Privacy Policy

Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Information We Collect

1.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you engage with the Berru Charitable Foundation. This information may include:

• Contact Information: Name, mailing address, email address, telephone number, and other similar contact data
• Donation Information: Payment card details, billing address, donation amount, donation frequency, and transaction history
• Grant Application Information: Organization details, tax identification numbers, financial statements, program descriptions, budget information, and supporting documentation
• Employment Information: Resume, cover letter, references, employment history, and educational background for job applicants
• Volunteer Information: Skills, interests, availability, background check information, and emergency contact details
• Communication Preferences: Newsletter subscriptions, communication preferences, and areas of philanthropic interest
• Event Registration: Attendance information, dietary restrictions, accessibility needs, and guest details

1.2 Information Automatically Collected

When you visit our website or use our online services, we automatically collect certain information about your device and browsing activities:

• Device Information: IP address, browser type and version, operating system, device identifiers, and mobile network information
• Usage Data: Pages visited, time spent on pages, links clicked, referring website addresses, and navigation patterns
• Location Information: General geographic location based on IP address
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies to enhance user experience and analyze website performance

1.3 Information from Third Parties

We may receive information about you from third-party sources, including payment processors, background check providers, public databases, social media platforms, and other charitable organizations with whom we collaborate. This information helps us verify identities, process donations securely, and ensure compliance with applicable regulations.

2. How We Use Your Information

The Berru Charitable Foundation uses the information we collect for various legitimate purposes related to our charitable mission and operations:

2.1 Charitable Operations

• Processing and acknowledging donations, including issuing tax receipts
• Evaluating and processing grant applications
• Managing grantee relationships and monitoring grant compliance
• Coordinating volunteer activities and managing volunteer programs
• Organizing and managing charitable events and fundraising activities
• Conducting due diligence and background checks as required

2.2 Communication and Engagement

• Sending newsletters, impact reports, and updates about our programs and initiatives
• Responding to inquiries, requests, and feedback
• Providing information about donation opportunities and fundraising campaigns
• Inviting supporters to events and educational programs
• Sharing stories of impact and beneficiary testimonials

2.3 Legal and Regulatory Compliance

• Complying with federal and state charitable solicitation laws
• Meeting IRS reporting requirements for tax-exempt organizations
• Maintaining accurate financial records and audit trails
• Preventing fraud, money laundering, and other illegal activities
• Responding to legal requests and protecting our legal rights
• Ensuring compliance with anti-terrorism financing regulations

2.4 Operational Improvement

• Analyzing donation patterns and donor engagement to improve fundraising strategies
• Evaluating program effectiveness and measuring social impact
• Improving website functionality and user experience
• Conducting research and analysis to advance our charitable mission
• Training staff and volunteers on best practices

3. Information Sharing and Disclosure

The Berru Charitable Foundation respects your privacy and does not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

3.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment processors and financial institutions for donation processing
• Email service providers for newsletter distribution
• Website hosting and cloud storage providers
• Database management and CRM platforms
• Background check services for volunteers and employees
• Professional advisors including attorneys, accountants, and auditors

These service providers are contractually obligated to protect your information and use it only for the specific purposes for which it was disclosed.

3.2 Legal Requirements

We may disclose your information when required by law or in response to:

• Court orders, subpoenas, or other legal processes
• Government or regulatory inquiries and investigations
• Requests from law enforcement agencies
• IRS reporting requirements and tax compliance obligations
• State charitable registration and reporting requirements

3.3 Public Disclosure

As a charitable foundation, certain information is publicly available by law, including:

• IRS Form 990 and related tax documents
• Grant recipient information and award amounts
• Board member and officer information
• Annual reports and financial statements

We may also recognize donors publicly (such as in annual reports or on our website) unless you have requested anonymity. You may opt out of public recognition at any time by contacting us.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, or dissolution of the Berru Charitable Foundation, your information may be transferred to a successor organization. We will notify you of any such change and provide you with choices regarding your information.

4. Data Security Measures

The Berru Charitable Foundation implements comprehensive security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security practices include:

4.1 Technical Safeguards

• Encryption: All sensitive data transmitted over the internet is encrypted using industry-standard SSL/TLS protocols
• Secure Storage: Personal information is stored on secure servers with restricted access and regular security updates
• Firewalls: Network firewalls protect our systems from unauthorized access and cyber threats
• Access Controls: Multi-factor authentication and role-based access controls limit data access to authorized personnel only
• Regular Monitoring: Continuous monitoring of systems for suspicious activity and potential security breaches
• Data Backup: Regular backups ensure data recovery in case of system failures or disasters

4.2 Administrative Safeguards

• Staff Training: Regular training for employees and volunteers on data privacy and security best practices
• Confidentiality Agreements: All staff members and service providers sign confidentiality agreements
• Privacy Policies: Comprehensive internal policies governing data handling and privacy protection
• Incident Response Plan: Documented procedures for responding to data breaches and security incidents
• Regular Audits: Periodic security audits and assessments to identify and address vulnerabilities

4.3 Physical Safeguards

• Secure office facilities with controlled access
• Locked filing cabinets for physical documents containing personal information
• Secure disposal procedures for documents and electronic media
• Visitor logs and identification requirements for office access

While we implement robust security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but remain committed to protecting your information using industry best practices.

5. Your Privacy Rights and Choices

You have certain rights regarding your personal information. The Berru Charitable Foundation respects these rights and provides mechanisms for you to exercise them:

5.1 Access and Correction

You have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Update your contact information and communication preferences
• Receive a copy of your donation history and tax receipts

5.2 Communication Preferences

You can control how we communicate with you:

• Email Communications: Unsubscribe from marketing emails using the link in any email or by contacting us directly
• Direct Mail: Request removal from our mailing list for printed materials
• Phone Calls: Opt out of fundraising calls by informing us of your preference
• Text Messages: Reply STOP to any text message to unsubscribe from SMS communications

Please note that even if you opt out of marketing communications, we may still send you transactional messages related to your donations, grant applications, or other services you have requested.

5.3 Anonymity and Pseudonymity

You may choose to:

• Make anonymous donations (subject to legal reporting requirements)
• Request that your name not be publicly recognized as a donor
• Use a pseudonym when interacting with us, where legally permissible

5.4 Data Deletion

You may request deletion of your personal information, subject to certain limitations:

• We must retain certain information to comply with legal and regulatory requirements
• Donation records must be maintained for tax and audit purposes
• Grant-related information must be retained for compliance and reporting
• We may retain anonymized or aggregated data for research and analysis

5.5 State-Specific Rights

Residents of certain states may have additional privacy rights under state law, including:

• California Residents: Rights under the California Consumer Privacy Act (CCPA) including the right to know what personal information is collected, the right to delete, and the right to opt out of sales (note: we do not sell personal information)
• Virginia, Colorado, and Connecticut Residents: Rights under respective state privacy laws including access, correction, deletion, and data portability
• Nevada Residents: Right to opt out of the sale of personal information (note: we do not sell personal information)

6. Data Retention

The Berru Charitable Foundation retains personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory requirements:

• Donation Records: Retained for a minimum of seven years for tax and audit purposes, as required by IRS regulations
• Grant Files: Retained for the duration of the grant period plus seven years for compliance and evaluation purposes
• Employment Records: Retained according to federal and state employment law requirements
• Volunteer Records: Retained for the duration of volunteer service plus three years
• Marketing Communications: Retained until you opt out or request deletion
• Website Analytics: Typically retained for 26 months

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention and disposal policies.

7. Compliance with Financial Regulations

As a charitable foundation engaged in financial activities, the Berru Charitable Foundation complies with various federal and state regulations governing financial services and charitable organizations:

7.1 IRS Compliance

• Maintaining tax-exempt status under Section 501(c)(3) of the Internal Revenue Code
• Filing annual Form 990 returns with accurate donor and grant information
• Issuing compliant donation receipts for tax deduction purposes
• Maintaining proper documentation of charitable activities and expenditures
• Complying with private foundation excise tax and distribution requirements

7.2 Anti-Money Laundering (AML) and Counter-Terrorism Financing

• Screening donors and grant recipients against OFAC and other sanctions lists
• Implementing know-your-donor procedures for large contributions
• Monitoring transactions for suspicious activity
• Maintaining records of due diligence procedures
• Reporting suspicious activities to appropriate authorities when required

7.3 State Charitable Solicitation Laws

• Registering with state charity regulators where required
• Filing annual financial reports with state authorities
• Complying with state-specific disclosure requirements
• Maintaining proper records for state audits and examinations

7.4 Payment Card Industry (PCI) Compliance

When processing credit card donations, we comply with PCI Data Security Standards (PCI DSS):

• Using PCI-compliant payment processors
• Never storing complete credit card numbers or security codes
• Encrypting cardholder data during transmission
• Maintaining secure networks and systems
• Regularly testing security systems and processes

8. Children's Privacy

The Berru Charitable Foundation does not knowingly collect personal information from children under the age of 13 without parental consent. Our website and services are not directed to children under 13. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information promptly.

For youth programs and educational initiatives involving minors, we obtain appropriate parental or guardian consent and implement additional safeguards to protect children's privacy and safety.

9. International Data Transfers

The Berru Charitable Foundation is based in the United States, and your information is primarily processed and stored in the United States. If you are located outside the United States and choose to provide information to us, please note that we transfer the data to the United States and process it there.

When we engage international grantees or service providers, we implement appropriate safeguards to ensure your personal information receives adequate protection, including standard contractual clauses and data processing agreements that comply with applicable international data protection laws.

10. Third-Party Websites and Services

Our website may contain links to third-party websites, social media platforms, and services that are not operated by the Berru Charitable Foundation. This Privacy Policy applies only to information collected by us. We are not responsible for the privacy practices of third-party websites or services.

We encourage you to review the privacy policies of any third-party websites or services before providing them with your personal information. When you use third-party payment processors or donation platforms, their privacy policies and terms of service will also apply to your transactions.

11. Changes to This Privacy Policy

The Berru Charitable Foundation may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes to this Privacy Policy, we will:

• Update the "Last Updated" date at the top of this policy
• Post the revised policy on our website
• Notify you via email if you have provided us with your email address
• Provide prominent notice on our website homepage

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our services after changes to this Privacy Policy constitutes your acceptance of the revised policy.

12. Contact Information for Privacy Concerns

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us using the information below. We are committed to addressing your privacy concerns promptly and thoroughly.

How to Submit Privacy Requests

To exercise your privacy rights or submit privacy-related requests, please:

1. Contact us using the information provided above
2. Clearly describe your request and specify which privacy right you wish to exercise
3. Provide sufficient information to verify your identity (we may request additional information to confirm your identity before processing your request)
4. Allow us reasonable time to respond (typically within 30-45 days, depending on the complexity of your request)

We will respond to all legitimate privacy requests in accordance with applicable law. If we cannot fulfill your request, we will explain the reasons for our decision.

Filing a Complaint

If you believe we have not adequately addressed your privacy concerns, you have the right to file a complaint with:

• Your state Attorney General's office
• Your state's charity regulator
• The Federal Trade Commission (FTC)
• Other applicable regulatory authorities