Policy Title: External Data Privacy Policy
Date of Issue: February 2025
Approved by: Jonathan Wang, COO
Review/Revision Date: March 5, 2025
Purpose
JFCS East Bay has prepared this policy to help staff, clients (both direct and indirect), and external parties understand how we collect, use, and disclose information from individuals—including clients, donors, volunteers, and job applicants—when they use our website (jfcs-eastbay.org) and related services (the “Services”).
By using the Services, clients and other users acknowledge that they understand and agree to the terms outlined in this External Data Privacy Policy and the related Privacy & Safe Communications Policy. Understanding and acceptance of these policies are required in order to receive Services. If you do not understand any part of the policy, we encourage you to contact us using the information provided at the end of this document.
This policy is publicly available on our website and serves as JFCS East Bay’s official Privacy & Safe Communications Policy.
Protected Health Information (PHI)
We will keep your Protected Health Information secure.
We may collect PHI when you schedule appointments, communicate with us via email or text, submit forms, or receive treatment. PHI is handled according to our Confidentiality of PHI Policy, which can be found here.
If you have questions about our use or disclosure of PHI, please consult the Confidentiality of PHI Policy or contact our Privacy Officer.
Information We Collect & How We Collect It
We collect the following categories of Personal Information:
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Identifiers (e.g., name, email, phone number, address, social security number)
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Employment- and volunteer-related information
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Demographic details (e.g., date of birth, race, gender)
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Geographic data
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Health-related data (e.g., medical history)
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Financial or government benefits information
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Inferences about preferences or characteristics
We collect information in the following ways:
1. Directly from you:
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When you request an appointment or consultation
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When you create a user profile or register an account
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When you email or otherwise communicate with us
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When signing up for newsletters or registering for events
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When applying for a job or volunteering
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When paying for services or making a donation
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When submitting surveys or feedback
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When posting on our public platforms or social media
Clinical information may be collected during phone calls, paper intake forms, or in-person visits. We use a trauma-informed approach and will explain the purpose of sensitive questions. If you’re uncomfortable sharing information, please contact our Privacy Officer.
2. Publicly Shared Information:
You may choose to share content publicly on our Services. Please note that we cannot control how others use publicly available content.
3. Automatically via technology:
We and our vendors may collect usage data using Cookies, Web Beacons, and similar tools. This includes information such as your browser type, operating system, pages visited, and referral URLs. This data is anonymized and helps us improve our Services.
Use of Cookies:
Cookies may be used to analyze web traffic and usage trends. These cookies do not identify individuals by name or other personally identifiable attributes. Most browsers allow users to block cookies.
4. From third parties:
We may collect your information from people or organizations acting on your behalf. If you provide information about another person, you must have their consent.
How We Use Your Information
We use your information to:
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Provide and improve our Services
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Communicate with you (e.g., updates, reminders, marketing emails—you may unsubscribe at any time)
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Personalize your experience
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Analyze trends and user behavior to improve functionality
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Monitor and prevent fraud or abuse
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Comply with legal obligations
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Conduct audits and fulfill regulatory requirements
We may link Usage Information to Personal Information. If so, we treat it as Personal Information. We may also de-identify or aggregate data for lawful analytics and research purposes.
With Whom We Share Information
We may share your information:
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With partners: When collaborating with trusted organizations. Their use of your data is subject to their privacy practices.
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With vendors: Who support our operations and are contractually obligated to safeguard your data.
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For legal or regulatory purposes: When required by law, subpoena, or to protect our rights and safety.
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For audits or health oversight activities: As required to comply with standards and regulations.
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As aggregate or de-identified data: For reporting, research, or marketing purposes.
Your Rights
JFCS East Bay complies with all applicable laws regarding the privacy and security of your data, especially sensitive health and financial information.
You have rights regarding how your data is used and can:
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Request access to your Personal Information
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Request corrections or updates
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Limit or withdraw consent for certain uses
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Learn more about how to manage cookies or other data collection methods
