Effective Date: September 11, 2023

The Foundation for Middle East Peace, located at 2025 M Street NW, Suite 600, Washington, DC 20036 (“FMEP”, “we”, “us”, or “our”), is a 501(c)(3) tax-exempt private operating foundation founded to ensure a just, secure, and peaceful future for Palestinians and Israelis. 

FMEP is dedicated to protecting your data and maintaining your trust. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. This privacy policy explains how we collect, use, disclose and secure the personal information we gather about you through our website, or when you interact with us online, where the law requires that we disclose this information to you (“Privacy Policy”). 

You should read this Privacy Policy carefully and ensure that you understand it. By accessing, browsing, or otherwise using our website, you confirm that you have read, understood, and agree to the Privacy Policy. If you do not agree, you should not use our website. If you have any questions or concerns about our data privacy policies or practices, you can contact us by the methods described in Section G. 

A. Scope

1. 1. This Privacy Policy: This Privacy Policy applies regardless of how our website is accessed and covers any device by which we make our website available, or that you choose to access our website.
   2. Third-Party Sites:  Our website may contain links to third-party websites. Our Privacy Policy does not apply to third-party websites. If you click on a link to another website, you should read their privacy policy. Please see our Terms and Conditions for more information about third-party links.
   3. What is Personal Data?: Personal Data is data or information that is identified or identifiable with a natural person (“Personal Data”). It may include your name, your email address, your physical address, telephone number, username, or other information that is identifiable to you.
   4. Data We Do Not Collect: We do not collect the following categories of information, and if we ever collect any of the below-listed information, we will seek your consent when we are legally required to do so:
      1. Sensitive Data. Sensitive Data may include information about your racial or ethnic origin, religious or philosophical beliefs, health, sex life or sexual orientation, geolocation, citizenship or immigration status, genetic or biometric data, political opinion, or information concerning trade union membership.
      2. Any Data from Known Children. Our website and services are not directed at children, and we do not knowingly collect any information from children under the age of 16. If you are a parent or guardian and believe that your child has provided us with Personal Data without your consent, please contact us.
   5. Changes to Our Privacy Policy: We regularly review our Privacy Policy and update it as necessary to reflect feedback, changes in our operations, and/or our compliance obligations. We encourage you to periodically review this page for updates.

B. Your Data Rights 

FMEP is committed to the data protection principles of lawfulness, fairness, and transparency. If you, your data, and FMEP are covered by a specific data protection law or regulation, you may have certain rights with respect to your Personal Data. We have provided a summary (“Data Rights”) for your reference: 

1. Right of Access. You may have the right to obtain confirmation about whether we are processing your Personal Data and, if we are, access to a copy of that information.  
2. Right to Correction. If you believe that the Personal Data in our records is inaccurate or incomplete, you may request that we correct any inaccurate or complete any incomplete Personal Data we hold. 
3. Right to Deletion. In certain circumstances where we no longer have a reason to continue processing your Personal Data, you may ask us to delete or remove your Personal Data from our records. This right is sometimes referred to as “the right to be forgotten.” Please note that when we are required to notify our Data Processors of your request, it may take some time for your data to be fully removed.
4. Right to Withdraw Consent. When we are using your Personal Data based on consent, you may have the right to withdraw that consent at any time.  
5. Right to Restrict Processing. In certain circumstances, you may request that we restrict the processing of your data. 
6. Right to Object / Right to Opt-Out. You may have the right to object to processing of your data when it is processed based on our legitimate interests or your consent. 
7. Right to Data Portability. In certain circumstances, you may request that we transfer your Personal Data to you or to another Data Controller. 

Please note that these rights are not absolute and certain exceptions may apply to any requests you send to us. The rights do not apply to all of the data we collect, store, and use, not all individuals who visit our website are covered by an applicable data protection regulation that allows them to exercise these rights.  

C. How FMEP Collects Your Data

1. What We Collect & How We Collect Your Data 
   1. Contact Information. When you submit your personal contact information to us, you provide us with Personal Data. This includes your name, email address, phone number, and other contact information. We collect this information when you sign up for our newsletter, when you request information about us, or when you voluntarily complete a form or survey. 
   2. Analytics Information. When you visit our website, we collect analytics information from you through Cookies (which are described in further detail below). Cookies collect information about your browser, Internet Protocol address, device, and your interactions with our website. This information is collected automatically.  
   3. Other Information. Occasionally, we may send you a survey or questionnaire about our services, or you may choose to reach out to us directly. When you complete a survey or questionnaire or reach out to us directly, you provide us with whatever information you choose to disclose to us, which may be considered Personal Data under certain data security laws and regulations. This information is only collected voluntarily when you choose to share it with us. 
2. Data Use: We use your data for the following purposes:
   1. To provide, update, maintain, and protect our website and business, and to investigate and help detect security interests and abuse. 
   2. To identify usage trends and determine the effect of our email and other campaigns.
   3. To communicate with you. When you sign up for our newsletter, we use your personal information, including your name and email address, to send our newsletter to you. If you reach out to us with a specific request, comment, or question, we may use that information to respond to you. 
   4. To send you Zoom event RSVPs for our events. 
   5. To allow you to subscribe to our podcasts. 
3. Legal Basis: Our collection and processing of your Personal Data is based on the following legal bases:
   1. Consent. We collect and use your Personal Data based on your consent when you first visit our website and accept or reject Cookies, and when you voluntarily submit your Personal Data to us when you sign up for our newsletter, register for an event, or contact us. 
   2. Legitimate Interests. We also collect and use your Personal Data when it is necessary for our legitimate interests related to our organization and mission. For example, as part of Our Mission, we produce weekly reports on Israel and Palestine, settlement in the West Bank, and Middle East-related activity in the U.S. Congress. When you subscribe to these reports, we process your Personal Data, including your name and email address. 
   3. Compliance with a Legal Obligation. We may use the data we collect to comply with our legal obligations. For example, we may have an obligation to preserve your Personal Data if there is a valid request from a government regulator, law enforcement, or court order. 
   4. Exercise of a Defense or Legal Claim. If you bring a claim against us, or we bring a claim against you, we may use the Personal Data we have for our defense or in pursuit of our claim. 
4. Cookies: We send Cookies to your web browser when you visit our website. Cookies are small pieces of data that websites store on a device, that are used to collect information about you and your visits to our website (“Cookies”). Cookies can improve your browsing experience because they help our website remember your preferences to offer you a more personalized experience. They also help us understand how visitors are using our website. For more information about Cookies and what they do, please visit https://allaboutcookies.org/. We use the following types of Cookies:
   1. Strictly Necessary Cookies. These Cookies are essential for you to browse the website and use its features. They also enable our website to provide enhanced functionality and personalization. 
   2. Performance Cookies. These Cookies collect information about how you use our website, like what pages you visit and what links you click on. This information cannot be used to identify you as it is aggregated and anonymized. These Cookies allow us to analyze activities on our website, such as traffic, and may help us improve our functioning. 
   3. Marketing Cookies. These Cookies are set by third parties such as Twitter or Google. These Cookies identify your browser and internet device and are used to build a profile of your interest and show you relevant advertisements on those sites. 
   4. Social Media Cookies. These Cookies allow you to share our content on social media sites such as Facebook or Twitter. They may also track your browser history across other websites and build a profile of your interests, which may provide you with personalized advertisements and messages. 

You can disable Cookies in your browser settings, however, if you do, some of our website features and services may not function properly as a result. 

D. Data Storage & Retention

1. Personal Data: FMEP uses Mailchimp to store and process your personal data that you submit to us. Mailchimp’s servers are located in the United States, and FMEP accesses the data stored on the servers from the United States. Mailchimp’s Standard Terms of Use may be found here:  https://mailchimp.com/legal/terms/ . More information about Mailchimp’s Security Policies can be found here: https://mailchimp.com/about/security/.
2. Cookies: Cookies may be kept on your device for up to two years depending on the type of Cookie. Generally, Cookies fall into one of two categories in terms of data retention:
   1. Session Cookies. These Cookies only operate from the time you visit our website to the end of your browsing session. Once you close your browser, these Cookies are automatically deleted. 
   2. Persistent Cookies. These Cookies stay on your device between browsing sessions. These Cookies usually stay on your browser for one month to two years, depending on the type of Cookie. These Cookies tend to be Strictly Necessary Cookies and Marketing Cookies. You may delete the Cookies that stay on your browser by accessing your browser’s settings, though our website will not remember your preferences if you do. 

E. Disclosure of Personal Data 

1. Service Providers: We may disclose your Personal Data to our contracted service providers so that they may provide us with services. Specifically, we use:
   1.  Mailchimp, which runs our marketing, automation, and email platform for our newsletters and stores our data on its servers.  
   2. Zoom, which we use to send you invitations and host our virtual meetings and webinars.
2. Google Analytics: Users who visit this website may be tracked through Google Analytics. Google Analytics allows us to gain insights into how you engage with our site and helps us improve the functionality of our website. For more information about how Google uses this data, please visit: https://policies.google.com/technologies/partner-sites.
3. We do not Sell Data: FMEP does not sell, rent, or lease any of the Personal Data we collect from any source to third parties.

F. Data Transfer 

Our webservers and hosting services are located in the United States. Personal Data you provide while located in the European Union, the European Economic Area, the United Kingdom, or in another international jurisdiction may be transferred to the United States. If you provide us with Personal Data from outside of the United States, you consent to the transfer of your Personal Data to the United States. When we transfer data from the EU, EEA, UK, or another country with cross-border transfer obligations, Mailchimp’s transfers are done in compliance with safeguards and/or Standard Contractual Clauses. 

G. Exercising Your Data Protection Rights

This section describes how you may exercise your Data Rights (described in Section B, above), when you are entitled to do so. The Data Rights and processes described in this section do not apply generally, and nothing in this section is intended to extend these rights to you, nor act as an admission that FMEP is required to comply with any specific data protection law or regulation. 

If you are unsure if you and/or your Personal Data fall under a specific data protection law, please review the scope of the data privacy laws or consult with an attorney. 

1. Exercising Your Rights:
   1. If you, your data, and FMEP are covered by a specific data protection law or regulation, and you wish to make a request or objection based on one of the rights listed above, please contact us at the contact information located in Section H. We may ask for additional information to verify your identity before we act on your request or objection.
   2. We have at least 30 days to respond to your request or objection from the date we receive it, and we will alert you if we exercise our right to take additional time to process your request. Please note that we may retain a copy of your communications, including your name and contact information, to help us resolve any issues you raise.
2. Appeal
   1. If you, your data, and FMEP are covered by a specific data protection law or regulation, and we refuse to take action with regard to your data privacy rights, we will provide you with a notification and the reason for our refusal. You may be entitled to appeal our decision. If you choose to appeal, please email us at the email address in Section H with “APPEAL” and your first and last name in the subject line.
3. Complaints
   1. If you have any complaints about the way we handle your Personal Data, please contact us so we may resolve the issue.
   2. If you, your data, and FMEP are covered by a specific data protection law or regulation, and you are unsatisfied with our response, or you do not believe that we can assist you with your complaint or concern, you may also have the right to lodge a complaint with a government authority: 
      1. If you are located in the EEA or EU, you may lodge a complaint with the competent Data Protection Authority (“DPA”) for your country. The contact details for the DPAs are listed on the following website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. 
      2. If you are located in the UK, you may lodge a complaint with the Information Commissioner’s Office (ICO) at the following website: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/. 
      3. If you are located in the United States, you may have the right to contact your states’ Attorney General to lodge a complaint if you are concerned about the outcome of your appeal. 

H. How to Contact Us

If you have any questions about our Privacy Policy, or if you would like to exercise one of your data protection rights, please contact us at: 

       2025 M Street NW, Suite 600

       Washington, DC 20036

info@fmep.org

       202-835-3650

I. Disclaimer 

Nothing in this Privacy Policy should be taken as an admission or as evidence that any particular data privacy or information security law or regulation applies to FMEP generally, or in any specific context. This Privacy Policy also does not guarantee complete security of your data, as we cannot reasonably ensure complete security.