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A FIRM COMMITMENT TO PRIVACY
(Effective Date August 5, 2020)
This privacy policy (“Policy”) governs how United Way of Central Indiana (“United Way”) collects, uses, maintains, and discloses all information it collects; both online and offline, on any platform or through any medium; for donors, volunteers, and other constituents as well as visitors (“Visitor”) to our website, www.uwci.org (“Site”).
This Policy may be changed or updated by United Way at any time, in United Way’s sole and absolute discretion, as indicated by the “effective date” first listed above. Refer to this Policy on a regular basis, as it is United Way’s policy to post any changes made to this Policy on this page and all changes shall be effective immediately upon posting of such revised Policy. By using our Site, Visitor agrees to the terms of this Policy then in effect and the continued use of the Site after any changes are made to the Policy is deemed acceptance of the changes, and each Visitor is required to check the Policy periodically for updates.

INFORMATION UNITED WAY COLLECTS
“Personally Identifiable Information” (“PII”) is information that tells us who you are, such as name, physical address, and e-mail address, and any other information the Site collects that is defined as personal or personally identifiable under an applicable law. United Way will collect PII from Visitors on the Site only if they voluntarily submit such information. Visitors can refuse to supply PII, but it may prevent them from engaging in certain Site related activities and limit their ability to use the Site.
“Usage Information” is information automatically collected by a web server (which may be hosted by a third party) that a Visitor's browser makes available when visiting the Site, such as a computer’s IP (Internet Protocol) address or browser type.

PRIVACY OF CHILDREN
No one under the age of 13 may provide any PII on the Site, and United Way does not intentionally collect PII from children who are under the age of thirteen on our Site. If United Way learns that PII has been collected or received from a child under the age of 13 on our Site, it will delete that child’s personal information from its files and the Site, in accordance with the federal Children's Online Privacy Protection Act of 1998. If any Visitor is under the age of 13, do not use or provide any information on this Site, make any purchases through the Site, or provide any information to United Way, including your name, address, telephone number, email address, or any screen name or user name you may use.
United Way facilitates youth engagement programs throughout the community, and collects information, including PII, to facilitate communication and coordination. If the child is under the age of 13 these data are collected from the parent/guardian of the child or from the child with the consent of the parent/guardian. If the child is age 13 or older, such data may be collected from the child’s parent/guardian or directly from the child without any consent from the parent/guardian. These data are maintained in United Way’s database, regardless of age, and are subject to the data security and sharing protocols outlined in this policy.
Any and all PII collected from any source to facilitate analysis to determine the efficacy of community impact programs and initiatives is subject to rigorous data transfer, security and access standards and in compliance with relevant laws and regulations.

UNITED WAY’S COMMITMENT TO OUR DONORS
United Way will not sell, share or trade our donors' names or personal information with any other entity, nor send mailings to our donors on behalf of other organizations other than as outlined elsewhere in this Policy or as a routine part of a donor’s other engagement with United Way (such as the Board of Directors listing on our Site). United Way will generate routine social media activity regarding United Way and our many community partners.
This policy applies to all information received by United Way; both online and offline, on any platform or through any medium.

HOW UNITED WAY PROTECTS YOUR INFORMATION
United Way uses industry-leading Secure Sockets Layer (SSL) technology to protect against the loss, misuse and unauthorized alteration of the information it collects and maintains, both online and offline. All information is stored in a secure database.
Unfortunately, the transmission of information via the internet is not completely secure. Although United Way does our best to protect your PII, the security of your personal or sensitive information transmitted to us is not guaranteed. Any transmission of PII or sensitive information is at your own risk. United Way will not be responsible for disclosure of information due to errors in transmission or circumvention of any privacy settings or security measures United Way put in place for your protection.
Security of Credit Card Information United Way uses a variety of safeguards to protect the security of credit card transactions, including encryption, access controls, network firewalls, physical security and other measures.

HOW UNITED WAY USES YOUR INFORMATION
United Way collects, uses and discloses information for the purpose for which it is provided and for the other purposes described in this Policy. United Way is the sole owners of the information it collects. United Way will not sell or rent this information to anyone without your permission.
United Way may utilize your PII to contact you regarding United Way, its programs and its agencies; for marketing and promotional purposes; to seek your feedback; to offer you opportunities to give, advocate and volunteer; and to share other pertinent information.
United Way may use your Usage Information to help us run and maintain our Site; study traffic patterns and generally learn about the usage of the Site; personalize Visitor experience; improve our Site; and target advertisements on our Site to Visitors. United Way may disclose Usage Information to third parties, including, but not limited to, our advertisers. United Way may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even those we do not disclose your PII for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Surveys and contests
From time-to-time United Way requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information.

Sharing your information
United Way may use trusted third-party service providers to help operate its business and the Site and to administer activities on its behalf; and may share PII and Usage Information with these third parties solely for such purposes. For example, information may be shared with individuals and/or third-party service providers who send out emails, newsletters, surveys and other mailings, and who provide fundraising, billing and/or payment processing services. Your PII may also be disclosed to any subsidiaries and/or affiliates of United Way.

REPORTING OF INFORMATION FOR INVESTIGATION OF POSSIBLE ILLEGAL OR HARMFUL ACTIVITIES
United Way may use and disclose PII and Usage Information when there is reason to believe that using and/or disclosing this information is necessary to investigate, identify, contact, or take action against someone who may have engaged in illegal activities or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Visitors of our Site, or anyone else who could be harmed by such activities. United Way may also disclose PII when there is reason to believe that the law requires it or if United Way otherwise believes disclosure is necessary or appropriate to protect the rights, property or safety of United Way, our customers or others.

COOKIES OR OTHER TECHNOLOGIES
United Way may use other technologies (such as cookies, explained below) to enhance Visitor experience and obtain information about a Visitor’s activities on our Site, such as pages and content viewed, the time and duration of visits and whether a Visitor clicked on a link.
Cookies used on the Site are “session” cookies, and are used to identify a particular visit to the Site. Session cookies expire after a short time or when a Visitor closes a web browser. Due to Internet communications standards, when Visitors visit the Site, it automatically receives the URL of the web site from which the Visitor came and the web site the Visitor visits when leaving.
Visitors may choose to set their web browser to refuse cookies, or to receive an alert when cookies are being sent. Doing so may result in some parts of the Site not functioning properly. Additionally, some of our business partners may use cookies on our site (for example, advertisers). However, United Way has no access to or control over these cookies.

GOOGLE ANALYTICS
United Way tracks Visitor traffic patterns with Google Analytics. Learn more about Google Analytics. United Way may use this information to administer its Site and analyze overall trends, such as the numbers and frequency of Visitors and how much Visitors use parts of the Site, so that United Way can make improvements. Google Analytics collects information anonymously. It reports website trends without identifying individual Visitors.

LINKS
The Site contains links to other websites. United Way is not responsible for the privacy practices or the content of such other websites and encourages Visitors to review the privacy policies of the other websites before providing them with any personally identifiable data.

VISITOR ACCESS TO AND CONTROL OVER INFORMATION
If you have questions about this Policy or wish to review, update, correct or delete your information or opt out of receiving future communications, you may contact United Way at community@uwci.org.
Approved by the Board on August 5, 2020.





UNITED WAY OF CENTRAL INDIANA, INC. WHISTLEBLOWER POLICY
INTRODUCTION
The purpose of the Whistleblower Policy is to provide a way for staff and volunteers who believe inappropriate financial transactions, harassment or discrimination are occurring within UWCI to report such action to those in authority, and be protected for doing so. This Whistleblower Policy also serves as the tool for compliance of federal Whistleblower requirements in the administration of all federal grant awards by United Way of Central Indiana.

APPROPRIATE INFORMATION TO REPORT
Any information regarding suspected theft, fraud, other misuse of UWCI funds, harassment or discrimination should be reported. This excludes issues related to any agency affiliated with UWCI. Calls concerning an affiliated agency should be made to the applicable agency’s hotline.
Whistleblower information should not include how funds are allocated by UWCI and/or by an agency. Calls of that nature should be made to the President & CEO of UWCI. Furthermore, reporting personnel issues is not appropriate through this means unless the report is regarding harassment or discrimination that can't be brought to a supervisor's or Director of Human Resource's attention for fear of reprisal. This would include, but not be limited to, hiring, termination, promotion, compensation, or supervisory related issues.

WHAT TO EXPECT WHEN YOU MAKE A REPORT
The call is received by a representative of a company contracted by UWCI to provide whistleblower services. The company representative will take the caller’s statement and will ask for their name and telephone number so that an investigator can confidentially contact the caller for any additional details. This will provide a means for the investigator to follow up with the caller and communicate the results of the investigation. Providing the name is optional, even though it would remain in confidence with any UWCI staff. The caller does not have to provide their name, even to the investigator. However, without a name and telephone number, the investigator will not be able to follow up with the caller.

ACTION OF THE INVESTIGATOR
Once the investigator has obtained all the pertinent information, he/she will report the information directly to the UWCI Ethics Officer (Governance Committee Chair) and the Chair of UWCI Audit Committee – both members of the UWCI Board of Directors. The Audit Committee has the authority to act on behalf of the Board and will obtain the professional assistance of others if such is warranted.
Specific action taken against the reported individual/agency will depend upon the outcome of the investigation. UWCI has a “zero tolerance” practice regarding fraud, theft, other intentional misuse of funds, harassment or discrimination.

NUMBER TO CALL/WEB REPORTING
Lighthouse
English speaking USA and Canada: 833-717-0811
Spanish speaking USA and Canada: 800-216-1288
Website: www.lighthouse-services.com/uwci

PUBLIC POSTING OF WHISTLEBLOWER NUMBER
The whistleblower contact information shall be posted on the UWCI website (for general public knowledge) and internal IT portals used by staff. Furthermore, the policy shall be verbally communicated to all employees upon hiring and at least once annually. The UWCI board of Directors shall also be updated annually.

FEDERAL WHISTLEBLOWER REQUIREMENTS
United Way of Central Indiana (UWCI) will adhere to federal Whistleblower requirements in the administration of all federal grant awards including Social Innovation Fund (SIF). Specifically, UWCI, will comply with the pilot program on Contractor employee whistleblower protections established at 41 U.S.C. 4712 by section 828 of the National Defense Authorization Act for Fiscal Year 2013 (Pub. L. 112-239).
• All federal grant awards and employees working on these awards will be subject to the whistleblower rights and remedies in the pilot program.
• Under this pilot program, an employee of a recipient may not be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing information that the employee reasonably believes is evidence of gross mismanagement of a Federal contract or award, a gross waste of Federal funds, an abuse of authority (an arbitrary and capricious exercise of authority that is inconsistent with the mission of CNCS or the successful performance of a contract or grant of CNCS) relating to a Federal contract or award, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal contract (including the competition for or negotiation of a contract) or award.
• The recipient shall inform its employees in writing, in the predominant language of the workforce or organization, of employee whistleblower rights and protections under 41 U.S.C. 4712, as described above.

Adopted (by concept rather than written policy) by Board of Directors – October 27, 2004
Approved by Audit Committee – June 2010
Approved by Board of Directors – October 17, 2012
Revised and Approved by Board of Directors – December 5, 2018
Staff revision of provider – August 13, 2020