Privacy Policy

Use of our Sites and our Services, may result in the collection of information from you (Your Information). Personal Data is a subset of Your Information, and refers to information that identifies, or can be used to identify you, such as your full name, account registration information, phone number, mailing address, and email address. Personal Information also includes your gender, birth date, and emergency contact details to the extent the emergency contact details identify another individual.

 

Your Information can be collected directly from you or from third parties we collaborate with in providing the Services. Your Information may be collected automatically through your use of our Sites or Services. Your Information may be combined or aggregated with information obtained via other sources, unless otherwise prohibited by this Policy.

 

A. Information You Provide Directly to Us

 

Generally

We may receive and collect Your Information as follows:

 

• When you register for or otherwise participate in our Services;

• When you register or apply for program membership

• When you apply for a scholarship or other financial assistance;

• When you make a reservation either by phone, in-person, or through our Sites;

• When you submit a required form or answers to one of our surveys;

• When you apply for employment or to volunteer;

• When you participate in promotions or sweepstakes sponsored by the Tengu Center;

• When you sign up for email offerings or marketing materials;

• When you make a purchase at the Tengu Center;

• When you visit the Tengu Center; or

• When you interact with our customer or guest services or contact us with other inquiries through e-mail, phone, or other means of communication.

 

Program Evaluation and Research Information Provided Voluntarily

 

When you participate in a program from our standard catalog offerings, or as part of a private group (Program), you may be asked to submit Your Information via evaluation materials, surveys, questionnaires, and other pre- and post-Program forms and research tools. We may use Monday or SurveyMonkey, Inc. (SurveyMonkey) to collect certain survey and questionnaire data. Data collected via these tools is subject to the their Privacy Policy;

 

Third Party Research Partners, Guest Faculty and Other Third-Party Collaborators

 

Often, we collaborate with certain third parties in providing the Programs or engaging in Program-related activities or certain product promotions when aligned with the Tengu Center’s mission. These third parties include guest faculty and speakers, collaboration partners, and other practitioners, and the Third-Party Research Partners described below (Our Collaborators). In some cases, you may be asked by Our Collaborators to share Your Information directly with them; and in all such cases, Our Collaborators are required to provide you with written notification of their own privacy and security practices vis-à-vis such information. When Our Collaborators pass along Your Information to us, the Tengu Center will handle it in accordance with this Policy, irrespective of the separate terms provided by Our Collaborators.

 

From time to time, the Tengu Center, on its own, and/or in collaboration with certain qualified third-party research and medical organizations (Third-Party Research Partners), may engage in research studies in connection with a Program (Research Studies). Research Studies often involve the voluntary submission of Your Information via electronic and other questionnaires (Study Questionnaires) directly to the Third-Party Research Partners. These Study Questionnaires are different from the general questionnaires or surveys sent by the Tengu Center. the Tengu Center is not responsible for the privacy policies and practices of Our Collaborators or Third-Party Research Partners and you should please read and confirm your understanding of their respective privacy policies before you submit information directly to them.

 

For clarity, in cases where the Tengu Center shares Your Information with Our Collaborators, Our Collaborators are obligated to comply with this Policy in the treatment and use of Your Information.

 

Financial Information (Non-Donor)

 

Billing and other financial information (such as your credit card number or bank account number when combined with your billing address, and referred to collectively as Financial Information) will be required to register for certain Programs, book a visit to the Tengu Center or related to other transactions, such as purchases made through the Tengu Center Shop. Tokenized information – which the Tengu Center does receive – is not Financial Information for purposes of this Policy because the Tengu Center cannot access bank or card numbers via the token. All reservations and bookings (whether online, in-person, or over the telephone) are made and processed directly through a fully-integrated third-party solution unless otherwise noted.

 

The Tengu Center does not enter or store any Financial Information in its computers, networks, facilities, online database, or files, although tokens do reside on our systems until all transactions with you have been finalized.  We do not review your Financial Information if you engage in a payment transaction, although we do know the amount that is charged to your credit card or debited from your bank account in any such transaction.  We may also receive your billing address. 

 

Information Voluntarily Submitted For Scholarship or Other Financial Assistance

 

Additional information may be requested as part of an application for a scholarship or other financial assistance.  Required details generally include your income level, the name of your employer (if any), demographic information, and other information necessary for the Tengu Center to process your request for financial assistance.  Applicants are invited to provide additional information relevant to their applications. the Tengu Center solicits this information via a Tengu Center-created form, hosted by Google Forms, and the information you provide in these cases will be subject to the privacy and other terms of use posted at www.google.com.

 

Testimonials, Stories, Information Shared via Social Media

 

You may submit testimonials to us directly or via Program evaluations, and are also invited to tag the Tengu Center in social media postings. Information submitted or shared in this manner is subject to the terms of this Policy.

 

B. Information Collected Automatically

 

Meta Data

 

Certain information may be gathered automatically through a variety of mechanisms, including non-identifying information, an IP address, referring URL, browser, operating system, cookie information, and Internet Service Provider (Meta Data). Generally, this kind of information on its own cannot be used to identify you.

 

The Tengu Center does not use automatic means to collect Personal Data, but we may associate Meta Data with Personal Data you or someone authorized by you has provided to us. Whenever we associate Meta Data with your Personal Data, it will be treated as Personal Data.

 

Information Obtained from Other Sources

 

We may obtain information about you from other sources. For example, we may receive background information in connection with an employment application; or via an email list purchased from or otherwise shared by a third party. Once information is received by the Tengu Center, we will treat it in accordance with this Policy.

 

Internet-Based Third-Party Advertising and Do Not Track Technology

 

Our Sites and certain Services use third-party advertising companies, which sometimes utilize third-party services for data collection and analytics.  These companies may use information about your visits to our Sites and to other websites in order to provide advertisements about products and services which may interest you. In so doing, we or these third parties may use cookies or other technologies for the purpose of collecting certain information about you. This may include your server activity logging, browser cookies, web beacons, and embedded scripts.

 

We use this information for our own marketing purposes, including but not limited to informing, optimizing and serving ads to you online when you are browsing other websites. We use a variety of third-party services to collect and track this information. Each service has its own policy for handling Do Not Track signals and methods for opting-out of the collection of information for these purposes. By using the Sites and Services, you consent to potentially encountering third-party tracking technologies and you understand and agree that our statements under this Policy do not apply to the tracking technologies or practices of such third parties.

 

For more information on internet based-advertising, including options for opting-out, the Network Advertising Initiative has created a website, which you can access here https://www.networkadvertising.org/.

 

Third-Party Sites and Social Media Plug-Ins

 

When you click on links on our Sites that take you to third-party websites, you will be subject to the privacy practices of the operator of the third-party website. We encourage you to read the posted privacy statement on those sites (if any). We are not responsible for the privacy practices and policies of these or any other third-party websites and/or social medial plug-ins.

 

We use social media buttons or plug-ins on our Sites, for example for Facebook, Twitter, Instagram, and Pinterest. If you click on one of these buttons, your browser connects directly to the web servers of the associated social media network(s). If you are registered and logged into your account(s) on the(se) network(s), the network will receive and may store information about your use of our Sites. Even if you are not registered with the social media network or you are logged out when you visit our Sites, your IP address may be transmitted to and stored by these organizations. If you interact with our Sites through a social media network, then you may be permitting us to have access to information from your profile (such as your name, e-mail address, photo, gender, location, and the people/sites you follow). Each network has its own privacy policy. If you do not want the network to collect information about you or to share it with us, you must review the privacy policy on the network’s website and take the steps described there. In addition, you should log out of the relevant network before you visit our Sites.

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.  

 

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

 

A. Used for Purpose Submitted

 

Other than as provided for in this Policy, we generally use Your Information for the purpose for which it was submitted. For example:

 

• If you provide Your Information as part of an employment application, we will use it to process your application and communicate with you about the same;

• If you provide Your Information to register for a Program or other visit to the Tengu Center, we will use Your Information to process the registration;

• If you apply for a scholarship or other financial assistance, we will use it to evaluate and process your application, and if you’ve provided permission, we may also share certain details with relevant individuals or organizations who funded the scholarship or other financial assistance. 

• In addition, if you’ve provided permission, we may include your story in Tengu Center-generated media and publications; or

• If you request materials and Services, we will use Your Information to respond to and process your request, and may also add you to our database in order to provide you with additional materials and information in the future.

We also share or transfer Your Information as directed or authorized to do so by you or where you consent to such disclosure. We may aggregate Your Information with the information of other individuals in order to analyze and compare information as between users of our Sites and Services.

 

Other general uses include:

 

• To communicate with you generally about our Sites, Programs and Services;

• To solicit feedback about the Programs;

• To facilitate your participation in events conducted by Our Collaborators or to otherwise make you aware of Our Collaborators’ products and services;

• To facilitate contact from Third-Party Research Partners who may request your voluntary participation in a Research Study as part of a Program; and

• To communicate with you about our giving and donor opportunities.

 

The foregoing are just a few examples of certain uses tied to the nature of your interactions with us.

 

B. Other Uses

 

Research Studies

 

Research Studies may be performed by the Tengu Center on its own, by a Third-Party Research Partner, or as a collaboration between us and a Third-Party Research Partner. The information you provide in connection with a Research Study will be shared between the Tengu Center and its Third-Party Research Partners in order to research and evaluate data and feedback from Program participants and other resources. Specific to Programs (such as RISE™) where research is performed by Third-Party Research Partners and/or other of Our Collaborators, you may be asked to voluntarily provide information directly to the Third-Party Research Partners, which will then be shared by the Third-Party Research Partners with us. Study Questionnaires (if any) and related Program surveys will be sent to you from the Third-Party Research Partner and are distinct from the Tengu Center’s general surveys provided to all of our Program participants.

 

The Third-Party Research Partner will aggregate the information it collects via the Study Questionnaires and other materials you have provided, and will perform an analysis, which it will share with the rest of the research team in aggregate form, including its own Institutional Review Board, affiliates and others. Submission of information directly to a Third-Party Research Partner is always voluntary.

 

Programs & Our Collaborators

 

When you attend an onsite research and/or live or online training Program, we may use and share Your Information as follows: typically, we will only disclose or share aggregate, anonymous, or de-identified information for research, compliance, marketing, advertising, or other purposes. We may, however, publicize direct quotes or testimonials from responses to a survey or evaluation; provided, however, that we will not disclose the participant’s name associated with the quote without that participant’s express, prior permission.

 

Further, we may also disclose Your Information to Our Collaborators and Third-Party Research Partners. For instance, we may share Your Information to permit Our Collaborators to communicate with you, provide you with materials relevant to a Program, present the Program, or otherwise facilitate your registration in a Program to be provided by these third parties.

 

Third-Party Marketing Activities

 

You may be presented with opportunities to receive information and/or marketing offers directly from third parties, including in some cases, Our Collaborators. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly. Where information about you is voluntarily disclosed by you to third parties, all information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them.

 

Third-Party Service Providers

 

We may use third-party vendors, consultants, and other service providers to perform certain services on behalf of the Tengu Center, such as hosting the Sites, hosting and processing Your Information and Meta Data, designing and/or operating features of the Sites and Services, performing analytic services that allow us to enhance the information we present to you either now or in the future, facilitating the delivery of our Services, or performing other administrative and operational tasks. We may provide these vendors with access to Your Information, including Personal Data, to carry out the services they are performing on our behalf, and in some cases, you will be required to submit information directly to these third parties.

 

We expect all of our third-party service providers to comply with federal and state laws regarding consumer privacy and data protection.

 

Furthermore, we may also provide our partners (and other third-party partners who might benefit from the information) with aggregated de-identified data (i.e., compiled data that does not in itself identify you) for research and commercial purposes.

 

Promotional and Marketing Activities; Recordings

 

At times, we may take photographs and/or make audio and video recordings of guests to promote the benefits of participating in our Programs and Services. If you elect to participate in such activities, you will be required to complete a release form which addresses permissions and other rules related to use of photographs and other recordings made by the Tengu Center.  In addition, the Tengu Center may use testimonial statements provided to us via an evaluation form or otherwise, as well as statements, photos, quotations and other information you share via a Tengu Center social media account (including where you have tagged the Tengu Center in your own social media posts), for general marketing and promotional purposes.  This use may include reference to your social media name/account. 

 

 

Release of Your Information for Legal Purposes

 

We may access, use, preserve, transfer, and disclose Your Information (including Personal Data), including disclosure to third parties, to the fullest extent permitted by applicable law: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Sites’ Terms of Use or other policies applicable to the Sites or Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, to the fullest extent permitted by applicable law, we may use IP address or other device identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, Internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you if permitted by applicable law.

 

Meta Data

We use this information in the aggregate (combined with similar information collected from other individuals who are using our Sites and Services) to help us analyze, maintain, and improve our Sites and Services, to monitor the online usage of our Sites and Services, assess our Sites’ performance, ensure technological compatibility with your computer, and understand the relative importance of the information provided about our Sites and Services. We may also use this data to conduct statistical analyses on usage patterns, trends and other aggregated data.

As a general matter, the Sites are not intended for use by children. We do not knowingly collect any Personal Data from children younger than the age of thirteen (13) through our Sites. We will endeavor to delete any Personal Data collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personal Data to us, please contact us at contact@thetengucenter.org.

 

Notwithstanding the foregoing, we may collect Personal Data (such as date of birth and gender) from children under thirteen (13) in-person when they visit the Tengu Center. In such cases, we will provide the applicable policies and procedures at that time.

The provisions in this section apply to you if you have or will donate to the Tengu Center, making you a Donor. Other sections of this Policy will continue to apply to you in your capacity as a user of our Sites and Services, or a guest at the Tengu Center.

 

We may have a Donor’s name and associated information, including Personal Data (Donor Information) because the Donor provided it directly, or because it was obtained through a referral from a Trustee, Board member or other affiliate of the Tengu Center, or otherwise obtained via our standard development activities.

 

If a Donor seeks to honor someone, or donate in someone’s memory, we will also request information pertaining to the honoree or individual being memorialized, which may include the names of individuals related to such people. the Tengu Center will not share these gift amounts with anyone outside of the Tengu Center (unless legally required to do so), and will otherwise use the Donor Information as specified in this Section.

 

Donor Financial Information Submission

 

Donors who use the online portal available on a Site, are prompted to submit Donor Information, as well as Donor Financial Information. Donor Financial Information submitted online is processed by GiveButter.com and will be subject to their privacy policy.

The Tengu Center will not receive Donor Financial Information from GiveButter but is provided with your name, your donation amount, and other details you voluntarily enter such as your address.

 

In cases where you submit Donor Financial Information in an “off-line” manner (via mail, or provided directly to an individual at the Tengu Center), the Tengu Center manually enters Your Information and Donor Financial Information into its fundraising system (currently GiveButter). Although we retain certain Donor Information, such as your name, address and amount of donation, any Donor Financial Information received by the Tengu Center off-line is destroyed following processing in our systems.

 

Use of Information

 

Every donor has the option to request anonymity when making a gift. Anonymity may pertain to all donations, or may be requested for certain gifts. In certain cases, including those below, where a Donor has not requested anonymity, the Tengu Center may publish your name on a list of donors; or may share your name and mailing address (but not the amount of your gift) to a private party for whom news of your generosity will be personally meaningful (e.g., in memoriam gifts).

 

Some instances or examples of disclosures outside of the Tengu Center include: (i) to acknowledge your generosity as a Donor to the Tengu Center in an annual report, or in reporting on the results of a special campaign. This list may be arranged by bracketed gift amounts, but shall not identify the specific gift amount; (ii) to notify individuals or their family members whom you have recognized with a gift “in honor” or “in memory” as described above; or (iii) to notify the founders of certain designated funds of your generosity.

 

The Tengu Center will honor a request from any Donor to refrain from sharing mailing addresses or gift amounts outside of the Tengu Center, unless the Tengu Center is legally obligated to disclose such information, including in federally required Form 990 filings and other similar circumstances.

 

Donor Information is shared internally to facilitate the Tengu Center’s development efforts. In addition to being accessible to individuals within the development functions, Your Information and the Donor Financial Information (to the extent housed in the Tengu Center’s systems) may be shared with Trustees, Board members and other senior staff members. The sharing may be done via email, oral communications, or in written reports, and we are unable to honor requests for anonymity with respect to these internal sharing practices.

 

Although the Tengu Center reserves the right to retain information as needed to comply with legal and regulatory obligations, you may opt-out of other uses as specified in Section below.

A. How You May Access and Manage Your Information and How to Opt-Out

 

We want to provide you with meaningful choices regarding managing Your Information and the communications you receive from us, and you may choose to limit or opt-out of certain promotional/marketing communications and/or how and with whom we share Your Information. If you choose to opt-out of promotional/marketing communications, please note this will correspondingly result in automatically opting-out of any surveys we may send to evaluate your stay and any Programs you may have attended. In addition to responding to the provided link in our electronic communications, you may email contact@thetengucenter.org to opt-out or otherwise change your communication preferences (including being added to the “do not contact” list).

 

You may still receive administrative communications from us, such as order confirmations, notifications about your account activities (e.g., account confirmations, password changes, etc.), products or services you have requested, and other important announcements, and you may receive direct mail from us.

 

B. How to Contact Us About Our Privacy Policy

 

Should you have any questions or comments concerning our Policy you may e-mail us at contact@thetengucenter.org.

 

C. We Reserve the Right to Contact You

 

The Tengu Center reserves the right, but is under no obligation, to contact you for any reason regarding, related to, or arising from, the Services, Sites, your account or subscription, this Policy, the Terms of Use, or any other policies or agreements relevant to you. Our primary method of communication is email.

 

D. Your California Privacy Rights

 

Under California law, California residents who have an established business relationship with us may choose to opt-out of our disclosure of Personal Data about them to third parties for direct marketing purposes. Unless noted in this Privacy Policy, our policy is not to disclose Personal Data collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, please contact us by email contact@thetengucenter.org.

 

E. Transfer or Sale as Part of a Business Transaction

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In the event the Tengu Center goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Data might be among the assets sold or transferred and you hereby consent to such sale, transfer or assignment.

 

F. Governing Law

 

We, and our servers, are located in the United States and are subject to the applicable U.S. local and national laws. When you choose to use our Sites and Services, you do so on your own initiative and understanding that your use of the Sites and Services and our use of Your Information is subject to U.S. laws and regulations. If you choose to use our Sites and Services, you consent to the use and disclosure of information in accordance with this Policy and subject to such laws, including the transfer of your Personal Data to servers located in the United States.

 

G. Changes to this Policy

 

This Policy was last revised on the below date. Any changes to the Policy will be made through updates to the Policy and posted on our Sites, with a new effective date. Unless we clearly indicate otherwise, we will use information in accordance with the Policy under which the information was collected.

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Last Updated Date: January 9, 2024