Last Revised: 01/01/2021
The United States Foundation for the Commemoration of the World Wars, DBA The Doughboy Foundation (“ we” or “ us” or “ our”) operates the website at https://Doughboy.org and its subpages, subdomains, desktop and mobile versions, including all content, materials, features, applications, functionality, products and services made available on such website (the “ Website”).
Information We May Collect.
Depending on the circumstances, we may collect and hold different information about you, including information that identifies you as an individual or relates to an identifiable person, such as your name, contact details (including mailing address, email address or phone number), username or password, and information about how you use the Website (“Personal Information”).
How We Collect Personal Information.
We may collect Personal Information from you in a variety of ways, including, but not limited to:
a. Directly from you, such as where you provide information to us when you visit the Website, create an account on the Website, request downloads or upload or post content to the Website, make a donation, subscribe to our newsletter, contact us with a question or request, place an order for products or services with us, voluntarily submit any information to us, enter into any sweepstakes, contest or other promotion through the Website or use the Website in connection with other activities, services, features or resources we make available on the Website. In particular:
i. If you create an account on the Website, you may be asked for your name, title, affiliation, email address, mailing address and/or phone number. You may use the Website as a guest and not create an account in order to use it. However, not all functionality may be available to you as a user or account holder on the Website.
ii. If you make a donation, you may be asked for your name, email address, mailing address and other information required to process the donation payment.
iii. If you make a donation, your name and donation amount may be displayed on the Website. This is the default option if you do not elect to make a donation anonymously, so by making a donation, you consent to the publication of your name, donation amount and any other comments you provide as part of your donation, unless you elect to make a donation anonymously. If you wish to make a donation anonymously, you may elect to do so by checking the applicable box at the time of the donation. Checking such box will prevent display of your name and donation amount on the Website.
iv. If you submit an Internship Application, you may be asked for your name, email address, phone number, and other information regarding your candidacy including your academic and professional qualifications.
v. If you enter into any sweepstakes, contest or other promotion through the Website, you consent to the publication of your name and any other information that the sweepstakes, contest or other promotion rules provide will be made public. Separate rules may apply.
b. From publicly available sources of information which may include but is not limited to:
a. Military service records
b. Political campaign contribution records
c. Public records such as home ownership
d. Public records such as service on boards
How We May Use Personal Information.
We may use your Personal Information for the following purposes:
a. To present the Website to you and other users, including all content, materials, features, applications, functionality and services made available on the Website.
b. To provide you with notices about your account.
d. To send you information you requested or subscribed to, including newsletters and updates and information on our organization, activities, fundraising events, our causes and products and services. Please see Section 9 for choices regarding the use of your information.
e. To provide products and services to you that you have ordered or requested, or information about those products and services,
f. To assist you with inquiries, questions, requests or purchases, to enhance your experience on the Website or with our products and services, or to provide you with better customer service.
g. To process and evaluate your application, qualifications, and credentials for an internship with us.
h. To conduct analysis of the Website or products and services made available through the Website, such as developing and improving the Website and/or our products and services.
i. To process payments for an order that you place or donation that you make.
j. To understand how you and other users use the services and resources provided on the Website when you complete surveys, whether online or offline.
k. For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our studies and promotional campaigns, conducting studies and analyzing the results of studies, and operating and expanding our business activities.
l. To fulfill our obligations and enforce our rights arising from any agreements entered into between you and us, such as our Terms & Conditions.
m. If we reasonably believe it is necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our Terms & Conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other users; or (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
n. In any other way we may describe when you provide the Personal Information and for any other purpose with your consent.
How Personal Information Is Disclosed.
We may disclose your Personal Information for the following purposes:
i. We do not sell, trade or rent your Personal Information to any third parties. However, we may disclose your Personal Information to our employees, affiliates or third parties who provide services to us, including service providers and subcontractors that assist us with the purposes for which we use your Personal Information. These services may include technical support, customer inquiries, mailing and shipping operations, billing and payment processing functions, , data analysis, auditing, web hosting, data entry and services provided by professionals such as accountants, lawyers, business advisors and consultants.
ii. For the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business.
iii. To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any dissolution, bankruptcy or similar proceedings).
iv. To your authorized representatives or advisers when you ask us to do so.
v. If we reasonably believe it is necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our Terms & Conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Some Personal Information may be made public. If you create an account on the Website, the name and/or account name you have provided when creating your account may appear on the Website if you publish or post any content on the Website while you are signed into your account, such as when you post comments, send messages, or make a donation (except where you elect to donate anonymously).
We may disclose your Personal Information to any other third party not described above for any other purpose with your prior consent.
“ Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
i. Browser, device and other technical information;
ii. Internet Protocol (“IP”) address;
iii. Pages visited;
iv. Website usage;
v. Information collected through cookies and other technologies; and
vi. Aggregated information
How We Collect Other Information.
We collect Other Information in a variety of ways, including:
i. Automatically through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Website and its services function properly.
ii. Through your use of the Website. When you visit the Website, we may track and collect Website usage data, including but not limited to the date and time your device accessed the Website.
iii. Using cookies. Cookies are pieces of information stored directly on the computer that you are using which allow us or third-party analytics service providers to collect information such as browser type, time spent on the Website, pages visited, language preferences, and other website traffic data. We use the information for security purposes, to facilitate navigation and display information more effectively. We can recognize your computer to assist your use of the Website. For example, we may use tools, such as Google Analytics or Facebook Pixel, to collect technical and navigational information, such as browser type, time spent on our Sites and pages visited. Cookies also allow us to select which of our advertisements are most likely to appeal to you and display them while you are on the Website. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/.
iv. Using tracking technologies. We may use tracking technologies to track you across third party websites.
v. Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Website to, among other things, track the actions of users of the Website to improve the Website and its associated services.
vi. Using your IP Address. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever you access the Website, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We may use IP Addresses for purposes such as calculating usage levels of the Website, helping diagnose server problems, and administering the Website and its associated services. We may block certain IP addresses if they attempt to access the administrative portions of the site without authorization.
vii. From you. Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information to us.
viii. By aggregating information. Aggregated Personal Information does not personally identify you or any other user of the Website (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We Use and Disclose Other Information.
We use and disclose Other Information for any lawful purpose. If we are required to treat Other Information as Personal Information under applicable law, then we use it for all the purposes for which we use and disclose Personal Information in Sections 4 and 5.
In some instances, we may combine Other Information with Personal Information (such as by combining your name with the state in which you live). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
If at any time you would like to unsubscribe from receiving our newsletters or other communications you may opt-out on a going-forward basis, by clicking on the “unsubscribe” link (or similar) provided in the relevant communication. Please note that if you do opt-out of receiving certain emails from us, we may still send you important administrative information, and you cannot opt-out from receiving administrative information.
We will retain your information for as long as your Website account is active or as needed to provide you with services. Please be aware that we will not be able to delete any content you have shared with other users or third parties on the Website or with third party social networking sites.
Third Party Contributors
Certain third parties may make available certain materials, content, data or products via the Website. Such materials, content, data or products may also be made available on the Website via links (“ Third Party Contributors”).
We do not control the content of or websites associated with those Third Party Contributors or the use of your information by those Third Party Contributors. The Third Party Contributors may have their own privacy policies and terms & conditions, and their use, collection and disclosure of your information, even if the collection is via the Website, will be governed by their privacy policies and terms & conditions. So please check each Third Party Contributor’s policies and terms before you submit any information to those Third Parties Contributors, even if you submit that information through the Website. Often, Third Parties Contributors will include links to external websites in their contributions..
The Website may use social plug-ins which are provided and operated by third party social networking sites, such as Facebook’s Like Button or account creation using your social media account information. As a result, you may send to the third party social networking site the information that you are viewing on a certain part of the Website.
You may link your account on a third party social networking site to your Website account. When you create this linkage, some of the information you provide to us from the linking of your accounts may be published on your Website account and your activities on the Website may be displayed to your social network “contacts” on the Website or that third party social networking site.
When you link your Website account to a third party social networking site, such as Facebook, YouTube, Twitter, Pinterest, Instagram or other sites, we may, for example, receive information from the social networking site in accordance with the terms of that social networking site, including your profile information, profile picture, gender, username with your social network account, age range, language, country, contacts list and any other information you permit the social networking site to share with third parties. The information we receive is dependent upon your privacy settings with the social networking site. You should always review, and if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to the Website.
How We Protect Your Personal Information
We adopt appropriate data collection, storage and processing practices and security measures in accordance with industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be fully secure. Please note that we cannot fully ensure or warrant the security of any information you transmit to us or other information which we may obtain from your use of the Websites, and you provide us with your information at your own risk.
All financial transactions are handled via payment portals. The safety and security of your information also depends on you. Where you have chosen an account password for access to certain features of the Website, you are responsible for keeping this password confidential. We ask that you not share your password with anyone and encourage you not to use the same password on the Website as you use on other websites. If you have created an account or have logged onto the Website via your social networking site account (such as through your Facebook account), you are responsible for maintaining the security of your login credentials in accordance with the instructions and policies of the relevant social networking site.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Website account has been compromised), please immediately notify us of the problem by contacting us in accordance with Section 18 below.
Please note that email communications are not always secure; so please do not include credit card information, passwords or other sensitive information in your emails to us.
Accessing and Correcting Your Personal Information
If you have created an account on the Website, you will generally be able to access and update your account details online. We request that you keep your account information as current as possible.
Use of Services by Children
Our services are not directed to individuals under the age of 13, and we request that these individuals do not provide Personal Information through the Website or any services made available through the Website. In the event that we learn that we have collected personal information from an individual under age 13, we will delete that information. If you believe that we might have any information collected from an individual under 13, please contact us at [email protected]
The Website is controlled and operated by us from the United States, and is not intended to subject us to any non-U.S. jurisdiction or law. The Website may not be used in any non-U.S. jurisdiction. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Website and its associated services you consent to the transfer of information to countries outside of the U.S. which may have different data protection rules.
The Doughboy Foundation
Attn: Privacy Officer
PO Box 17586
Arlington, VA 22216
Telephone: (202) 796-2812
Email: [email protected]