PENCIL Privacy Policy: PENCIL, INC. (“PENCIL”) has created this Privacy Policy to explain why we collect particular information and how we will protect your personal privacy. It describes the information that we gather from you, how we use and disclose your information, and the steps we take to protect your information. This policy applies to all information received by PENCIL, both online and offline, on any platforms (including PENCIL’s website, mobile applications, electronic, written or oral communications, collectively “Platforms”). By using the Platform, you consent to the privacy practices described in this Privacy Policy.

PENCIL takes your privacy seriously and your privacy is very important to us. PENCIL will only share your personal information when you give us permission to do so, when it is necessary to further our mission, when we are required to do so by law, or as set forth below. We do not sell our donors’ names or personal information, nor send mailings to our donors on behalf of other organizations. PENCIL may collect information from our donors, volunteers, students, and employer partners in connection with fulfilling our mission of providing students from schools with meaningful workplace experience and internships, including certain information that is required for us to collect in order to comply with all regulatory and legal requirements related to our program (as further detailed below).

How We Use Information We Collect: The information that we collect from you will depend on how you plan to interact with PENCIL. Some examples of information we may ask you to provide to us include:

• Donors: For our donors, we may ask for certain personal information necessary to process your donation, including your name, phone number, address, email address or credit card information. Such information helps PENCIL keep track of the generous gifts that you make over the years (whether online or otherwise) and enables us to provide you with a charitable tax receipt. In order to establish such records, PENCIL may share such information with its third-party vendors who help PENCIL track such information.
• Students: In order to provide our services, students may be sharing personal identifiable information with us. For example, students applying for our internship program will need to provide us with their resumes and certain work papers or government documentation. This information enables us to confirm your eligibility for certain city-sponsored internship opportunities and helps match you with such internships.
• Corporate Partners: For our corporate partners, we may ask our corporate partners to provide us with the names of volunteers who are participating in the program and will be interacting with students for regulatory and legal reasons.
• Volunteers: For our volunteers participating in our program, including volunteers from our corporate partners, we may ask the volunteers to provide us with information, such as the volunteer’s name and zip code, so that we can run background checks before the volunteers meet with the students, as required by law.
• Website Users via Cookies. When you use the Platform, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) (“Cookies”) to your computer or mobile device, to help analyze our web page flow, customize our content, and promote trust and safety. You are always free to decline our cookies if your browser permits, although doing so may interfere with your ability to use the Platform or certain features of the Platform. We may also use Google Analytics or a similar service that uses Cookies to help us analyze how users use the Platform. When you visit the Platform, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Platform, the pages you view on the Platform, your actions on the Platform, and the dates and times that you visit, access, or use the Platform. When you use the Platform on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals. We may also use Cookies or automatically collected information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Platform; (b) provide customized content and information; and (c) monitor and analyze the effectiveness of the Platform.

How and Why We Share Information

Third Party Vendors. We may use third party vendors to help us further our mission and provide services to our students, volunteers and donors and to comply with applicable laws. For example, we are required to obtain and store collected information from students for seven (7) years in order to comply with regulatory and legal requirements, which we do through third party sites, such as Submittable. In addition, PENCIL may share student resumes with potential or current employers to help facilitate the interview process and subsequently the employment process; however, we do not share any other student personal information with any employers. PENCIL also collects certain information that is necessary to process donations from donors, as noted above. We work with secured third-party vendors to collect and process our donor’s credit card information and we do not store such credit card information on our servers. We have selected a third-party provider to process such credit card information that uses industry standard encryption and data security protocols.

Newsletters, Event Notifications, etc. We may use your contact information to send newsletters, event notifications or information about PENCIL opportunities to help us connect NYC students to success. You may elect not to receive further communications from us by responding with your preferences. All PENCIL e-newsletters and direct email communications have easy-to-follow unsubscribe instructions at the bottom of each email. You can also email us at any time at pencil@pencil.org if you wish to be removed from our mailing lists, access or update your contact information, request access to information that we may hold about you, or request that we delete any of your personally identifiable information that we have on record.

As Required by Law. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to take precautions against liability; to protect PENCIL from fraudulent, abusive, or unlawful uses or activity; to protect the security or integrity of the Site; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; or to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant.

Our Commitment to Children’s Privacy: Protecting the privacy of young children is especially important. We are concerned about the safety and privacy of children who use the Internet. Although we encourage children to learn more about our organization and opportunities to serve their communities, we encourage that this be done with parental supervision. Consistent with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly request personally identifiable information online from anyone under the age of 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with personally identifiable information online without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information online without verifiable parental consent, he or she should contact us at pencil@pencil.org. If we learn that information has been collected through the Platform from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has provided us with information online, please alert us at pencil@pencil.org to request that we delete the information from our systems.

Data Security: We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information; however, no security measures are perfect or impenetrable, so we cannot ensure or warrant the security of any information you transmit to us through the Platform, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We cannot control the actions of other users or other third parties with whom you may choose to share your information and therefore we cannot and do not guarantee that information you post through the Platform will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.

Changes and Updates to this Privacy Policy: We reserve the right to make changes to this Privacy Policy at any time. We will notify you about significant changes in the way we treat your information, including by placing a prominent notice on the Platform or by sending you an email so that you can choose whether to continue using the Platform. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms. Immaterial modifications are effective upon posting of the updated Privacy Policy or Terms of Service on the Platform. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

This Privacy Policy is effective as of September 23, 2019.

Contact Information: If you have any questions or concerns about this Privacy Policy, your personal information, our use and disclosure practices, please contact us at (646) 638-0565, or pencil@pencil.org.

Thank you for your interest and support!

PENCIL, Inc.
30 West 26th Street, 5th Floor
New York, NY 10010