reasonable measures to promptly delete such personal information from our records. If you are a parent or guardian and discover that your child under 18 years of age has provided us with personal information, please contact us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on where you are a resident, you may have certain rights with respect to your personal information.
The following section applies only if you are a resident of the United States:
Depending on the state in which you reside, you may have certain rights, including, for example, those listed below:
· right to know whether or not we are Processing your personal information;
· right to request access to and receive details about the personal information we maintain about you and how we have Processed it;
· right to correct inaccuracies in, obtain a copy of, or request the deletion of your personal information;
· right to non-discrimination for exercising your rights;
· right to opt out of the Processing of your personal information if it is used for targeting advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects;
· right to access the categories of personal information being Processed;
· right to obtain a list of the categories of third parties to which we have disclosed personal information;
· right to limit use and disclosure of sensitive personal information;
· right to withdraw your consent to our Processing of your personal information; and/or
· right to opt out of the collection of sensitive personal information collected through the operation of a voice or facial recognition feature.
For residents of California, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
The following section applies only if you are a resident of the EEA, the UK or Canada:
In some regions (like the EEA, the UK and Canada), you have certain rights under applicable privacy laws and regulations under certain circumstances.
In the EEA and the UK, under certain circumstances, by law you may have the right to:
· request access to your personal information;
· request rectification or erasure of your personal information;
· object to the Processing of your personal information where we are relying on a legitimate interest (or that of a third party);
· request the transfer of your personal information to another party in a machine-readable, commonly used and structured format;
· restrict the Processing of your personal information; and/or
· request not to be subject to automated decision-making.
If you are located in the EEA or the UK and are not satisfied with our response to your complaint or believe our Processing of your personal information does not comply with the GDPR, the UK GDPR or other applicable privacy laws or regulations, you also have the right to complain to the supervisory authority in your country. For example, in the UK, you should contact the Information Commissioner’s Office at https://ico.org.uk/global/contact-us/ or +44 0303 123 1113.
In Canada, subject to applicable law, you have the right to access, update, rectify and correct inaccuracies in, and withdraw consent to the Processing of, your personal information in our custody or control. You may make such a request or withdraw consent by emailing us using the contact information in the “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” section below. We may request certain personal information for the purpose of verifying your identity. If you reside in Quebec, you may also have the right to receive a copy of your information (including in a structured, commonly used technological format), or to have us share it with an authorized third party in certain circumstances and you may also have the right to request that we cease disseminating or de-index (or re-index) your personal information.
The following section applies only if your personal information is subject to privacy laws and regulations of jurisdictions other than the United States, the EEA, the UK or Canada:
To the extent that privacy laws and regulations of jurisdictions other than the United States, the EEA, the UK or Canada (“Other Foreign Privacy Laws”) apply to our Processing of your personal information, you may have certain rights with respect to such personal information (including, depending on the jurisdiction, rights that may be comparable to those of EEA/UK Residents, as described above). In such case, we will follow such other applicable Other Foreign Privacy Laws with respect to your rights, and the description herein of the rights of EEA/UK Residents, as and to the extent applicable, shall be considered notice of your rights to the extent that we are required to provide you with such notice under such applicable Other Foreign Privacy Laws.
10. HOW DO YOU EXERCISE YOUR RIGHTS?
To exercise the rights discussed herein, you can contact us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below if you are a resident of the applicable jurisdiction. The rights discussed herein are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your personal information needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement. We will consider and act upon any request in accordance with our policies and procedures and applicable privacy laws and regulations.
We will respond to your request within the period of time required by applicable privacy laws or regulations (e.g., one month under the GDPR and the UK GDPR). In some cases, we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
Under the GDPR and the UK GDPR, you will not have to pay a fee to exercise any of the rights granted thereby. In some cases, we may charge a reasonable fee if your request is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.
Withdrawing Your Consent
If we are relying on your consent to Process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below.
However, please note that this will not affect the lawfulness of the Processing before its withdrawal nor, when applicable law allows, will it affect the Processing of your personal information conducted in reliance on lawful Processing grounds other than consent.
What We May Need From You
To exercise any of the rights discussed herein, we may need to request specific information from you to help us verify your identity to determine you are the same person about whom we have personal information in our systems. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
Under certain U.S. state privacy laws, you can designate an authorized agent to make a request on your behalf. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Appeals
Under certain U.S. state privacy laws, if we decline to take action regarding your request, you may appeal our decision by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?” below. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for our decision. If your appeal is denied, you may submit a complaint to your state attorney general.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicate your choice not to be tracked online.
12. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?
In Short: Yes, we may update this Privacy Notice from time to time in our sole discretion.
We may update this Privacy Notice from time to time in our sole discretion. The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification or both. We encourage you to review this Privacy Notice frequently to be informed of how we are Processing your personal information. Your continued provision of personal information to us or access or use of our Services after we notify you of material changes constitutes your acceptance of such changes. If you do not want to agree to any revised Privacy Notice, you should not continue to access or use our Services.
13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY NOTICE?
If you have questions or comments about this Privacy Notice, or to exercise your rights over your personal information (as and to the extent required under applicable law), you may email us at info@gf.org or contact us by post at:
John Simon Guggenheim Memorial Foundation
90 PARK AVE
New York, NY 10016
United States
[1] For the purposes of this Privacy Notice, the term “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable laws and regulations, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679 or the UK General Data Protection Regulation (i.e., the General Data Protection Regulation (EU) 2016/679 as implemented into the laws of the United Kingdom).