Privacy Policy of American Pilgrims on the Camino
Adopted by the board of directors, January 10, 2020

American Pilgrims on the Camino was established to celebrate, promote and support the Camino de Santiago, a network of ancient pilgrimage routes leading to Santiago de Compostela in northwest Spain. We are a registered 501(c)(3) nonprofit, volunteer-driven, organization and we aim to be the premier resource for information and meeting point within the community of pilgrims in the United States. We are continually seeking meaningful ways to support and give back to the Camino de Santiago.
Our mission is to foster the enduring tradition of the Camino by supporting its infrastructure, by gathering pilgrims together, and by providing information and encouragement to past and future pilgrims, no matter their method of travel to Santiago, either on foot, by bike, on horseback or in a wheelchair.
This policy explains how we collect, manage, use and protect your personal data. “Personal data” includes any information allowing you to be identified as an individual.
This document may be changed or updated from time to time, so please check back to see if we have made any changes to how we handle your data.

1. Who “we” are
The terms “American Pilgrims on the Camino,” “American Pilgrims,” “we,” and “our” refer to American Pilgrims on the Camino, a 501(c)(3) nonprofit organization registered in California.

2. When we collect personal data
We collect personal data from you when you complete any of our order forms. When you order from us (join the organization, register to attend a Gathering, make a donation, or request a credential) you will be asked to provide contact information (like name, telephone, email address and mailing address) and financial information (like credit card number and expiration date). This information is used for billing purposes and to complete your request. If we have trouble processing a request, we’ll use this information to contact you. We will also use this information to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information about yourself, but it is not required.

3. What personal data we collect
No registration is required to use this website and therefore we do not require you to disclose any personal data to us to browse our website. You do need to provide us with certain personal data in order for us to provide you with certain services:
Membership: Basic personal data such as name, mailing address, email, phone number, and additional optional information including volunteer interests, professional skills, Gatherings attendance, Camino experience, and member comments.
From our website pages: Using Google Analytics, we track what pages you visit, how long you spend on each page, how you found us, and if you have visited us before. None of this information can be traced back to you. It is not linked to any personal information that can identify any individual person. If you request a credential or register for an event, we ask you to create an account with us and provide the information required on that form. We will not share or sell it with anyone not associated with the organization or our business partner.
From other websites: Notification of payments or donations is made through our designated payment collection services. We have no access to the bank account or credit/debit card details which you provide to these third parties.
3.1 Children
The safety and privacy of children is very important to us. A parent or guardian may include a child aged under 18 as part of a household membership but we do not knowingly communicate directly with a child, only with the first named adult member. The minimum age for a student membership is 18 years.

3.2 Personal Data: Bank Accounts and Credit Cards
Bank Accounts: We use the NeonPay platform to process regular membership, event registration and donation payments made by debit or credit card. We do not have access to the bank account and full card details you provide to them.
Occasionally, an individual makes a payment by personal check. A copy of the check is kept by our bank for six months and is accessible to us during that time.
Credit Cards: Website payments are processed by NeonPay and we do not have access to the full credit card details.

4. Cookies
We do not use cookies on our website.

5. How we use personal data
We use your personal data for the following purposes:
To provide you with the products, services and information you request from us;
To analyze transactions and improve our products, services and website;
To keep accurate membership records to support and engage with our members and to fulfill our obligations to them;
To maintain local chapter membership lists;
To support our volunteers;
To send you American Pilgrims-related information about news, events, products, services, and activities;
To keep accurate financial records supported by internal control procedures;
To perform our obligations under any contracts we enter into with you.
Consent: You give us specific permission to contact you, and the details of your preferred method. You can withdraw your consent at any time by contacting us.

6. How we share personal data
We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone nor will it be posted for general public access. We will use your information to respond to you regarding the reason you contacted us. We will not share your information with any third party outside of our organization other than as necessary to fulfill your request (such as to mail a credential).
Unless you opt-out, we may contact you via email in the future to tell you about our latest newsletter, upcoming local or national events that might be of interest to you, new products or services, or changes to this privacy policy.

7. How we protect and store personal data
We take precautions to protect your information. We know how much data security matters to you, and we will treat your data with the utmost care and take all steps reasonably necessary to protect it and ensure it is treated securely and in accordance with this Privacy Policy and applicable law.
When you submit sensitive information via the website, your information is protected both online and offline. All information electronically stored is backed up on the servers of our suppliers who host our IT systems. All payment details are encrypted and any account passwords for our site are also encrypted and cannot be shared.
While we do everything we can to ensure that electronic submission of data via email or our website is secure, we cannot guarantee total safety. Any transmission is at your own risk. Once we have received personal information, we will use strict procedures to keep it confidential. Only individuals who need the information to perform a specific job (such as membership services) will have access to personally identifiable information.
We will keep your information only for as long as you engage with us in any of the above ways, and only as long as we need it.
We will, on a regular basis, review the personal data we collect and hold, to ensure the data is kept only for the appropriate amount of time.
8. Your individual rights
8.1 You have the following rights regarding personal data that we hold about you. If you would like to exercise any of the rights, please contact us.
(a) Access. You have the right to ask us to provide you with a copy of your personal data and the other details we hold about you.
(b) Rectification. We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about you.
(c) Prevention of processing likely to cause damage or distress. We will cease processing your personal data for a specific purpose, or in a specific way, if it is likely to cause unwarranted damage or distress, either to you or a third party.
(d) Erasure. At your request, we will delete your personal data in a timely manner.
(e) Restriction. We will restrict the processing of your personal data in certain circumstances (e.g. if you believe your personal data held by us is inaccurate), if requested by you to do so.
(f) Right to opt-out. You can opt-out of the processing of your personal data for a particular purpose.
(g) Right to opt-out of marketing. You can opt-out of our using your data to contact you for direct marketing purposes
8.2 We will process all personal data in line with your rights in each case in accordance with the time limits and requirements of applicable law.

9. Contacts and Complaints
You may ask any questions and make any requests, comments, or objections regarding this policy and/or our use of your data by emailing info@americanpilgrims.org or by writing to American Pilgrims on the Camino, 120 State Avenue NE #303, Olympia, WA 98501.
We are not a “public authority” as defined by the Freedom of Information Act 2000, and we will therefore not respond to requests for information made under that Act.

Last Updated: February 16, 2020
Issued by American Pilgrims on the Camino, 120 State Avenue NE #303, Olympia, WA 98501