Privacy Policy

IIT Madras Foundation Privacy Policy

We collect your contact personal information, unique identifiers, preference information, publicly available personal information and information relating to your use of our website or information provided offline to IITM Foundation as donors or patrons. We use your personal information for various purposes, such as to send you information related to our activities, such as fund raising, soliciting donations, and surveys. We may share your personal information with service providers to the extent necessary to enable their performance.

Please let us know if you do not want certain information to be used for specific purposes. You may contact us to correct, update, amend or request deletion of your personal information at (email/address/fax/phone). You may also turn off cookies in your browser.

Scope

The IITM Foundation (“IITMF”, “we”, “our”), including any affiliates and/or parent company, values the trust that you place in us to appropriately use and protect your information. As an example, IITMF considers IIT Madras and IIT MAANA (IIT Madras Alumni Association of North America) as affiliate organizations. This Privacy Policy describes how IITMF collects and uses personal information about you when you visit www.iitmfoundation.org, including the following subdomains (if any) or when you provide us the information offline. By using this IITMF website or by providing us your information offline, you accept the privacy practices contained in this Privacy Policy.

Nature of Personal Information Collected Online or Offline

We may collect the following personal information about you when you visit the IITMF website or when you provide us your information offline:

• Contact information, such as your name, home or other physical address, email, telephone number, fax number, organization name, and/or job title when you submit a contact form or make a donation.
• Unique identifiers and preference information such as your username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, your navigation from actions that you take on our website.
• Information about you that you share or make visible on the Internet.

Methods of Collection of Personal Information Online or Offline

Personal information about you may be collected in the following manner:

• We may require personal information directly from you.
• We may collect information about you from affiliates, subsidiaries, business partners, ad networks, and other third parties.
• We may collect personally identifiable information such as contact information (e.g., name, address, telephone number and e-mail address), demographic information (e.g., zip code, organization and/or role), billing information (e.g., credit or debit card numbers), or sensitive information (e.g., bank information), during the course of your interaction with IITMF.
• We may collect contact and demographic information during surveys and questionnaires.
• We may use various technologies to collect personal information, store content information and preferences, about visitors to the IITMF website, including without limitation, web logging, cookies, beacons, tags and scripts. We may receive reports based on the use of these technologies by external agencies on an individual as well as aggregated basis.
• We may place a text file called a “cookie” in the browser files of your computer, for record keeping purposes and to deliver content specific to your interests. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
• We may collect anonymous data known as “click stream data” from visits to the IITMF website.
• We may partner with third parties to manage our advertising on other external websites. Our third party partner(s) may use cookies and other technologies to gather information about your activities on the IITMF website and other websites in order to provide you advertising based upon your browsing activities and interests.
• We may use framing techniques to serve content to/from our partners, in which case, you would be providing personal information to these third parties and not directly to IITMF.
• We may collect your name and email address for subscription to our newsletter(s), periodic email(s).
• We may obtain your contact information via general email solicitations or through solicitation lists at our events or other events which IITMF may partner with.

Use and Disclosure of Personal Information Collected Online or Offline

We may use the information collected for the following purposes:

• To solicit donations.
• To invite you to IITMF events.
• To improve the content, diagnose problems with our server, to administer the IITMF website.
• To gather demographic information about our user base/database as a whole.
• To communicate with you, respond to your inquiries, to send you newsletter(s).
• To provide the information you or your organization have requested, and
• To conduct surveys and research: Participation in these surveys or contests (which may be conducted by third party service providers) is completely voluntary and you therefore have a choice whether or not to disclose information. We will not share the personal information you provide through a contest or survey with third parties unless we give prior notice and choice.

IITMF does not sell, trade or share donor information collected online or offline to third parties. We will retain and use your personal information only as necessary with notice to you to comply with legal obligations, resolve disputes and enforce agreements.

We may disclose your personal information for the following purposes:

• To third parties that provide services to help us with our business activities, only as necessary to provide these services to us with notice to the donor,
• As required by law, and when we believe in good faith that disclosure is necessary to protect our rights, investigate fraud or respond to government requests.
• To third parties which are not associated with IITMF’s business activities with notice and consent of the donor.

Opt-out

You may opt-out of certain uses of your personal information by sending us written communication indicating your decision to opt-out. Opting-out may affect the manner in which we provide our communication or information to you.
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing email preferences in your account or by contacting us at (address, phone, fax and email).
We may, at our sole discretion, from time to time and when legally required, describe how your personal information will be used and may provide you the option to opt-out of such use. You can notify us of your preferences during the information collection process or by contacting us.

Protection of Your Information

We use reasonable and appropriate physical, technical and administrative industry safeguards to protect information from unauthorized access, use, loss, misuse or unauthorized alteration. Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances.

Seals, Buttons and Content from Other Companies

IITMF website may include seals, buttons and content links to other websites (for example, Facebook, LinkedIn, Twitter, YouTube, Google+). When you use a link to go from www. iitmfoundation.org to another website, our Privacy Policy is no longer in effect and we are not responsible for the use or protection of your personal information by such third parties. Please read the privacy notice of each website you visit.

Changes to this Privacy Policy

This Privacy Policy may be periodically updated, with or without notice. We will not apply changes to this Privacy Policy retroactively to personal information we have previously collected. We encourage you to review this Privacy Policy each time you visit the website or provide us your information offline.

Contact Information

If you have questions or concerns about this Privacy Policy or any other aspect of privacy and security of your personal information, please contact us at:
Email: sunil@iitmfoundation.org
Regular mail:
Attn: Andrea Monaghan
19925 Stevens Creek Boulevard, Suite #100, Cupertino, CA 95014
Phone: 1-408-657-0383
We will respond to your request within thirty (30) days.

Equal Opportunity Employer

The IITM Foundation is committed to supporting its work and the communities in which it operates through maintaining a diverse workforce at all levels of The IITM Foundation, and through the recognition, acceptance and valuing of individual differences. Towards this end, The IITM Foundation is an Equal Opportunity Employer (EOE), adhering to the U.S. laws that prohibit discrimination in the terms and conditions of employment. The IITM Foundation EOE policy, as detailed herein, provides equal employment opportunities to all qualified persons without regard to race, creed, color, religion, national origin, ancestry, alienage or citizenship status, age, disability or handicap (including HIV/AIDS), sex, marital status, familial status, veteran status, sexual orientation, genetic information or any other characteristic protected by applicable federal, state or local laws. As a result, The IITM Foundation adheres to an Affirmative Action Plan.

Equal opportunity and equal consideration will be afforded in all personnel actions involving applicants and employees, including recruiting and hiring, selection for training, placement, promotion, rates of pay or other compensation, transfer and layoff, or termination.

Reasonable Accommodation

In accordance with applicable laws including the Americans with Disabilities Act (ADA) the Americans with Disabilities Amendments Act (ADAA) and the regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC) to ensure equal employment opportunities to qualified individuals with disabilities, The IITM Foundation will endeavor to make reasonable accommodations for the known physical or mental disabilities of an otherwise qualified employee to enable the employee to perform the essential functions of his or her position unless the accommodation would impose an undue hardship on The IITM Foundation’s operations. If you believe you need reasonable accommodation, please speak with the President, or Chairman, or any Board Member. You may be required to provide medical documentation substantiating the reasons for the requested accommodation and the nature of the accommodation sought.

Executive Compensation Policy

This policy has been drafted to comply with the revised Form 990, Part VI, Section B, question 15.

I. Purpose:

A. To assure that possible future decisions regarding executive compensation are made through a process free of potential conflicts of interest.

II. Notes:

At this time, The IITM Foundation operates primarily with unpaid volunteers including a volunteer President who serves as the top management official role. This policy is included to address the revised 990 form, as well as to fulfill requirements with Charity Navigator, which requires that this policy be on file, even if the organization’s top management official is uncompensated. The following policy would only apply if The IITM Foundation hires a compensated top management Official.

III. Persons whose compensation is subject to this policy:

A. The compensation of an Executive Director, Chief Executive Officer, or top management official, where applicable, shall be reviewed under this policy.

IV. Body empowered to evaluate executive compensation:

A. The Board of Directors or a duly authorized subcommittee of the board will evaluate executive compensation. Authorized subcommittees may include the Governance and Nominations Committee, the Operations & Finance committee, an Executive Search Committee, or other committees authorized by the Board.

B. Only those members of the Board of Directors who are free of conflicts of interest may be involved in evaluation of executive compensation.

C. The Board of Directors or Committee should, to the extent reasonably available, rely upon appropriate data as to comparability prior to making its decision, and shall contemporaneously place such data and other reasons for its decision in the minutes.

D. If the Board of Directors or Committee does not have data as to comparability, it shall document any other bases for believing the proposed compensation is reasonable.

E. The Board of Directors or Committee shall make this determination at the time of hiring and at least once every two years or at the time of a 10% or greater increase in compensation.

Whistleblower Policy

General

The IITM Foundation requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
Reporting Responsibility
It is the responsibility of all directors, officers and employees to exercise ethical conduct and to report violations or suspected violations in accordance with the Whistleblower Policy.

No Retaliation

No director, officer or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the organization.

Reporting Violations

The IITM Foundation has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with a Board member or anyone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of law and ethics to the President, who has specific and exclusive responsibility to investigate all reported violations.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law or organization’s ethics. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Conflict of Interest Policy

This Conflict of Interest Policy governs the activities of the Board, Officers and Executive Committee, Committee Chairs, Regional leaders and staff of The IITM Foundation (hereafter referred to as “Responsible Person”). It is the responsibility of all Responsible Persons to be aware of this policy, and to identify conflicts of interest and situations that may result in the appearance of a conflict and to disclose those situations/conflicts/or potential conflicts to the President or the Chairperson of The IITM Foundation, as appropriate. Questions about the policy should be directed to the Corporate Secretary of The IITM Foundation.

Defining a conflict of interest:

A conflict of interest arises when a board member or staff member has a personal or professional interest that is potentially at odds with the best interests of The IITM Foundation, resulting in inappropriate financial gain to persons in authority at The IITM Foundation or even the appearance of a lack of integrity in The IITM Foundation’s decision‐making process. Potential conflict of interest situations include but are not limited to the following:

• A Responsible Person or the family members of a Responsible Person directly or indirectly benefits financially or non‐financially as a result of a decision, policy or transaction made by The IITM Foundation.
• A Responsible Person accepts a gift or another favor in circumstances where it might be inferred that such action was intended to possibly influence him/her in the performance of his/her duties.
• A Responsible Person seeks to obtain preferential treatment by The IITM Foundation.
• A Responsible Person seeks to make use of confidential information obtained from The IITM Foundation for his/her own benefit (not necessarily financial) or for the benefit of his/her family or associates.
• A Responsible Person uses information about The IITM Foundation’s donors or contacts the donors for his/her own financial benefit or for the financial benefit of his/her family or associates.
  In general, The IITM Foundation takes a broad view of conflicts of interest and board/staff are urged to think of how a situation or transaction would appear to outside parties when identifying conflicts or possible conflicts of interest.

Disclosure of Conflicts:

A Responsible Person is under a continuing obligation to disclose any potential conflict of interest as soon as it is known or reasonably should be known. In addition, he/she will annually identify through an Annual Disclosure Form any interests that could give rise to conflicts of interest. In general, employees should disclose to their supervisor, and Board members, Officers and Committee members should disclose to the President of The IITM Foundation.

Procedures to review conflicts:

For each interest disclosed, the full Board or the Executive Committee, as appropriate, will determine whether a conflict of interest exists and if yes, the appropriate response. The IITM Foundation will, as far as possible, refrain from taking action while the matter is under review.

Procedures to handle conflicts:

• When the conflict involves a decision‐maker, the person with the conflict (“interested party”): (i) must fully disclose the conflict to all other decision‐makers; (ii) may not be involved in the decision of what action to take (e.g., may not participate in a vote) but may serve as a resource to provide other decision‐makers with needed information. In some cases the person with the conflict may be asked to recuse him/herself from sensitive discussions so as not to unduly influence the discussion of the conflict.
• The fact that a conflict was managed and the outcome will be documented in the minutes of Board or Executive Committee meetings.

Violations of the Conflicts of Interest Policy:

If the Board or Executive Committee has reasonable cause to believe a Responsible Person has failed to disclose actual or possible conflicts of interest, it shall inform him/her of the basis for such belief and provide him/her an opportunity to explain the alleged failure to disclose. If, after hearing the Responsible Person’s response and after making further investigation as warranted by the circumstances, the Board or Executive Committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

Document Retention and Destruction Policy

Certain federal laws prohibit the destruction of certain documents. Not-for-profit organizations should have a written, mandatory document retention and periodic destruction policy. Policies such as this will eliminate accidental or innocent destruction. In addition, it is important for administrative personnel to know the length of time records should be retained to be in compliance.

Document Retention and Destruction

The Document Retention and Destruction Policy identifies the record retention responsibilities of staff, volunteers, members of the board of directors, and outsiders for maintaining and documenting the storage and destruction of the organization’s documents and records.
The organization’s staff, volunteers, members of the board of directors, committee members and outsiders (independent contractors via agreements with them) are required to honor the following rules:

• Electronic documents indicated under the terms for retention in the following section will be maintained on the organizations’ electronic storage system
• Paper documents may be destroyed after scanning into electronic form
• All other electronic documents may be deleted from all individual computers, databases, networks, and back-up storage after one year
• No paper or electronic documents will be destroyed or deleted if pertinent to any ongoing or anticipated government investigation or proceeding or private litigation
• No paper or electronic documents will be destroyed or deleted as required to comply with government auditing standards