Last Revised: July 31, 2019
We may need to change the Policy from time to time in order to address new issues and to reflect changes on the Sites or in the law. We reserve the right to revise or make any changes to the Policy, and your continual use of the Sites subsequent to any changes to this Policy will mean that you accept such changes. Therefore, please bookmark this page and review it periodically to assure familiarity with the most current version of the Policy. We will post all changes to the Policy here so that you will always know what information we gather, how we might use that information, and when and how we will disclose that information. You can tell that the Policy has been updated by checking the last revised date posted on the top of this page. If due to such changes, you decide that you want to delete any portion of your personal information from our database, please notify UJA-Federation at .
YOU CONSENT TO OUR USING ANY INFORMATION THAT YOU PROVIDE TO US OR THAT WE COLLECT, IN ACCORDANCE WITH THE TERMS AND THE TERMS AND CONDITIONS OF THIS POLICY.
Information We Collect and Track. UJA-Federation collects and retains two types of information: (i) personal information that individuals, including donors, provide when interacting on the Sites, or voluntarily provide on certain other occasions (such as via the phone, in person meetings, emails or in response to mailings); and (ii) tracking data, which is automatically collected from every Site visitor, (collectively, "Information"). The Information that we gather may include your name, title and address (collectively, "Postal Information"), telephone number, email address, credit card number or other elements of personal information.
In addition, if you contact us, we may keep a record of your correspondence, including any Information contained therein (other than payment/credit card information).
You may decline to provide any personal information, but please realize that you thereby may be unable to register on UJA-Federation's website or to participate in activities or services offered by UJA-Federation.
The tracking data we record includes, without limitation, information regarding the number and frequency of visits to the Sites, the websites that you access before and after you visit the Sites, the Internet software used to access the Sites, and your IP address and Internet service provider.
How We Use Your Information. The Information that we collect and that you provide to us is used for our business purposes and the purpose for which you provided it, including, without limitation, to respond to your requests or correspondence. UJA-Federation may also use the Information to contact you about the Sites or to request your input regarding ways in which we might improve the Sites. We may also use your Information to inform you about UJA-Federation's activities, products, services, events and fundraising efforts in which UJA-Federation hopes you may be interested. The Information may also be analyzed so that we can provide you with useful information and can serve you in the best manner possible through enhanced features and functions on the Sites.
We will not disclose any personal information to third parties, except (i) to parties who perform a service for us, such as sending you mail or email, web hosting, credit card processing and other similar services; (ii) when we believe that such disclosure is required by law; (iii) to enforce this Policy or the Terms; (iv) to protect the rights, property, security or safety of UJA-Federation, UJA-Federation donors, Site users or the public; (v) to respond to an emergency; or (vi) as otherwise stated in this Policy. In addition, we may disclose Information to certain third parties if you have requested or authorized the disclosure of such Information.
Information provided to third parties is limited to the Information needed to perform their functions. We seek to limit third-party use of Information; however, we are not responsible for such third-party use of Information that is not in compliance with this Policy.
UJA-Federation may make your Postal Information available to other, pre-screened, reputable not-for-profit organizations. This information is never sold, and if any person, including donors, would like to opt out of having UJA-Federation share your Postal Information with other not-for-profit organizations, please either email with "Opt Out" in the subject line, call the Donor Center at (212) 836-1486, or write us at UJA-Federation of New York, 130 East 59th Street, New York, NY 10022.
UJA-Federation may use certain tracking data. Tracking data information may be used for a variety of purposes, including but without limitation, to compile statistical, demographic or aggregated information about visitors to the Sites generally, or for load balancing metrics and also may be used to create reports on user demographics and the traffic patterns of the Sites. The reports that are generated from tracking data are used for a variety of purposes, including, for example, to improve the Sites and our services.
Blog Postings. You should be aware that any information provided or content posted by you to the Sites may be read, collected or used by other visitors of the Sites. UJA-Federation is not responsible for the third-party use of any Information provided in such manner. By participating in the use of the blog, you consent to UJA-Federation's use or disclosure of any content that you submit.
Transfer of Information to Third Parties Upon a Sale or Change of Control. We retain the right to transfer or assign all Information pursuant to a merger, purchase or other transaction relating to UJA-Federation or our assets if the assignee or purchaser agrees to abide by the terms of this Policy.
How Your Information Is Protected. We take reasonable precautions to protect your Information from loss, misuse or alteration. We maintain reasonable physical, electronic and procedural safeguards for your Information. You should recognize, however, that there is no such thing as "perfect security" on the Internet, and we cannot guarantee the security of your Information. In addition, because Internet communication is unsecure, it is also possible that the information you supply to us or your access of any information via the Sites will be intercepted during transmission. We are not liable for any breach of our systems or interception of our transmission, and we hereby fully disclaim, to the fullest extent provided under law, any liability associated with any claim relating to a breach of security, data or information.
Other Communications. From time to time, we may email donors and/or users of the Sites information regarding important developments affecting UJA-Federation. We may also email users on occasion regarding the Sites. Such emails may be sent to users of the Sites even if they have not requested to receive any communication from us.
Referrals. If a user elects to use our referral service to inform a friend about the Sites, we request the name and email address of the friend. UJA-Federation will automatically send the friend a one-time email inviting him or her to visit the Sites. UJA-Federation stores this information for the sole purpose of sending this one-time email.
Links to Third-Party Sites. The Sites may contain links to websites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. We encourage you to review the privacy policies of those sites prior to providing them with any information.
Children Under the Age of 13. Because UJA-Federation is concerned about the privacy protection of children who access the Internet, we comply with the Children's Online Privacy Protection Act (COPPA). Accordingly, the Sites are not intended for use by anyone under the age of 13, and we do not knowingly collect Information from anyone under 13 years of age without the consent of a parent or guardian.
Compliance With Laws. We reserve the right to disclose any Information to comply with any law, regulation, decree, judgment, order, subpoena or any other governmental order ("Order") without any obligation to contest or verify the accuracy of such Order.
Applicable Law. This Policy will be governed by and construed in accordance with the laws of the State of New York, without regard to any principles of conflicts of law. You agree that any action at law or in equity that arises out of or relates to any use of the Sites will be filed only in the state or federal courts located in New York County, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action.
How You Can Update or Correct Your Information and Contact the Site. You can call or email UJA-Federation at the numbers provided on the Sites or send a message to to update or correct your Information.
UJA-Federation is committed to the highest standards of ethical conduct. Given UJA-Federation’s mission and responsibilities, which literally span the globe, all employees, Board members and lay leaders have an obligation to preserve the organization’s reputation and standing, in our community and beyond, to uphold the public trust, and to act in an ethical and lawful manner. UJA-Federation requires its employees, Board members and lay leaders (“UJA-Federation personnel”) to observe high standards of business and personal ethics, and to comply with all applicable laws and regulations, in the conduct of their duties and responsibilities for the organization. Accordingly, UJA-Federation has established a Standards and Conflicts Committee, so that potential ethical issues can receive the attention they deserve. UJA-Federation’s reputation for acting in accordance with the highest standards of ethical conduct is one of its most valuable assets. The assistance of all employees, Board members and lay leaders in preserving this asset is both expected and sincerely appreciated.
As part of its overall commitment to the highest standards of ethical conduct, UJA-Federation has established a Whistleblower Policy (the “Policy”). This Policy has been developed and implemented to encourage employees and volunteers to make good faith reports of possible violations of law or infractions of rules or organizational policies by any UJA-Federation personnel, and to raise any concerns they may have about such matters, confidentially and without fear of retaliation, within UJA-Federation prior to seeking a resolution outside the organization. Reports also may be made through this process regarding inappropriate acts or possible breaches of law or established policy by entities with whom UJA-Federation does business, such as vendors or service providers, including investment managers or consultants.
PLEASE NOTE THAT THIS WHISTLEBLOWER POLICY APPLIES TO UJA-FEDERATION AND ITS EMPLOYEES, BOARD MEMBERS AND LAY LEADERS. WHILE THIS POLICY DOES NOT APPLY TO GRANTEE AGENCIES, WHICH HAVE THEIR OWN POLICIES AND PROCEDURES, IF UJA-FEDERATION RECEIVES A REPORT ABOUT POSSIBLE VIOLATIONS AT A GRANTEE AGENCY. WE WILL APPRISE THE AGENCY OF SUCH REPORT AND INQUIRE ABOUT STEPS TAKEN TO ADDRESS THE COMPLAINT.
Types of matters that should be reported under the Whistleblower Policy include suspected fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, abuse or misuse of UJA-Federation’s resources or assets, conflicts of interest, suspected compliance or ethics-related issues, concerns or violations, or suspected wrongdoing.
The Whistleblower Policy reporting mechanisms may also be used to report human resources issues, personal problems with co-workers or managers, or matters of workplace discrimination or harassment. However, these types of matters are more typically handled using the “Internal Complaint Procedures” outlined in the UJA-Federation Employee Policy Manual.
In order to encourage UJA-Federation employees and volunteers to come forward with any good faith report of suspected illegal or unethical behavior on the part of any UJA-Federation personnel, all reports made through the mechanisms established under the Whistleblower Policy will be treated as confidential to the utmost extent possible.
Reports may also be made anonymously, as described below.
Moreover, no person who makes a good faith report under the Whistleblower Policy may be subject to any form of retaliation, harassment or adverse employment action. Any employee who engages in any such retaliatory action is subject to serious disciplinary action, including possible termination of employment.
Any person who makes a report pursuant to the Whistleblower policy will be treated with dignity and respect.
Several avenues have been established to receive Whistleblower reports from particular sources, as described below. However, these avenues are in no way restrictive; a person making a report under the Whistleblower Policy may contact any of the following persons:
The Chair of the Standards and Conflicts Committee of UJA-Federation has been designated as the primary recipient of complaints of wrongdoing from members of the Board of Directors, lay leaders and members of the public. Currently, Gary Rosenberg serves as Chair of the Standards and Conflicts Committee. Mr. Rosenberg may be reached directly at (212) 551-8410 or at firstname.lastname@example.org.
Two persons have been designated as primary contacts to receive reports of wrongdoing from UJA-Federation staff members: UJA-Federation’s General Counsel and Chief Compliance Officer and UJA-Federation’s Vice President of Human Resources. Ellen Zimmerman serves as General Counsel and Chief Compliance Officer of UJA-Federation, and Sari Ferro serves as UJA-Federation’s Vice President of Human Resources. Ms. Zimmerman may be reached directly at (212) 836-1312 or . Ms. Ferro may be reached directly at (212) 836-1650 or .
To ensure that any person wishing to make a good faith report in a confidential setting will feel assured of such confidentiality, UJA-Federation has retained an outside organization, ComplianceLine, that specializes in handling reports about perceived violations of law or organizational policies. Reports to this organization may be both anonymous and non-anonymous. Instructions as to making a report may be found at www.MyComplianceReport.com (enter the Access I.D. “UJA”) or by calling (888) 495-4351.
All persons receiving reports are responsible for investigating and resolving all reported complaints and allegations expeditiously, and will promptly contact the complainant to acknowledge receipt of the reported concern. If ComplianceLine receives the report, an investigation will be conducted internally by the appropriate person designated by the Chief Compliance Officer of UJA-Federation. All reports will be promptly investigated to the extent possible and appropriate corrective action will be recommended to UJA-Federation’s Standards and Conflicts Committee, Audit Committee and Executive Committee, as and if warranted by such investigation. In addition, the Chief Compliance Officer will coordinate with the Chair of the Standards and Conflicts Committee to report annually to the Executive Committee on all investigations.
The Whistleblower Policy has been established as part of UJA-Federation’s comprehensive effort to maintain the highest standards of ethical conduct. As described above, this Policy has been structured to encourage UJA-Federation’s employees and volunteers to come forward and report, in good faith, confidentially, and without fear of reprisal, any suspected violations of law or organizational rules or policies by UJA-Federation personnel.
Amended as of February 1, 2017 by the UJA-Federation Standards and Conflicts Committee
United Jewish Appeal-Federation of Jewish Philanthropies of New York, Inc. (“UJA-Federation”) is a nationally and internationally known and respected public charity and nonprofit organization, with a long-standing reputation for lawful and ethical conduct. We believe the trust and confidence of our donors, volunteers and other supporters depend on our continuing to maintain the highest standards of ethical and lawful conduct. It is also UJA- Federation’s position that all of its leaders must comport themselves so that there is not even the appearance of conflict between personal interests and those of the organization. To ensure the continuity of its high standards of conduct, UJA-Federation desires to set forth the common understandings that must exist among its many lay leaders and other members of the community regarding its practices.
While this memorandum does not contain all of UJA-Federation’s rules and policies, it is intended to assist in understanding UJA-Federation’s policies and practices relating to business transactions, and its allocations processes, to clarify principles that must guide its conduct, and to provide guidance in resolving ethical and legal questions that might arise.
Download a PDF of the full text of our Ethical Guidelines and Practices.
Last Revised: January 21, 2011
Honesty: Fundraisers shall at all times act honestly and truthfully so that the public trust is protected and donors and beneficiaries are not misled.
Respect: Fundraisers shall at all times act with respect for their organization and with respect for the dignity of donors and beneficiaries
Integrity: Fundraisers will act openly and with regard to their responsibility for charitable dollars entrusted to UJA-Federation. They shall disclose all actual or potential conflicts of interest and avoid any appearance of personal or professional misconduct.
Transparency: Fundraisers are to generate clear reports about the work they do, the way donations are recorded, and costs and expenses, in an accurate and clear manner.
UJA-Federation is fully accountable for the honest solicitation of charitable funds, the efficient administration of those funds, and the effective use of funds in pursuit of our organization’s mission.
We strive to meet the highest standards of accountability and professionalism, as follows, by:
We respect a donor’s right:
In raising funds via the internet, UJA-Federation:
UJA-Federation fundraising activities are designed to comply with all applicable local, state and federal laws, as well as with all internal rules and policies of UJA-Federation.
UJA-Federation is pleased to provide its Agency Accountability Guidelines for informational purposes. In developing these Guidelines, UJA-Federation received guidance from legal and financial professionals with expertise in not-for-profit governance and fiscal responsibility, to establish appropriate standards to be considered by UJA-Federation as a funder of network agencies and other not-for-profit organizations. Our grantees are each 501 (c) (3) organizations, with independent boards of directors, and are expected to obtain appropriate professional guidance about matters of governance, fiscal policy and procedure.
Copyright 2011 – 2017 United Jewish Appeal-Federation of Jewish Philanthropies of New York, Inc.
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