Master Privacy and Cookie Policy

Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation has implemented this Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation Website, located at https://www.tawanifoundation.org/ (the “Website”) and to demonstrate our commitment to the protection of your privacy. This Privacy Policy is effective as of November 2020.

This Website is operated by Tawani Enterprises Inc. on behalf of ourselves and our group companies (“we”, “our” or “us”).

We recognize that when you choose to provide us with your Personal Data, you trust us to act in a responsible, transparent and responsible manner. We take your privacy very seriously. Please read this Privacy Policy carefully as it explains what  information we collect and why, how we use your Personal Data, and how you can exercise your privacy rights under  either the General Data Protection Regulation (“GDPR”) or the California Consumer Privacy Act (“CCPA”), as applicable.

This Privacy Policy is only applicable to the Website, and not to any other websites that you may be able to access from the Website, each of which may have data collection and use practices and policies that differ materially from this Privacy Policy. This Privacy Policy also does not apply to any third party applications or software that integrate with our Website, or any other third party products, services or businesses (collectively, “Third Party Services”), which are governed by their own privacy policies. By using the Website, you are agreeing to the terms of the Privacy Policy.

This Privacy Policy applies to all information collected through the Website as well as any related services, sales, marketing or events.

If you have any questions or concerns about this Privacy Policy, or our practices with regards to your Personal Data, please contact our privacy officer using the below details:

Privacy Officer
Tawani Enterprises Inc.
104 S Michigan Ave Chicago, IL 60603, USA
jon.lyons@tawani.net

Notification of Privacy Policy Changes

We reserve the right to change the Privacy Policy at any time. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. Your continued use of the Website, including use after the posting of any changes to these terms, will be deemed an acceptance by you of the Privacy Policy.

  1. INFORMATION COLLECTION PRACTICES
  1. What Personal Data Does Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation Collect and How?

“Personal Data” describes information that is capable of identifying specific users (also termed ‘Data Subjects’).  All Personal Data is collected and processed fairly and lawfully, and in a way that respects your rights and is permitted by law. Examples of Personal Data we collect include:

  • your name, phone number, email address, gender, location information, birthday, when you complete optional information request forms such as Newsletter subscription forms, and general contact request forms on our website. These forms may sometimes request you provide other Personal Data to help us determine your needs related to our products and services.
  • We also collect customer testimonials, which may contain personally identifiable information such as your name and details of your experience.
  • We may collect data necessary to process any payments you make (“Payment Information”).
  • Data collected through “cookies” and “web beacons”, including through the use of Google Analytics and other online analytics providers, in line with your cookie policy (below).
  1. How we use your Personal Data

Personal Data from option information request forms

 We use the Personal Data collected from the optional information request forms to discuss your interest in our company and services, to send information and updates about our company, such as promotions and events, and to contact you if requested or necessary. Depending upon your request, Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation may also ask for additional information, such as how you heard about us. This information is provided by you on a voluntary basis only and is not required by us in order for you to use and enjoy the Website. Information collected may also be used to improve the services we provide to you, to relay administrative information, and to verify login information.

Testimonials

We may also post customer testimonials on the Website which may contain personally identifiable information such as the customer’s name. Prior to posting the testimonial, we do obtain the customer’s consent to post their name along with their testimonial.

Notifications and One-Time E-mails

Upon successfully submitting information to us such as making a purchase, booking a reservation, entering a sweepstakes, completing a survey or any other related action where you voluntarily provide us information, we may send you an e-mail notification (either a single message or a finite campaign) pertaining to that event where no opt-out is required.

Processing Payments

We use a third party payment processor, currently ResNexus (the “Payment Processor”) (see below), to assist in securely processing your Payment Information. If you pay with a credit or debit card, the Payment Information that you provide through the Website will be encrypted and transmitted directly to ResNexus. We do not store your Payment Information and do not control and are not responsible for the Payment Processor’s collection or use of your information. You may find out more about how ResNexus stores and uses your Payment Information through its privacy policy.

Disclosure to Third Parties

We may provide your Personal Data and the data generated by cookies to third parties. Such third parties may include Google Analytics and other online analytics providers as well as third party software providers that we may engage to assist us in providing you with services and ensure we give you a better experience. Such third party entities will be obligated to use your personal data solely in connection with our services, and for no other purpose.

  1. Cookie Policy

What are cookies and how do they work?

The Website uses “cookies” and “web beacons” to collect data, including through the use of Google Analytics and other online analytics providers as described below.

A “cookie” is a small text file that contains a random and unique identifier that either Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation or its third party web analytics provider on behalf of Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation transfer to your computer’s hard drive through your web browser (unless you adjust your browser settings to reject cookies). This enables Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation or its third party web analytics provider’s system to recognize your browser and track your movement through the Website. While cookies do identify a user’s computer, they do not personally identify users and passwords and credit card information is not stored in cookies.

“Web beacons” (also known as clear gifs) are typically a transparent graphic image which, in combination with cookies, help us understand how you interact with the Website. We use web beacons to measure visitor behavior, help us improve visitor experience, and manage site content.

If you don’t like cookies, you can disable them altogether (please refer to the Help function on your browser settings). Please note that the Website relies on some of these cookies for functionality. If these are disabled, the Website may not work properly. Alternatively, if you want to disable certain types of cookies from this Website, you can do so by clicking on  Preferences

What sort of cookies do we use?

We use the following types of cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our Website and are necessary to enable the basic features of the site to function and to do so securely and optimally. For example, these cookies themselves allow you to select your cookie preferences.

Functional cookies: These cookies allow us to analyze your use of the site to help us improve your experience. They also allow us to recognise you when you return to our Website, and enable us to store your preferences (for example, your choice of language or region), personalise our content for you, greet you by name, store your settings and allow you to sign-in where necessary. We also use these cookies to combat fraud.

Performance cookies: These cookies allow us to recognise and count the number of visitors, and to see how visitors move around our website when they are using it, so we can see how our services are performing. These cookies may track things such as how long you spend on the Website or pages you visit and are used for the legitimate purpose of improving the way our Website works by, for example, ensuring that you find what you are looking for easily.

Analytical cookies: These cookies are used to track point of entry to point of registration for those users participating in our affiliate signup programs, and to track and measure the success of a particular marketing campaign. Some of these analytical cookies are processed by third parties, including Bounteous Inc. which is an online analytics company that partners with Google Inc to provide analytical data. This data also helps us understand how our users are interacting with the Website. To disable these types of analytical cookies, please go to Preferences

Targeting cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed to make our Website more relevant to your interests and provide you with interest-based advertising. We may also share this information with Bounteous for these purposes. Data collected may includes user journey, gender, geolocation, affinity interests. To enable or disable these cookies, please go to Preferences

  1. Retention

Unless you withdraw your consent (see below for more information on this), we will keep your Personal Data for as long as is necessary for the purpose for which it is collected or used. The actual time will depend on the type of relationship you have with us, the nature of the data and the purpose for which it is used. However, we will periodically review all data at reasonable intervals, taking into account the purpose and use of your information both now and in the future (including whether it is necessary to store that information to perform our obligations under a contract), whether we have any legal obligation to continue to process your information (such as record-keeping obligations imposed by relevant law or regulation), and whether we have any legal basis to continue to process your information, in order to ensure our records are accurate and up-to-date. We will delete any data no longer required for our legitimate interests or any other purpose (such as for legal compliance). Please also keep us informed if your information is no longer accurate or otherwise up-to-date.

  1. Updating and Choice/Opt-Out

If you are subscribed to receive newsletters or commercial emails from us, you may send us a request to unsubscribe from receiving such emails at any time by following the unsubscribe instructions within the email. We will comply with your unsubscribe request promptly. See ‘Your Rights’ section below and the ‘Right to Withdraw Consent at Any Time’.

  1. Sale of Business or Assets

In order to accommodate changes in our business – which is one of our legitimate interests – we may sell or buy portions of our company or other companies or assets. In such transactions, visitor information may be one of the transferred assets. In the event that all or substantially all of Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation assets are acquired in a transaction, our visitor information may be an asset that is reviewed and transferred. Such a transaction will be disclosed per the “Notification of Privacy Policy Changes” guidelines above.

  1. Security, Storage and Privacy

Your privacy is important to us, as is the security of your information. We ensure all information is collected and stored in a manner that is appropriate for the nature of the data that we collect, and the need to fulfil your request. Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation does not share, sell, rent, or trade Personal Data with third parties for their promotional purposes.

We have implemented measures to protect against the loss, misuse, and alteration of your Personal Data. The Website uses security measures to help protect against the loss, misuse, and alteration of the information under our control. We store the information in two redundant databases in two secure environments at different locations with our data hosting service provider. We also use computer safeguards such as firewalls and data encryption and physical access controls to our buildings and files.

However, no computer or other safeguards can be 100% secure from malicious intrusion, hackers or other unauthorized access. Therefore – although we use appropriate technical and organisational measures to protect your Personal Data  that are proportionate to the state of the art, the costs of implementation and the nature, scope, context and purposes of processing the Personal Data as well as the risk of varying likelihood and severity for your rights and freedoms – we cannot guarantee that impenetrable security measures are in place or the illegal and/or unforeseen activity of third parties that may allow them to get around the robust privacy or security measures in place. For example, we cannot control any illegal and/or unforeseen activity of other users that may allow them to get around the privacy or security settings on the Website.

We will take prompt corrective action if we discover any failure to comply with this Privacy Policy and notify you promptly if you are affected. Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation  will not be liable for any incidental, indirect, consequential or punitive damages or for loss of profit or opportunity, loss of use or other financial loss arising out of or relating to this Privacy Policy.

Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation is not responsible for the privacy practices or the content of any other websites to which we link. We encourage our visitors to read the privacy statements of each and every website that they visit.

Further, where applicable, we use ResNexus for our online reservation services. More information about ResNexus can be found at www.resnexus.com. ResNexus uses industry-standard encryption to protect your personal and payment information during and after your reservation. After your reservation is complete, the system removes your credit card information to prevent theft or disclosure. ResNexus meets or exceeds rigorous industry standards for protecting credit card information and is PCI compliant. This PCI compliance has been verified by an external auditor.

  1. Legal disclosure

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Website, or to protect the health and safety of our employees or the general public.

  1. Children under the Age of 13

Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, please do not provide any information on this Website.

  1. Links to Other Sites

 This Website contains links to other sites that are not owned or controlled by Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation . Please be aware that we, Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation , are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personal data, should you have any concerns. This Privacy Policy applies only to information collected by this Website.

  1. Online Privacy Policy Only

This Privacy Policy applies only to information collected through the Website.

  1. PRIVACY POLICY ADDENDUM AND EU CITIZEN MEMBER RIGHTS UNDER THE GDPR

This addendum to our Privacy Policy outlines European Union data subject rights under the GDPR. Certain rights may not apply to website users outside of the EU.

Name and Address of the controller

The Data Controller for the purposes of the GDPR, and other data protection legislation is:

Tawani Enterprises Inc.

104 S Michigan Ave Chicago, IL 60603, USA

jon.lyons@tawani.net

Phone: (312) 374-9455

Any EU data subject may, at any time, contact our Privacy Officer directly at the above email address to exercise any of the rights listed below or generally with any questions and suggestions concerning data protection.

B1.       YOUR RIGHTS UNDER THE GDPR

Under the GDPR you have the following rights:

  • Right to be informed – the right to receive the information contained in this policy about the way we process your personal data. ‘Processing’ through this Privacy Policy means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.
  • Right of Access – the right to know if we are processing your personal data and, in most circumstances, to have a copy of any personal data of yours that we hold. You can also ask for certain other details such as what purpose we process your data for and how long we hold it. You will not have to pay a fee to exercise these rights, although we may charge a fee if your request is unfounded (for example, we have told you that we do not hold any of your personal data), disproportionate, repetitive or excessive.
  • Right to rectification – You have the right to request that we correct inaccurate data or complete incomplete data that we hold on you.
  • Right to erasure – Known as the Right to be forgotten. In certain circumstances you may request that we erase your personal data held by us. For example, where it is being held for longer than is necessary in relation to the purpose for which it was collected and stored, or to comply with a legal obligation.
  • Right to restrict processing – You have the right to restrict the way we process your personal data in certain circumstances. For example if you contest the accuracy of the data, if our processing is unlawful, to pursue legal claims, or you otherwise object to our processing but do not wish for us to erase your personal data.
  • Right to object – You have the right to object to us processing your data for (i) direct marketing purposes (ii) research or statistical purposes and (iii) purposes of profiling related to direct marketing or based on our legitimate interests.
  • Right to data portability – you have the right to receive a copy of certain personal data in a structured and readable format, or to have it transferred to another organisation where technically feasible and it does not affect the rights and freedoms of others.
  • Right to Withdraw Consent at Any Time – Where we use your Personal Data based on your prior consent, such as where you have given us permission to send you marketing communications by email, mobile messaging or by direct message on social media, you can withdraw your consent at any time by contacting us. See above ‘Choice/Opt Out’
  • Right to escalate a complaint to the Data Protection Authority – You have the right to be confident that Col IL James N Pritzker Charitable Distribution Fund dba TAWANI Foundation handles your Personal Data responsibly and in line with good practice. If you have any concerns about the way we are handling your information, then in the first instance you should raise this with us via our Privacy Officer (details in section A.1. of this Privacy Policy). We will take your concern seriously and work with you to try to resolve it. However if you are still unhappy with our response you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
  1. PRIVACY POLICY AMENDMENT REGARDING THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) 
  1. Residency

If you are resident in California, or otherwise domiciled in California but outside for a temporary or transitory purpose, a number of rights and obligations will apply to your personal data. Categories of personal data collected over the last 12 months are as set out at section A.1. of this Privacy Policy.

  1. Your Rights with respect to your personal data

 Your rights under the CCPA are as follows:

  • Right to be informed: You have the right to request disclosure of personal information relating to you that we have collected, used, disclosed, or sold within the past 12 months. If we collect personal information about you, you have the right to request disclosure of:
    • The categories and specific pieces of personal information we have collected about you;
    • The categories of sources from which we collected that information;
    • The business or commercial purpose for collecting your personal information; and
    • The categories of third parties with whom we share your personal information.
  • Right of request deletion of the data: If we collect personal information directly from you, you have the right to request that we delete your personal information that we collect or maintain.
  • Right to opt-out from future selling of your personal data: If we sell information about you, you have the right to request that we stop selling your information (an “opt-out request”).
  • Right to non-discrimination for the exercise of consumer privacy rights: You have the right not to be discriminated against for exercising any of your CCPA rights. As provided by the CCPA, we reserve the right to provide services that are reasonably related to information that you may choose to provide to us.
  1. Exercising these rights

In order to exercise any of these rights, please send us an email to the Privacy Officer at the above address.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us.

For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, 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. We will delete such additionally provided information as soon as we finish verifying you.

 

UPDATED: November 2020