Privacy Policy

Donor Privacy Policy

Our Commitment to Our Donors

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. We 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. This policy applies to all information received by the Israel Tennis & Education Centers Foundation, both online and offline, on any Platform (“Platform”, includes the Israel Tennis & Education Centers Foundation website and mobile applications), as well as any electronic, written, or oral communications.

THE INFORMATION WE COLLECT

This notice applies to all information collected on/or submitted to ITEC website. The types of personal information collected are:

• Name
• Address
• Email address
• Phone number
• Credit/Debit Card Information

On some pages, you can submit information about other individuals. For example, if you send a memorial or honorarium, you may include another person’s name and address for acknowledgement purposes. In this case the types of personal information collected are:

• Name
• Address

CHILDREN UNDER 13

ITEC does not knowingly collect personal information from children under 13 years of age. Children must ask their parents for permission before providing personal information to any website or purchasing any products or services online. ITEC urges all parents to participate in their children’s exploration of the Internet and to teach them about protecting their personal information while online.

THE WAY WE USE INFORMATION

ITEC guarantees that we do not and will not sell or trade our donors’ personal or contact information with anyone else, nor will we send mailings on behalf of other organizations.

We use the information you provide when making a donation to complete that donation only. We do not share this information with outside parties.

We use return email addresses to answer the email we receive and to distribute additional information if requested. Such addresses are not shared with outside parties.

We never use or share personally identifiable information provided online in ways unrelated to the ones described above without also providing you with an opportunity to opt-out or otherwise prohibit such unrelated uses.

OUR COMMITMENT TO DATA SECURITY

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

WHISTLEBLOWER POLICY

At ITEC, we believe that communication is the heart of good employee relations. Employees should share their concerns, seek information, provide input and resolve work-related issues by discussing them with their supervisors until they are fully resolved. It may not be possible to achieve the results an employee wants, but the supervisor needs to attempt to explain in each case why a certain course of action is preferred. If an issue cannot be resolved at that level, the employee is welcome to discuss the issue with the HR Manager. The supervisor should set up a time for both of them to meet with the HR Manager. If the employee’s concern cannot be resolved by the HR Manager, the employee may discuss it with an officer of the organization. The manager should schedule that meeting for the employee.

Regardless of the situation, employees should be able to openly discuss any work-related problems and concerns without fear of retaliation. The HR Manager and supervisors are expected to listen to employee concerns, encourage their input and seek resolution to the issues and concerns. Often this will require setting a meeting in the near future. The HR Manager and/or supervisors are to set these meetings as quickly as possible, and employees are expected to understand that issues may not always be addressed at the moment they arise. Discussing these issues and concerns with management will help to find a mutually acceptable solution for nearly every situation.

If an employee has a concern about discrimination and/or harassment, ITEC has set up special procedures to report and address those issues. The proper reporting procedures are set forth in the organization’s Harassment and Discrimination Policy.

Retaliation against any employee for filing a complaint or participating in an investigation is strictly prohibited.

Occasionally, talking with a supervisor or someone in Human Resources about this conduct is not an option. If an employee/visitor feels that his/her complaint has not been or cannot be properly handled, he/she may forward the complaint to the Chairman of the organization.

DOCUMENT RETENTION AND DESTRUCTION POLICY

I. Purpose

This policy provides for the systematic review, retention, and destruction of documents received or created by ITEC in connection with the transaction of ITEC business. This policy covers all records and documents, Page 3 of 6 regardless of physical form, contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate ITEC operations by promoting efficiency and freeing up valuable storage space.

II. Document Retention

ITEC follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.

IV. Glossary of Terms

1. Board and Board Committee Materials. Meeting minutes should be retained in perpetuity in the ITEC minute book.

2. Commercial Fundraiser. A commercial fundraiser for charitable purposes must maintain during each solicitation campaign, and for not less than 10 years following the completion of each solicitation campaign, records including any electronic records, containing information regarding:

a) The date and amount of each contribution received as a result of the solicitation campaign and, for non-cash contributions, the name and mailing address of each contributor.

b) The name and residence address of each employee, agent or other person involved in the solicitation campaign.

c) Records of all revenue received and expenses incurred in the course of the solicitation campaign.

d) For each account into which the commercial fundraiser deposited revenue from the solicitation campaign, the account number and the name and location of the bank or other financial institution in which the account was maintained.

i. If commercial fundraiser sells tickets to events and represents that they will be donated for use by another, then he or she must keep the number of tickets purchased and donated by each contributor, name address of all organizations receiving donated tickets. ITEC must maintain a copy of its contract with the commercial fundraiser and records of solicitations and donations according to the table above.

3. Contracts. Final, executed copies of all contracts entered into by ITEC should be retained. ITEC should retain copies of the final contracts for at least seven years beyond the life of the agreement, and longer in the case of publicly filed contracts.

5. Legal Files. Legal counsel should be consulted to determine the retention period of particular documents, but legal documents should generally be maintained for a period of ten years.

6. Personnel Records. State and federal statutes require the ITEC to keep certain recruitment, employment and personnel information. ITEC should also keep personnel files that reflect performance reviews and any complaints brought against ITEC or individual employees under applicable state and federal statutes. ITEC should also keep all final memoranda and correspondence reflecting performance reviews and actions taken by or against personnel in the employee’s personnel file. Personnel records should be retained for seven years.

7. Press Releases/Public Filings. ITEC should retain permanent copies of all press releases and publicly filed documents under the theory that ITEC should have its own copy to test the accuracy of any document a member of the public can theoretically produce against ITEC

8. Tax Records. Tax records include, but may not be limited to, documents concerning payroll, expenses, proof of deductions, business costs, accounting procedures, and other documents concerning ITEC revenues. Tax records should be retained permanently. Payroll tax returns can be retained for only seven years.

V. Electronic Documents and Records Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an email message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

VI. Emergency Planning ITEC’s records will be stored in a safe, secure and accessible manner. Documents and financial files that are essential to keeping ITEC operating in an emergency will be duplicated or backed up at least every week and maintained off site.

VII. Document Destruction ITEC’s chief financial officer is responsible for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction. Destruction of financial and personnelrelated documents will be accomplished by shredding. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.

VIII. Compliance Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against ITEC and its employees and possible disciplinary action against responsible individuals. The chief financial officer and finance committee chair will periodically review these procedures with legal counsel or certified public accountant to ensure that they are in compliance with new or revised regulations.

CONFLICT OF INTEREST POLICY

All decisions of the Board of Trustees and officers of administration of ITEC are to be made solely on the basis of a desire to promote the best interests of the organization. It is therefore the policy of the Board and ITEC:

1. That all activities or behavior, which conflict with the best interests of ITEC, are prohibited. Clear examples would include:

a) Use of the Organization’s Resources: For an ITEC trustee or officer to make unauthorized use of any resources, including the services of ITEC employees, for his or her own personal benefit.

b) Compliance with Rules: For a trustee or officer to fail to strictly comply with any rules, regulations or standards of personal behavior applicable to ITEC.

c) Disclosure of Confidential Information: For a trustee or officer, without proper authority, to give or release to anyone not authorized to receive such information, any data of a confidential nature secured through his or her relationship to ITEC.

d) Acceptance of Gifts: ITEC trustee or officer, or any dependent member of his or her immediate family to accept from any organization or person doing or seeking to do business with ITEC, a loan or a favor of more than nominal value. This paragraph shall not be deemed to prohibit normal loans made in the course of business from banks or financial institutions that may have or expect to have relations with ITEC.

e) Competition with ITEC: ITEC trustee or officer, directly or through a corporation in which he or she has a substantial interest, to engage in for remuneration any other enterprise when the activity is in direct competition with the organization.

2. That, in the event that the Board or an ITEC officer shall be called upon to consider a transaction involving the organization and (i) a member of the Board or any officer of the organization (or a member of his or her immediate family), or (ii) an organization with which a member of the Board or any office of the organization is “affiliated,” such trustee or officer, as soon as he or she has knowledge of the transaction, shall: a) Disclose fully the precise nature of his or her interest or involvement in such transaction and/or such organization; and b) Refrain from participation in the organization’s consideration of the proposed transaction. For the purposes of Section 2 of this conflict-of-interest policy, a trustee or an officer is “affiliated” with any organization of which he or she (or a member of his or her immediate family residing in his or her household) is a principal executive officer, general partner or controlling stockholder.

3. That the following persons also disclose to the organization on a continuing basis all their relationships and business affiliations that reasonably could give rise to a conflict of interest, or the appearance of a conflict of interest, involving the organization: The Trustees (including the Chairman); the Vice Chairman; the Treasurer; and other officers shall designate as being officers from whom, because of their respective duties and responsibilities, the organization should receive continuing disclosure of such outside relationships and business affiliations.

Each of these Trustees and officers shall identify any company, organization or other entity, whether or not for profit, of which he or she is a principal executive officer, director, trustee, general partner or controlling stockholder.

All disclosures required to be made hereunder must be directed in writing to the Chairman who, together with the Executive Committee of ITEC shall have responsibility for administration of this conflict-of-interest policy. All known violations, disputes and other issues arising out of the application of this policy to officers of the organization shall be referred to the Chairman for appropriate action. Matters under this policy concerning trustees shall be reported to the Chairman of the Board of Trustees for appropriate action.