Privacy Policy

Effective Date: September 2024

ASU Enterprise Partners and its Affiliates (collectively, “we”, “us”, “our”, or “the Enterprise”) are committed to protecting your privacy by developing technology that provides a useful and safe online experience. This Privacy Policy governs the collection and usage of Personal Information (defined below) collected by the Enterprise, whether online or offline. By using the Enterprise Services (defined below), you consent to the data practices described in this Privacy Policy. Please also review our Donor Bill of Rights.

As used in this Privacy Policy:

• “Affiliates” of ASU Enterprise Partners includes but is not limited to: (i) the Arizona State University Foundation for a New American University, (ii) ASU Enterprise Partners Outreach Hub, (iii) Enterprise Collaboratory at ASU, (iv) Skysong Innovations, LLC; and (v) Newswell.
• “Personal Information” means information actively provided to the Enterprise, such as your email address, name, home or work address, telephone number, age, gender, preferences, interests, and favorites, as well as information the Enterprise actively gathers through your use of the Enterprise Services (defined below), such as cookies. Personal Information does not include information that is publicly available.
• “Donor Personal Information” is a subset of Personal Information and additionally includes the gift history of a donor or potential donor to the Enterprise or to Arizona State University.

When This Privacy Policy Applies

This Privacy Policy applies to the following Enterprise services (collectively, the “Enterprise Services”):

1. When you visit any Enterprise website, including but not limited to asufoundation.org, giveto.asu.edu, asuep.org, and any other website that we own or control and which posts or links to this Privacy Policy (“Website”);
2. To any information we collect through a Website or in email, text, or other electronic messages between you and the Enterprise; and
3. When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This Privacy Policy does not apply to information collected by any third-party, including third-party websites that may be linked within the Enterprise Services.

This Privacy Policy applies to all Personal Information provided to the Enterprise, as described in the “Collection of Personal Information” section, below. Because the Enterprise accepts gifts through the Enterprise Services, Personal Information also includes Donor Personal Information. We collect Personal Information, including Donor Personal Information, to allow our development personnel to use information about our donors and visitors to the Service, and this Privacy Policy describes how we collect, use, and share it.

If you do not agree with our policies and practices, your choice is not to use the Enterprise Services. By accessing or using the Enterprise Services, you agree to this Privacy Policy. This policy may change from

time to time. Your continued use of the Enterprise Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Security of Personal Information

The Enterprise uses various technical and organizational measures to secure Personal Information from unauthorized access, use, or disclosure. The Enterprise secures Personal Information on computer servers in a controlled, secure environment, reasonably protected from unauthorized access, use or disclosure. The Enterprise encrypts, either itself or through a third-party security provider, Personal Information sent by the Enterprise to third-parties.

Collection of Personal Information

The Enterprise collects your Personal Information in two primary ways: (1) Personal Information you actively provide to the Enterprise; and (2) Personal Information automatically collected by the Enterprise in connection with your use of the Enterprise Services, such as cookies, your IP address, browser type, domain names, access times and referring website addresses. All such Personal Information is used by the Enterprise for the operation of the Enterprise Services, to maintain quality of the Enterprise Services, and to provide general statistics regarding use of the Enterprise Services.

The Enterprise encourages you to review the privacy policies/statements of websites you choose to link to from Enterprise websites so that you can understand how those websites collect, use, and share your information. The Enterprise is not responsible for the privacy policies/statements or other content on websites not operated by the Enterprise.

Information we obtain from social media platforms: We may maintain pages for the Enterprise on social media platforms, such as LinkedIn, Google, YouTube, Facebook, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your data. You or the platforms may provide the Enterprise with Personal Information through the third-party platform, and we will treat such Personal Information in accordance with this Privacy Policy.

Information we obtain from other third parties: We may receive Personal Information about you from third-party sources, such as publicly available sources and data providers. Our use of any Personal Information obtained from such third-parties is governed by our agreements with those third-parties; however, we will treat such Personal Information in accordance with this Privacy Policy.

Text Message Communications

We may use text messaging to communicate with you about the Enterprise Services or other information related to the Enterprise and its operations. Normal messaging rates apply, and the frequency of messages may vary. You may opt-out of text messaging at any time by following the instructions in the text message (e.g., replying to the text message with STOP) or by contacting us at smstracking@asuep.org and providing your cell phone number and the type of messages for which you wish to opt-out (e.g., all text messages, fundraising text messages, etc.). Doing so will add your phone number to the appropriate do-not-contact list and will end the text communications from the receiving (or specified, if opting out via email) Enterprise phone number. You may continue to receive Service-related and other text messages from other phone numbers managed by the Enterprise so you may need to opt out of those using the same methods described above.

Use of Your Personal Information

The Enterprise collects, maintains, and uses your Personal Information to operate and present the Enterprise websites and the Enterprise Services, and to assist with or provide any other services, products, or information you have requested. Examples include ASU Foundation fundraising campaigns, Arizona State University alumni events, and other matters of interest to the Arizona State University community. The Enterprise also uses your Personal Information to inform you of other products or services available from the Enterprise. The Enterprise may contact you via surveys to conduct research about your opinion of current services or potential new services that we may offer. The Enterprise may also use your Personal Information to fulfill any other purpose for which you provide it or with your consent.

The Enterprise does not sell, rent, or lease your Personal Information, or the Enterprise’s user or donor lists to third-parties. The Enterprise may, however, share such data with trusted partners to help the Enterprise perform statistical analyses; send you email, texts, or postal mail; provide customer support; process payments; or arrange for deliveries. These third-parties are not permitted to use your Personal Information except to provide services to the Enterprise, and they are required to maintain the confidentiality and security of your Personal Information.

Our servers are located in the United States of America. If you are accessing the Enterprise Services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed by us in our facilities and by those trusted partners with whom we may share your Personal Information.

Disclosure of Personal Information

The Enterprise shares your Personal Information, without notice, with, between, and among our Affiliates, as well as with Arizona State University.

Except as otherwise stated in this Privacy Policy, the Enterprise does not disclose Personal Information to individuals or entities who are not Affiliates. The Enterprise may disclose your Personal Information with third-parties, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with the law, such as a court order, subpoena or search warrant, government investigation or other legal requirements; (b) necessary for the prevention or detection of crime (subject in each case to applicable law), such as to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (c) protect and defend the rights or property of the Enterprise, such as when disclosure would mitigate our liability in an actual or threatened lawsuit, or to enforce our agreements with you; and (d) to protect the legal rights of our users, business partners or other interested parties or protect any individual’s or the public’s safety.

Our Use of Cookies

The Websites use cookies to enhance your online experience. Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e.,

when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using our website.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The cookie tells the web server that you have returned to a specific page. For example, if you personalize the Website pages or register with the Website, a cookie helps the Website recall your specific information on subsequent visits and thereby simplifies the process of recording your Personal Information. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the Enterprise features that you customized.

We also use analytics cookies to help us understand how our Website is used and how effective marketing campaigns are, and to help us improve our Website for you. Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each internet browser. You can check the specific steps in your particular browser help menu. If you choose to decline cookies, you may not be able to fully experience the features of the Websites you visit.

To learn more about cookies generally, visit www.allaboutcookies.org.

How We Respond to Do Not Track Signals

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we, like many organizations, do not respond to DNT signals.

Information Retention

We will retain your Personal Information for the period necessary to reasonably fulfill the purposes outlined in this Privacy Statement for our legitimate business purposes unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you;
• Whether we are subject to a legal obligation (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

Your Choices about Your Personal Information

If you would like to exercise any of your consumer rights, such as the right to access, correct, update, suppress, restrict, or delete Personal Information that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (data portability), you can contact us at privacyanddataprotection@asuep.org.

In your request, please clearly specify which rights you wish to exercise and provide details on the Personal Information you would like to have access to, changed, suppressed, or deleted. For your

protection, we only fulfill requests related to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will comply with your request as soon as reasonably practicable, or as required by applicable law.

Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Additionally, our databases and other systems of record may have residual data which will not be removed. We also may not allow review of certain data for legal, security or other reasons.

Our Contact Information

We welcome your comments regarding this Privacy Policy. If you believe we have not adhered to this Privacy Policy, please contact the Enterprise at privacyanddataprotection@asuep.org. We will use reasonable efforts to address your concerns.

Changes to This Privacy Policy

The Enterprise will occasionally update this Privacy Policy. Any change becomes effective when we post the revised Privacy Policy on our website and update the Effective Date above. In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.