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Privacy Policies

Effective Date: December 13, 2025

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1. Introduction and Commitment to Privacy
The Rouben Malian Memorial Foundation Inc. (hereinafter referred to as "the Foundation," "we," "us," or "our") is deeply committed to protecting the privacy and security of our donors, website visitors, and partners. We understand that your decision to support our mission—whether through financial contributions, advocacy, or simply visiting our website—is based on trust. We value that trust and are dedicated to maintaining the highest standards of integrity in how we handle your personal information.

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This Privacy Policy (the "Policy") serves as a comprehensive disclosure document explaining how we collect, use, protect, and share information gathered through our website (the "Site") and through offline channels. By accessing the Site or providing us with your personal information, you agree to the terms and practices described in this Policy.

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2. Information We Collect
We collect information in two primary categories: Personally Identifiable Information (PII) and Non-Personally Identifiable Information (Non-PII).

 

2.1 Personally Identifiable Information (PII)
PII is information that can be used to identify you specifically. We only collect PII when you voluntarily submit it to us. Instances where we may collect PII include, but are not limited to:

  • Donations: When you make a financial contribution, we collect your first and last name, billing address, email address, telephone number, and payment information (credit card numbers, CVC codes, and expiration dates). Note that payment information is generally processed by secure third-party payment processors and is not stored directly on our servers.

  • Communications: When you subscribe to our newsletter, fill out a "Contact Us" form, or sign up for a volunteer opportunity, we collect your name, email address, and the content of your message.

  • Tribute Gifts: If you make a donation in honor or memory of someone, we may collect the name and contact information of the honoree or their family to send an acknowledgment letter.

  • We collect a mobile telephone number from volunteers and partners for account authentication.

 

2.2 Non-Personally Identifiable Information (Non-PII)
When you interact with our Site, we automatically collect certain data that does not identify you personally but helps us understand how our Site is used. This includes:

  • Log Data: Our servers automatically record information including your Internet Protocol (IP) address, browser type and version, operating system, the referring web page, pages visited on our Site, the time and date of your visit, and the time spent on those pages.

  • Device Information: We may collect information about the device you are using to access the Site, including the hardware model and unique device identifiers.

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3. How We Use Your Information
The Foundation uses the information we collect for specific, mission-driven purposes:

  • Processing Transactions: To verify your identity, process your donation, issue an official tax receipt, and prevent fraudulent activity.

  • Communication: To respond to your inquiries, send you administrative messages (such as changes to this Policy), and provide you with updates regarding our programs, the impact of your gifts, and upcoming events.

  • Stewardship: To properly thank you for your generosity and maintain a history of your support for our internal records.

  • Site Improvement: To analyze trends, administer the Site, track user movements, and gather broad demographic information for aggregate use. This helps us optimize our content and ensure the Site is technically robust.

  • Legal Compliance: To comply with applicable laws, regulations, and legal processes, such as responding to subpoenas or government requests.

  • Account authentication and security.

 

 

4. Cookies and Tracking Technologies
4.1 Use of Cookies
Our Site may use "cookies" to enhance your user experience. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

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We use cookies for various purposes:

  • Essential Cookies: These are necessary for the operation of the Site, such as maintaining your session while you navigate through donation pages.

  • Analytics Cookies: These allow us to recognize and count the number of visitors and to see how visitors move around the Site. We use tools like Google Analytics to help us understand this data.

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4.2 Managing Cookies
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Foundation’s services or websites you visit.

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5. Sharing and Disclosure of Information
We do not sell, rent, or trade our donor lists to other organizations or companies. However, we may share your information in the following limited circumstances:

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5.1 Service Providers
We engage trusted third-party service providers to perform functions on our behalf. These may include:

  • Payment Processors: To securely process credit card transactions.

  • Email Marketing Services: To distribute our newsletters and alerts.

  • Database Management: To host and maintain our donor records. These service providers have access to personal information needed to perform their functions but are contractually restricted from using it for other purposes.

  • Identity and Account-Security Providers: To authenticate volunteer and partner logins and to detect and prevent fraudulent or unauthorized access to our systems, we use telephone-verification and fraud-prevention services (such as Twilio Inc.), as described in Section 7.

 

5.2 Legal Requirements
We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to:

  • Comply with a legal obligation or a court order.

  • Protect and defend the rights or property of the Rouben Malian Memorial Foundation.

  • Prevent or investigate possible wrongdoing in connection with the Site.

  • Protect the personal safety of users of the Site or the public.

 

 

6. Data Security
We implement a variety of security measures to maintain the safety of your personal information.

  • Encryption: Sensitive information (such as credit card data) is transmitted via Secure Socket Layer (SSL) technology, which encrypts the data during transmission.

  • Access Control: Access to your personal information is restricted to authorized personnel who need the information to perform specific jobs (e.g., billing or donor services).

  • Physical Security: The servers on which we store personally identifiable information are kept in a secure environment.

  • Disclaimer: While we strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

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7. Volunteer and Partner Account Security and Verification

 

7.1 Overview

The Foundation maintains secure online accounts for volunteers and partners who are granted access to our internal systems, tools, and records in connection with our programs. Because these accounts may provide access to sensitive personal information, we apply additional identity-verification and account-security measures when a volunteer or partner registers for, signs in to, or makes sensitive changes to such an account. To provide these measures, we use telephone-number verification and fraud-prevention services supplied by our third-party provider, Twilio Inc. ("Twilio"). When a volunteer or partner provides a mobile telephone number for account access, we may transmit that number to Twilio, which checks it against information held by the relevant mobile carrier. We use the results solely to verify the account holder's identity, detect signs of account compromise, and decide whether to permit a sign-in or other sensitive action. We do not use these results for marketing, advertising, or any unrelated purpose. The specific checks we may perform are described below.

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7.2 Silent Network Authentication

We use Silent Network Authentication to confirm that a volunteer or partner is in possession of the mobile telephone number associated with their account by verifying it directly against the mobile carrier's network over the device's data connection, without sending an SMS one-time passcode. This provides a streamlined authentication step during account sign-up and sign-in while reducing the interception and phishing risks associated with SMS-based codes. The result is used only to allow or deny the authentication attempt.

 

7.3 SIM Swap Detection

We use SIM Swap detection to determine whether the SIM card associated with a volunteer's or partner's mobile number has been changed recently before we rely on that number to verify identity or authorize a sensitive action, such as a sign-in or password reset. A recent SIM change can indicate an account-takeover attempt in which a third party transfers a victim's number in order to intercept verification codes. Where a recent change is detected, we may require additional verification, delay or decline the action, or route the account for manual review.

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7.4 Reassigned Number Detection

We use Reassigned Number detection to determine whether a mobile number on file has been deactivated and reassigned to a different subscriber since we last verified it. This helps prevent us from sending verification codes, account notifications, or other sensitive communications to an unintended recipient, protects the privacy of both former and current subscribers, and supports our obligations regarding contacting reassigned numbers.

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7.5 Identity Match

We use Identity Match to confirm that the identifying details a volunteer or partner provides to us — such as name and address — are consistent with the information the mobile carrier holds for the telephone number associated with their account. This strengthens our verification process when an account is established and helps us detect the use of false, synthetic, or misappropriated identities to gain access. Any match result is used as one factor in our security decision and for no unrelated purpose.

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7.6 Call Forwarding Detection

We use Call Forwarding detection to determine whether calls to a volunteer's or partner's mobile number are being diverted to another line before we use a voice channel for verification or otherwise rely on the number for authentication. Unexpected call forwarding can indicate an attempt to intercept voice-based verification or account-recovery calls. Where this is detected, we may rely on an alternative verification method or flag the account for review.

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7.7 Consent and Choice

Where required by applicable law, we will obtain a volunteer's or partner's consent before performing these checks. A volunteer or partner may decline by choosing not to use telephone-based account access, in which case we will offer an alternative method of verification where available. Twilio processes this information on our behalf as a service provider and is contractually restricted from using it for any purpose other than providing these services to us.

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8. Children’s Privacy
Our Site is not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to remove that information from our servers.

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9. International Users
The Foundation is headquartered in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the U.S. where our servers are located. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

 

 

10. Your Rights and Choices
You have specific rights regarding the personal information we hold about you:

  • Opt-Out: You may opt-out of receiving future fundraising or educational communications from us by following the "unsubscribe" instructions in those emails or by contacting us directly.

  • Access and Correction: You may contact us to request access to the personal information we hold about you and to ask for corrections if that information is inaccurate.

  • Deletion: You may request that we delete your personal information, subject to our legal obligations to retain certain financial records for tax and auditing purposes.

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11. Changes to This Policy
The Rouben Malian Memorial Foundation reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

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12. Contact Us
If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, please contact us:

Rouben Malian Memorial Foundation 1 Rockefeller Plaza, Level 15 New York, NY 10020

Email: [email protected]

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