Privacy Policy

Effective Date: December 14, 2023
Last Updated: September 3, 2024

This Privacy Notice (“Notice”) describes how Allies in Arts’ Transanta project (“Transanta,” “we,” “us,” and “our”) collects, uses, and discloses your information when you engage with us online, such as when you visit our website (https://www.transanta.com/) (the “Site”) or otherwise use or interact with any services that reference this Notice (collectively, the “Services”). 

Allies in Arts is a 501(c)(3) non-profit organization located in Los Angeles, California. Transanta is a mutual aid project under Allies in Arts’ umbrella that connects gift-givers with trans youth.

If you reside in the European Economic Area (“EEA”) or the United Kingdom (“UK”) you should also refer to our EEA- and UK-specific Privacy Notice titled Privacy Notice for Users in the EEA and the UK

For users who do not reside in the EEA or UK, by visiting the Site or using any of our Services, you agree that your personal information will be handled as described in this Notice. Your use of our Site or Services, and any dispute over privacy, are subject to this Notice and our Terms of Use, available at https://www.transanta.com/terms-of-use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Notice.

I. Personal Information We Collect About You

As further described below, we collect personal information directly from you, as well as from third parties and automatically through your use of our Site and Services. 

Personal Information We Collect Directly From You. The personal information we collect from you depends on how you use and interact with our Services.  

  • Application Information. If you submit an application form, we collect or receive your name, age, address, email, phone number, Amazon registry information, gender identity, demographic information, and any other information you choose to provide in your letter/submission. 

  • Donor Information. If you donate to our organization, we collect your name and donation amount. Note that we do not store payment card data – instead, we use a vendor to securely receive donations. Our vendor is responsible for securely maintaining payment card data.

  • Contact Information and Communications. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also collect any personal information you choose to email or communicate to us while using the Services.

  • Social Media Information. We also maintain records of communications and information that you post on our social media channels.

Information We Collect Automatically. We automatically collect personal information about your use of our Site and Services through cookies and other technologies. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information. Such personal information includes: 

  • Device and browsing information. We use cookies and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, precise location information, browser type, device information, device ID, Internet service provider, referring and exiting URLs, operating system, and similar device and browsing information. For more information, see Section IV. Cookies and Other Tracking Mechanisms, below.

  • Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent using the Services.

  • Location information. We may collect or derive location information about you, such as through your IP address and precise geolocation information from your device. You may turn off location data sharing through your device settings. 

For more information, please see the Section IV. Cookies and Other Tracking Mechanisms below.

II. How We Use Personal Information

We use your personal information for the following purposes:

  • Providing Services and Operations. To provide and operate our Services, including to assess the validity of your application, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, improve the Services, and for similar service and support purposes. 

  • Security and Protection of Rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Notice. 

  • Legal Compliance. To comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.

  • Business Purposes. For purposes related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and for other business transactions. 

  • Other Permissible Uses. We may use personal information for purposes not provided for in this Notice, but if we do, we will notify you (and, if necessary, obtain your consent) before using your information in this way.

III. How We Share Your Information

We may share your personal information in the following circumstances:

  • Anonymous Gift-Givers. As part of our Service, we disclose the first name you provide us on your submission, your age, and the caption you write for your application with anonymous gift-givers who participate in our Service.

  • Service Providers. We may disclose the personal information we collect from you to service providers, contractors, or agents who perform functions on our behalf, such as entities that host our Site, provide information technology, and perform other support services related to our Services. 

  • Affiliates. We may disclose the personal information we collect from you to our affiliates.  

  • In Response to Legal Process. We may disclose your personal information to comply with the law or other legal process. However, we will take steps to protect personal information from government overreach where feasible

  • To Protect Us and Others. We disclose your personal information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Notice, or as evidence in litigation in which we are involved. 

  • Compliance and Related Purposes. We may disclose personal information for purposes related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and for other business transactions. 

  • Restructuring or Dissolution. If Allies in Arts ceases operations, we may disclose personal information to a successor organization to keep Transanta operational.

  • With Your Permission. We may disclose personal information in ways not described above. If we do so, we will notify you and, if required by law, obtain your consent.

IV. Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve our Services. You have certain choices about our use of cookies within the Services, as described in this section.

Cookies. A cookie is a small alphanumeric identifier that is placed on your website browser when you visit a website. Cookies are transferred to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session while accessing our Site and Services. This allows us to display content and provide our Services to you while navigating our Site.

  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track statistical information about user activity. 

Disabling Cookies. Most website browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function. For more information on how you can customize your browser’s cookie setting, please visit the link to your web browser below:

We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track activities of Site visitors, and to help us manage content on our Site and Services. 

Do-Not-Track. Some web browsers offer a “Do-Not-Track” setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

V. Your Rights

Depending on your country of residence, users of our Services may have certain rights regarding personal information. These may include the right to access, rectify, or delete personal information. A parent or guardian may also be entitled to exercise rights on behalf of a minor. We will review all rights requests we receive to ensure that complying with such requests does not put our users in danger. To exercise a right, please use the Contact Us information below.

VI. Links

Our Site and Services may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Notice, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. 

VII. Security

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. 

VIII. Changes to this Notice

This Notice is current as of the Effective Date set forth above. We may change this Notice from time to time, so please be sure to check back periodically. If we change this Notice, we will post the updated Privacy Notice here, and those changes will go into effect on the “Last Updated” date shown above. If we make any changes to this Notice that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

IX. Contact Us

If you have any questions about our Notice you can contact us at privacy@alliesinarts.org or at PO Box 39875, Los Angeles, California 90039.

Additional Privacy Notice for Users in the EEA, and the UK

This section of our Notice applies in addition to the main body of our Notice. It applies specifically to individuals located in the EEA, or the UK.

The controller of our user’s personal information is Allies in Arts, a 501(c)(3) organization located in Los Angeles, California.

I. International Transfers of Your Personal Information

Allies in Arts is a 501(c)(3) organization based in the United States, and Transanta is a program operating under Allies in Arts’ umbrella. If you choose to use our Services, your personal information will be transferred to the United States. Such transfer is necessary to perform the Terms of Use and to provide you with the Services, as well as access to the Site. Third-party recipients of your personal information (see ‘How We Share Your Information’) may also be located in the United States, or in other countries outside of the EEA and the UK. You should be aware that the data protection laws of the United States may not offer the same level of protection as those in the EEA and UK.

We will take necessary measures to ensure that transfers out of your country are adequately protected as required by applicable data protection law. With respect to transfers to third party recipients in countries not providing an adequate level of data protection, we may base the transfer on appropriate safeguards, such as the EU standard contractual clauses adopted by the European Commission, the UK International Data Transfer Agreement or Addendum, or other approved data transfer or certification mechanisms together with binding and enforceable commitments of the recipient. In each instance, we will review the transfer and ensure that any additional technical and organizational measures are put in place to ensure that an adequate level of protection is provided. You are entitled to receive a copy of any documentation showing the suitable safeguards that have been taken by making a request using the contact details provided in the ‘Contact Us’ section above.

II. Lawful Basis

We collect, use, and disclose your personal information only where we have a legal basis to do so. By reference to the purposes set out under ‘How We Use Your Information’ above, our legal bases are the following:

Purpose

Legal Basis

Transactional Purposes

Performance of our Terms of Use

Communication and Support

Performance of our Terms of Use


Legitimate interest in responding to your inquiries in order to support and improve our Services

Administration

Legitimate interests in (i) taking steps to secure the Site and Services; (ii) protecting our rights by enforcing our Terms of Use

Analytics

Legitimate interest in understanding how our Site and Services are used in order to make improvements


Consent (for the placement of non-essential cookies and the subsequent use of non-essential cookie data for analytics or marketing purposes)

Restructuring or Dissolution

Legitimate interest in undertaking a restructuring of our charitable activities, or dissolution of the Allies in Arts organization


Compliance with legal obligation in relation to any court-mandated insolvency process

Legal Compliance

Compliance with a legal obligation

Other Operational and Business Purposes

Legitimate interest in ensuring the efficient management of our business

Where we refer to ‘legitimate interests’ as the legal basis, we take steps to ensure that our interests are not overridden by your interests, rights, or freedoms. 

III. Electronic Marketing

We will obtain prior consent to send you electronic direct marketing by email, SMS or direct message, except where we collect your contact details in the course of selling you a Service, in which case we may instead give you the option to opt-out of direct marketing, as permitted by applicable law.  

Where you currently receive direct marketing of any kind you can opt-out at any time by following the instructions in the marketing communication or by contacting us at privacy@alliesinarts.org.  

IV. Data Retention

We retain your personal information for as long as required to satisfy the purpose for which it was collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary to comply with legal obligations (such as fiscal or legal obligations) or to defend a legal claim. If you would like to receive further information on how long we store your personal information, please contact us using the contact details provided in the ‘Contact Us’ section and specify your request.

V. Your Rights

Subject to the conditions set forth in the applicable law of your jurisdiction, you have the right to access, right to rectification, right to erasure, right to restrict data processing, right to object against profiling and processing, right to lodge a complaint with your local supervisory authority and your right to data portability, as well as the right to withdraw consent.

Right to access personal information 

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information 

You have a right to request that we rectify inaccurate personal information or complete it. We may seek to verify the accuracy of the personal information before rectifying it. 

You can also request that we erase your personal information in limited circumstances where:

  • it is no longer needed for the purposes for which it was collected;

  • you have withdrawn your consent (where the data processing was based on consent);

  • following a successful right to object (see right to object);

  • it has been processed unlawfully; or

  • to comply with a legal obligation to which the company is subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary: 

  • for compliance with a legal obligation; or

  • for the establishment, exercise or defense of legal claims;

Right to restrict the processing of your personal information 

You can ask us to restrict your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy;

  • the processing is unlawful, but you do not want it erased;

  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

  • we have your consent;

  • to establish, exercise or defend legal claims; or

  • to protect the rights of another natural or legal person. 

Right to data portability

You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

  • the processing is based on your consent or on the performance of a contract with you; and

  • the processing is carried out by automated means. 

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. 

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. 

Right to object to using your personal information for direct marketing purposes

You can require that we stop using your personal information for marketing purposes.

Right to withdraw consent

You may withdraw consent (where such consent was obtained and relied on as the legal basis) for future processing of your personal information.

If you have any questions or if you wish to exercise one of your rights under applicable local privacy laws or submit any objections regarding the processing of your personal information, please contact privacy@alliesinarts.org and specify your request.  Please note that we may need to request additional information from you to confirm your identity, and we may extend the time taken to respond to your request if it is complex, or levy a fee, or refuse to comply with a request, if it is manifestly unfounded or excessive.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority in the country where you live or work or where you believe your rights have been infringed, if you have concerns about how we are processing your personal information or if you believe that your data protection rights have been violated.  The name and contact details of the European Union Supervisory Authorities are available at the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.  

If you have any questions about our data privacy practices, you can contact us at privacy@alliesinarts.org or at PO Box 39875, Los Angeles, California 90039.