1. Introduction
At SMILE Mass (“we,” “us,” “our”), we are committed to protecting the privacy and security of personal information of individuals (“you,” “your”) who interact with our website, programs, services, and communications. This Privacy Policy explains how we collect, use, share, and protect your information, and your rights in relation to your personal data.
By using our website, participating in our programs, or providing us your information (for example, via donation, contact form, newsletter subscription), you consent to the practices described in this policy (unless otherwise required by applicable law).
2. What Information We Collect
We collect various types of information to support our mission and operations. Broadly, the categories include:
- a) Personal Identifiers & Contact Information
- Name, email address, postal address, phone number
- In some cases, date of birth, emergency contact, family relationships
- Demographic or eligibility information (e.g. disability status) when relevant to program participation
- b) Payment & Financial Data
- Donation payment information (e.g. credit card, bank details)
- Billing address, transaction history
- c) Program Participation & Service-Related Information
- Information related to your enrollment or participation in SMILE Mass programs
- Health, accessibility, or accommodation details (to support inclusive services)
- Records, progress, or feedback associated with service delivery
- d) Website & Online Interaction Data
- IP address, browser type, device identifiers
- Cookies and similar tracking technologies
- Pages visited, time on site, referring/exit pages
- Newsletter sign-ups, form submissions, and other user interactions
- e) Communications & Correspondence
- Messages you send to us (e.g. via contact us forms, email)
- Volunteer applications, sponsorship interest, feedback
3. How We Use Your Information
We use your personal information for legitimate, necessary purposes, including but not limited to:
- To operate, administer, and deliver our programs and services
- To verify eligibility and provide reasonable accommodations
- To process donations, issue receipts, and manage donor relationships
- To send you informational, fundraising, or event-related communications (with your consent where required)
- To respond to inquiries, requests, or support needs
- To analyze and improve our website, programs, services, and user experience
- To comply with legal obligations, audits, or reporting requirements
- To protect against misuse, fraud, or enforce our terms
4. Legal Bases for Processing (Where Applicable)
Where applicable (e.g. under GDPR or similar laws), we rely on one or more of the following legal bases to process your personal data:
- Consent (you opt in to receive communications or share data)
- Performance of a contract or agreement (e.g. donation, program enrollment)
- Legitimate interests (e.g. improving services, preventing fraud), provided your rights do not override those interests
- Compliance with legal obligations
5. Sharing & Disclosure of Your Information
We do not sell your personal information. We may share your data under the following circumstances:
- With service providers or vendors acting on our behalf (e.g. payment processors, email service providers, IT support) under confidentiality agreements
- With affiliated organizations or partners when collaborating on programs or events (only minimal necessary data)
- In aggregated or de-identified form that cannot reasonably be traced back to an individual
- To comply with applicable laws, legal process, or governmental requests
- To protect the rights, property, or safety of SMILE Mass, our users, or the public
6. Data Security, Retention & Storage
- We implement administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, or destruction.
- We limit access to personal data to personnel and third parties who require it to perform their duties.
- We retain your personal data only as long as necessary for the applicable purpose, and as required by law or regulation.
- When no longer needed, we securely dispose of or anonymize records.
7. Cookies & Tracking Technologies
We use cookies, web beacons, and similar technologies to enhance your experience, understand site performance, and deliver content. You may manage or disable cookies through browser settings, but this may affect website functionality.
8. Your Rights & Choices
Depending on your jurisdiction, you may have certain rights regarding your personal data, including:
- Access: Request a copy of your personal data
- Correction: Request correction of inaccurate or incomplete data
- Deletion: Request deletion of your personal data (subject to legal exceptions)
- Restriction: Ask us to restrict processing under certain circumstances
- Objection: Object to certain processing (e.g. direct marketing)
- Portability: Request your data in a structured, machine-readable format
- Withdrawal of consent: If processing is based on consent, you may withdraw at any time (though this doesn’t affect prior lawful processing)
To exercise these rights, contact us as described below. We may ask you to verify identity before acting on a request.
9. Children’s Privacy
If any of our programs or website sections are directed to children (under 13 or under applicable local age), we will follow applicable legal safeguards (including parental consent) in collecting or handling their data.
10. International Transfers
If we transfer your data across borders (e.g. to service providers in other countries), we will ensure appropriate safeguards are in place (e.g. standard contractual clauses, adequacy decisions) to protect your rights and comply with applicable laws.
11. Changes to This Privacy Policy
We may update this policy from time to time. We will post the revised version on our website and update the “Effective Date.” Where required by law, we will notify you (e.g. via email) of significant changes, and obtain consent if needed.
12. Contact Us
If you have questions, concerns, or wish to exercise privacy rights, please contact:
SMILE Mass
Email: info@smilemass.org
Phone: 617-967-7755
