Lester's Feet Foundation

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, and we are responsible as "controller" of that personal information for the purposes of those laws.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Lester's Feet Foundation
You, client	You and each member of your family about which information is disclosed to us.
Personal information	Any information relating to an identified or identifiable individual.

2. Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Legal name, any aliases, home address, email, phone number.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual	Signature, social security number, driver's license number, physical characteristics or description, insurance policy number, education, employment, employment history, bank account number, business account numbers, loan numbers, or any other financial information, medical information, or health insurance information.
Commercial/Public information	E.g., records of real property, records of vehicle title and driving record, credit report information.
Inferences drawn from any of the information identified above	Used to create a profile about you or your family in order to determine qualification for assistance from us.

This personal information is required to provide assistance to you. If you do not provide personal information we ask for, it may delay or prevent us from providing assistance to you.

3. How Your Personal Information is Collected

We collect most of this personal information directly from you — in person, by telephone, text or email and/or via our website and apps. However, with your permission, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., medical providers, therapists, schools, lenders, banks, credit reporting agencies or background check and due diligence providers).

4. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so. Proper reasons include:

To comply with our legal and regulatory obligations;
To evaluate your application for assistance from us;
To perform our grant of assistance to you or to take steps at your request before awarding assistance;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for, and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our grant to you or to take steps at your request before approving aid to you.
To prevent and detect fraud against you or Lester's Feet Foundation	For our legitimate interests, i.e. to minimize fraud that could be damaging for us and for you.
Conducting checks to identify our clients and verify their identity	To comply with our legal and regulatory obligations.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you.
Ensuring the confidentiality of sensitive information	For our legitimate interests or those of a third party, i.e. to protect your personal identifying information and to comply with our legal and regulatory obligations.
Preventing unauthorized access and modifications to systems	For our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for us and for you, and to comply with our legal and regulatory obligations.
Credit reference checks via external credit reference agencies	For our legitimate interests, e.g. to ensure our recipients qualify for the aid they receive from us.

5. Communications

We may use your personal information to send you updates (by email, text message, telephone or U.S. Mail) about our mission and services. We have a legitimate interest in your personal information for this purpose. This means we do not usually need your consent to send you communications; however, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell OR share it with other organizations for marketing purposes.

You have the right to opt out of receiving communications from us at any time by:

Contacting us at support@lestersfeetfoundation.org; or
Using the "unsubscribe" link in emails or "STOP" number in texts.

We may ask you to confirm or update your communications preferences if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

Depending on the specifics of the assistance you receive from us, we may share your personal information with:

Service providers we use to help deliver our services to you;
Other third parties we use to help us run our business, such as website hosts;
Third parties approved by you, such as may be necessary for us to evaluate your application for assistance from us;
Credit reporting agencies;
Our insurers;
Our bank(s);
Our Board of Directors.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors and other legal and accounting professionals providing services to us.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We will NOT share your personal information with any other third party without your consent.

7. Where Your Personal Information is Held

Information may be held at our offices and service providers, representatives and agents as described above (see above: "Who We Share Your Personal Information with").

8. How Long Your Personal Information Will Be Kept

We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

9. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Your Rights Under the CCPA

If you reside in California, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended, to receive information:

Disclosure of Personal Information We Collect About You

You have the right to know:

The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you.

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide the personal information to you more than twice in a 12-month period.

Personal Information Used for a Business Purpose

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we shared and the categories of third parties to whom the personal information was shared; and
The categories of personal information that we disclosed about you for a business purpose.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform an agreement between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Comply with the California Electronic Communications Privacy Act;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

11. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Call us at 765-400-2178; or
Email/write to us at support@lestersfeetfoundation.org.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email/phone/in writing, you will need to provide us with:

Enough information to identify you;
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

You have the right to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information. Keep in mind that opting-out may negatively affect the assistance and services that we provide to you.

12. Changes to This Privacy Notice

This privacy notice was published on May 1, 2023.

We may change this privacy notice from time to time. When we do, we will inform you via our website or other means of contact such as email if you are in our system.

13. How to Contact Us

Please contact us by U.S. Mail, email or telephone if you have any questions about this privacy policy or the information we hold about you.

PO Box 250, Dry Ridge, KY 41035

support@lestersfeetfoundation.org

765-400-2178

Privacy Policy