Privacy Policy

This Privacy Policy (“Policy”) describes how we at Sandy Hook Promise (“Sandy Hook Promise”, “we”, “our”, “us”) collect, use, share and maintain information from you when you access to and use of the technology, products, and services offered by Sandy Hook Promise through its websites, mobile applications, and telecommunications services. In this Policy, we refer to all such Sandy Hook Promise resources as the “Sandy Hook Promise Platform” or just the “Platform”, which we further define below. We refer to users of the Platform as “Users”, “you”, “your”, and “yourself”.

We offer the Platform strictly in accordance with our Terms of Use. The terms of this Policy form part of our Terms of Use, and the two documents should be read together. Any capitalized terms not otherwise defined in this Policy will have the same meaning as we provide in our Terms of Use.

The Sandy Hook Promise Platform includes, for example, your access to and use of:

Our websites at:

• sandyhookpromise.org;
• actionfund.sandyhookpromise.org;
• sandyhookpromiselearning.org (also known as the “Sandy Hook Promise Learning Center” or the “Learning Center”); and
• saysomething.net websites (all of the above together referred to as the “Sites”);

Our Say Something Anonymous Reporting System (the “Say Something Anonymous Reporting System”), which includes:

• the online tip submission pages on our Sites;
• the Say Something Anonymous Reporting System mobile application for tip submission (the “App”); and
• our Say Something Anonymous Reporting System 24/7 telephonic tip reporting service, 844-5-SAYNOW (“844-5-SAYNOW” or “Phone Service”); and

The Donate and Online Store pages of our Sites.

By using the Sandy Hook Promise Platform, you consent to the use, disclosure, transfer, and processing of information we collect from you as we provide in this Policy.

HOW DO WE DEFINE “PERSONAL INFORMATION”?

“Personal information”, as used in this Policy, is any information relating to an identified or identifiable person. An identifiable person is someone who can be identified, directly or indirectly, by reference to an identifier such as a name, an email address, an identification number, location data, online or personal device identifier, or to one of more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Information You Provide Directly to Us:

Through the Say Something Anonymous Reporting System (Individual Users and Schools)

Sandy Hook Promise collects information from you when you provide it to the Say Something Anonymous Reporting System through the App, Sites, and/or Phone Service. You provide information, for example, when you initially select a school; report and/or update a tip; submit pictures, videos, audio files, or other content; make informational inquiries using topic tabs on the App and Sites and, update your school location (via the App only).

We have designed the Say Something Anonymous Reporting System to maximize your privacy, by providing you with a means to anonymously report events or issues of concern to you. Accordingly, we do not require you to provide any personally identifiable information when you use the Say Something Anonymous Reporting System. However, you may provide such information at your discretion, and we will treat such information in accordance with the terms of this Policy.

In the case of Users who are school administrators or educators accessing the Platform pursuant to a memorandum of understanding or other written agreement, you provide information when you set up and maintain User accounts for administrators and educators, you participate in training and compliance activities, you update school team composition and contact information, and so forth.

Through the Sandy Hook Promise Learning Center

Sandy Hook Promise collects information from you when you access and use the Sandy Hook Promise Learning Center. You provide information when you set up User accounts through the Learning Center, you provide and/or update your User contact information, you communicate with us concerning training programs and materials, request information and materials from us, download from or upload to the Platform information or material, and so forth.

Through Participation in a SAVE Promise Club

Sandy Hook Promise may collect information from SAVE (Students Against Violence Everywhere) Promise Club participants, including educators and adult sponsors, as well as student leaders and club members. You provide information when you provide club leader and participant contact information, you request or download information and materials from the Platform, and you upload or submit information or materials concerning club news, membership, activities, events, awards, and recognition.

Through All Other Aspects of the Sandy Hook Promise Platform

Users of the Sandy Hook Promise Platform may choose to interact with the Platform in ways that require them to provide us with personal information. The amount and type of information that you provide will depend on the nature of the interaction.

If you wish to:

• receive news updates or additional information about Sandy Hook Promise and its programs, products, services, and initiatives;
• use our “Contact Us”, “Donate”, “Get Involved”, “Advocate”, “Make the Promise”, and “Volunteer” features;
• Purchase Sandy Hook Promise-branded merchandise in our online store to support our work;
• access our blog, news articles, videos, and educational materials; and
• request or register for an event that we may organize from time to time.

Then we may ask you to provide information tailored to facilitate these requests including your:

• name and email address;
• postal address or geographic location;
• congressional district and/or elected official information;
• mobile telephone;
• age and status as a student, educator, parent, volunteer, etc.; and
• questions, requests, or statements of need.

We may also collect this information should you call or e-mail Sandy Hook Promise using the contact information found on our Sites, or when you contact us outside of the Platform, such as by telephone, mail, or in person at an event or in our offices, for any of the foregoing purposes.

Donor information will only be released to the donor or a legal representative of the donor as evidenced by a power of attorney document. The donor or their legal representative can then forward to any third parties requesting that information if necessary.

Information We Collect From Your Devices (Cookies and Related Tracking Technologies):

We use cookies and similar tracking technologies to track user activity on the Platform. A cookie is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user returns.

We use cookies to help us identify and track Users, their usage of the Platform, and their Platform access preferences. Users who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Platform, with the drawback that certain features of the Platform may not function properly without the aid of cookies.

In addition to cookies, other tracking technologies are also used, such as beacons, tags and scripts to collect and track information and to improve and analyze the Platform.

We may employ third-party companies and individuals to facilitate or analyze the Platform. These third parties have access to your personal information only to perform these tasks on our behalf. They are obligated not to disclose or use it for any other purpose.

We use several website analytics tools, including Google Analytics, a service that tracks and reports Platform traffic. Google uses the data collected to track and monitor the use of the Platform. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having your activity on the Platform available to Google Analytics by installing the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

We also collect personal information like Internet Protocol (IP) addresses and caller ID information when you use the Phone. For more information on our use of IP addresses and caller ID information, please see below the section captioned “Disclosure of Internet Protocol (IP) Address and Caller ID Information”.

How To Control Cookies

You may also use your web browser to enable, disable, or delete cookies. To do this, follow the instructions provided by your web browser. Each web browser is different and may appear differently depending on the device being used, so we encourage you to review the instructions provided by your specific web browser. If you are in the habit of using various browsers, then you will want to address the cookie controls in each of the browsers you use. Below are links to the cookie controls for some of the more common web browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Opera
• Safari
• Flash cookies
• Apple
• Android

If your browser is not listed above, we suggest that you either look in your browser’s help setting or search for “cookies” together with your browser name on the Internet. You may revoke your consent at any time.

Note that using your web browser to disable cookies may reduce the functionality of our Platform. For more information about how to manage and delete cookies, visit aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use your personal information exclusively for legitimate purposes consistent with Sandy Hook Promise’s nonprofit mission and our Terms of Use, such as:

• with respect to the Say Something Anonymous Reporting System: helping you in an emergency, for example, by directing your tips and other communications to operators and responding via secure, anonymous live chat;
• providing you with additional or added products, services, or information as it relates to your request or submission;
• providing you with required Platform notices;
• improving the Platform, for example, by using analytics to improve and enhance the performance and ease of use;
• generating and analyzing anonymized statistics about your use of the Platform;
• detecting, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Platform; and
• to support our organizational performance and operations (e.g., reports, trends, etc.).

WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share the information you provide through the Platform, but only as disclosed in this Policy. Like many other nonprofit organizations, Sandy Hook Promise may share personal information we collect with other nonprofits — many of which we work with in our antiviolence work. If you do not want your personal information shared with other organizations, please contact us and we will remove you from any shared lists.

Say Something Anonymous Reporting System

With respect to your use of the Say Something Anonymous Reporting System, we will disclose personal information only on a need-to-know basis to the affiliated school you designate on the Platform, to public safety officials and law enforcement in cases of possible threat to human life, and to those of our employees, volunteers, affiliates, and service providers who process it on our behalf as necessary to provide the Platform. Those employees, volunteers, affiliates, and service providers are bound by strict confidentiality rules and are permitted to use the information only to support our operations.

Please note that when you use the Say Something Anonymous Reporting System, you may connect with your school, which, along with Sandy Hook Promise, may help triage and act on the information you provide. Once the information is received by your school, this Policy will no longer govern it. If you wish to know about the data privacy practices of your school, please contact school officials directly.

Other Platform Uses

We use third parties to handle donations, employment and volunteer applications, and other information collection. When we identify such third parties, we encourage you to review the privacy policies of these vendors as each has its own unique privacy policy, separate and distinct from ours.

Other than to your affiliated school and our employees, volunteers, affiliates, and service providers, as described above, we disclose personal information only:

• to public safety officials and other government entities on an emergency basis or when requested by you;
• as required by law, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations;
• when we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the Platform, the rights of the schools with which we partner, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Platform; and
• to another organization in the event we were to combine with or be acquired by that organization.

SECURITY

Sandy Hook Promise cares about the security of your information. We use commercially available physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Sandy Hook Promise Platform. This includes the use of secure socket layers (SSL), which encrypts your personal information, including for example donation information, entered into our web forms to avoid the decoding of that information while in transit to Sandy Hook Promise’s donation processor.

In the event that any information under our control is compromised as a result of a breach of security, Sandy Hook Promise will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

CHILDREN

Because our site is a serious tool used to help prevent violence and victimization in schools, we restrict use of certain parts of our Platform based on age or school grade, as we provide in our Terms of Use. For example, the Sandy Hook Promise Anonymous Reporting System is not intended for use by students under grade 6. If you believe we have received information from someone under grade 6, or if you believe that we have received information from a child of any age without legally required parental or school consent, please contact us at the email address provided at the end of this Policy so that we may take appropriate action. With regard to our marketing practices, we will not knowingly collect, use or distribute personal information from children under the age of 13 without prior verifiable consent from a parent or guardian.

RETENTION

We may retain your submitted tip and information regarding your affiliated school for a minimum of 8 years or as long as necessary to fulfill the purposes described in this Policy, as required by law, or for legitimate organizational purposes, including for instance for research purposes, to the extent permitted by applicable law. Otherwise, we will retain your personal information only for as long as reasonably necessary to carry out the purposes for which you gave it to us, unless a longer period is required by applicable law. When those purposes, or legal requirements as the case may be, no longer apply, we will securely delete your personal information.

STORIES OF IMPACT & DATA SHARING

We periodically share Say Something Anonymous Reporting System “stories of impact” and/or tip data, as well SAVE Promise Club and youth engagement stories and news, internally, with donors, members of the media, as part of national/regional research projects, and our Say Something Anonymous Reporting System partners to showcase the impact our program has on student lives and their school and community culture, and to make changes to programs, where necessary. When we share these stories and data, all information specific to gender, location, and any other details that could allow the tipster, victim, or the school to be recognized are scrubbed from story or data, unless otherwise agreed to by such individuals or schools. Any use of tip data in research is similarly aggregated and anonymized.

DISCLOSURE OF INTERNET PROTOCOL (IP) ADDRESS AND CALLER ID INFORMATION

Sandy Hook Promise takes the anonymity of our tipsters very seriously—after all, the promise of anonymity is the foundation of our program and one of the important reasons we have been able to save countless lives. We have an unequivocal commitment to protecting the anonymity of those who Say Something to get help for someone who is a potential danger to themselves or others—that is, for tipsters who report in good faith.

As noted above, there are rare cases, in which a tipster may make a false claim or use the Platform to harass or intimidate others—and in such cases, anonymity of the tipster is not guaranteed. Our Crisis Center Team has access to two pieces of information that can help a school district narrow-down or identify a tipster, if required:

• IP address (for App or Site tips); and
• Caller ID information (for Phone tips).

We will not disclose IP address or caller ID information to a school district, unless they first:

1. Submit a formal request for IP address/Caller ID retention;
2. Provide a detailed articulation of surrounding events, investigation efforts/outcomes, a law enforcement case number, and contact information for a law enforcement sponsor; and
3. Conduct a phone call with Crisis Center Management to discuss the rationale behind the request

What to Know about IP Addresses:

• IP addresses are stored by the Platform only for 72 hours following a tip’s initial submission. Once this 72-hour window has closed, the Platform permanently purges the IP address and it is no longer available.
• School districts must make IP address retention requests within this 72-hour window. When a school district timely requests IP address retention, a member of the Crisis Center Team pulls and securely stores the subject IP address or addresses.
• We will not disclose a retained IP address until the school district provides proper documentation, including an articulation of events and outcomes (based on the Disclosure Criteria listed below) and the Crisis Center Director or their designee approves such documentation.
• Disclosure of an IP address does not necessarily “break anonymity” and does not guarantee the school district will be able to identify the tipster. An IP address is a single clue in support of a broader investigation.
• IP addresses are unreliable for identification purposes when they are associated with public internet service (e.g., Starbucks, school Wi-Fi, etc.), originate from a mobile hotspot, or are concealed by a VPN (virtual private network).
• Finally, unlike with telephone numbers, there are no “reverse lookup” solutions with respect to IP addresses. Rather, internet service providers (e.g., AT&T) will require a subpoena to disclose the subscriber information associated with an IP address, which can be used to narrow the identity of a tipster. This particular area of technical support is not generally available outside of standard business hours. Additionally, any information obtained from an internet service provider typically pertains to an adult account holder and not a juvenile. This may require additional resources to connect the adult account holder to a potential juvenile in question for this information to be useful for identification purposes.

IP Address/Caller ID Disclosure Criteria

First-person Tips: Tipster is reporting about themselves or about harm they are planning to commit.

• Imminent threat to life or property.
• Tipster refuses to self-identify.
• Tipster refuses to provide any details that can be used by school district / school personnel or law enforcement to identify the tipster.

Third-person Tips: Tipster is reporting about someone else or about a threat with which the tipster is not involved.

• Information provided is seemingly legitimate and credible.
• Upon a thorough investigation, a reasonable person would conclude that the information was deliberately false and provided with the intent to harm or disrupt (i.e., information was provided in bad faith and considered an “abuse of the system”).
• Results in a significant expenditure of time and/or resources OR in undue harm to others.

REQUESTS ABOUT YOUR PERSONAL INFORMATION

You may request that your personal information on our Platform or in our related systems be removed at any time, for any reason, by sending an email to [email protected], Subject: REMOVE MY INFORMATION. We will make all reasonable efforts to comply with your requests, subject to any contrary legal requirements. In addition, if you do not want your information shared, sold, or rented to other nonprofit organizations, or third parties, please send an email to [email protected], Subject: DO NOT SHARE MY INFORMATION and we will add you to our do not share list.

CHANGES TO THIS POLICY

We may update this Policy periodically and without prior notice to you to reflect changes in our information practices. Whenever we update this Policy, we will post the revised Policy through the Platform.

CONTACT US

If you have any questions about this Policy or our use of your information collected through the Platform, please contact us at [email protected].