ShulCloud Privacy Policy

Last Updated: June 2, 2017

This privacy policy (this “Privacy Policy”) in intended to inform you about how RustyBrick, Inc., a New York limited liability company located at  250 West Nyack Road, Suite 200, West Nyack, NY 10994 (“RustyBrick”, “we”, “our”, or “us”), collects and uses personally identifiable information ("PII") uploaded or otherwise submitted to us through our online, proprietary content management system for synagogues named "ShulCloud™" (the “Service”). 

How does the Service Work?

The Service enables subscribers of the Service who register with RustyBrick ("Subscribers") and/or through their respective synagogue members ("Members") to use the Service's features.   For the sake of clarity, and for purposes of this Privacy Policy, a prospective Subscriber using the Service on a trial basis shall also be deemed to be a "Subscriber" and a prospective Member using the Service on a trial basis shall also be deemed to be a "Member".  .   All references to "you", "your", and "yours" hereunder shall refer to either Subscribers or their Members or to both Subscribers and Members collectively, as applicable; provided, however, that such terms will refer collectively to both Subscribers and Members unless the context of this Privacy Policy indicates otherwise.

By using the Service, each Subscriber consents to the collection and use by RustyBrick (a) of Subscriber PII and the PII of Members, and other information collected from Subscriber and/or from Members, as described in this Privacy Policy, and (b) as described in RustyBrick’s terms of use agreement for the Service which is located at www.shulcloud.com/terms of use (the “Terms of Use”). By using the Service, each Member consents to the collection and use by RustyBrick of (i) Member PII and other information collected from Members as described in this Privacy Policy, and (ii) as described in the Terms of Use.

How can the terms of this Privacy Policy be modified?

We reserve the right to modify this Privacy Policy at any time.  You agree to review this Privacy Policy periodically to be aware of such modifications.  You further agree that your continued use of the Service after any such modifications have been made shall be deemed to be your conclusive acceptance of any modified version of this Privacy Policy.   We will indicate that changes to this Privacy Policy have been made by updating the date indicated after “Last Updated” at the beginning of this Privacy Policy.  We will be happy to provide you with prior versions of this Privacy Policy upon your written request to us. If you do not agree to abide by the initial version or any modified version of this Privacy Policy, then you are not authorized to use the Service.  The current version of this Privacy Policy is accessible via the footer of the Service’s homepage.  

How does the Service work?

The Service consists of a suite of web building tools and calendars and event management and member billing and receivables functionality which enables (a) Subscribers to manage and track various aspects of their synagogue membership online and to interact with collected data of Members using a variety of dynamic features, and (b) Members to track and modify their membership profiles as permitted by Subscribers, and (c) Members to view and pay their bills online or offline as well as to make donations online or offline.  Subscribers and Members may be able to use certain features of the Service without providing any PII to RustyBrick; however, you will need to provide us with certain PII in order to access and use most of the Service's functionality. 

What type of PII does RustyBrick collect from you and how do we use it?

Subscribers and/or Members typically submit various PII of Members to the Service, including without limitation, a Member's name, address, phone number, email address and other biographical information.  Subscribers also provide us with certain of their PII, such as name, address, and credit card information.  

RustyBrick may provide your PII to individuals or entities who work with us or on our behalf. These individuals or entities may use your PII to help fulfill your requests in connection with the Service and to help us communicate with you about different services or resources offered through the Service or which may be offered through the Service.  For example, we may transfer certain of your PII or other information to service providers and other third parties who assist us in operating the Service or who help us in executing requests made by you, as well as to prospective partners.   We may also use certain PII of Subscribers for promotional purposes.

RustyBrick also collects and uses non-PII as is further described below.  

Under what other circumstances may we release PII to third parties?

In addition to our methods described above, we may release your PII to third parties if we believe that such release is necessary to comply with the law (e.g., a legal process or a statutory authorization or requirement) or a court order, to apply or enforce the Terms of Use or otherwise protect our interests, to protect our Subscribers or any of their Members, to protect against the fraudulent, abusive, or unlawful use of the Service, or if we reasonably believe that a danger to any person or property requires disclosure of such PII.

RustyBrick may be required to disclose an individual's PII in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.  

Our rights under this Privacy Policy may be assigned by RustyBrick, as determined by us in our sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees.  Without limitation of the foregoing, we may sell, transfer or otherwise share some or all of our assets, including without limitation your PII, with any parent company, subsidiary, joint venture, and a company under our common control, as well as with a potential acquirer, including without limitation in connection with a merger, reorganization, sale of assets, sale of equity, or in the event of bankruptcy.  In each such an event, the PII we have collected from you may be one of the assets transferred.

Is information that I post to public areas of the Service private?

The Service may enable you to post comments and other information to portions of the Service which are publicly viewable (such as Member birthdays, life cycle dates, etc.).   All of this information may be made publicly viewable, at the discretion and in the sole determination of the applicable Subscriber.  If a Subscriber decides to make any of such comments (including some of its Members’ PII) publicly viewable, then this information will not remain private. Therefore, Members should not post any information to publicly viewable portions of the Service unless either (a) you have confirmed with  their applicable Subscriber that such portions of the Service will not be made publicly viewable, or (b) you wish for such information be viewed publicly.    If you are a Subscriber, RustyBrick does not give you permission to post any PII to publicly viewable portions of the Service without first receiving the express written consent of each person whose PII is viewable to post such information.  Thus, if Subscribers post PII or any other information of their Members, then we assume that full permission has been granted for such a use by such Members.  If you are a Member, please carefully weigh the potential negative ramifications of posting PII to public areas of the Service before you post any such information.

What other information does RustyBrick collect and how may this be used?

We may also collect anonymous and aggregate information from you about your preferences in using the Service by using cookies, action tags and other methods.  Cookies are small text files that enable us and third parties (such as advertisers) to identify your computer.  We may use cookies to, among other things, monitor Service usage, customize Service features, identify your computer operating system and browser, serve and enable the serving of marketing tools, and complete transactions.  An action tag is a small, graphic image on a webpage that is designed to allow the Service owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time at which such webpage was viewed.  Action tags may be associated with cookie information.  We may also use such anonymous and aggregate information for promotional and other business purposes.

Do I have the ability not to be identified by RustyBrick other than by the PII you provide us?

Yes. If you do not wish to be easily identified by us using your PII (other than for any PII you may provide to us), you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence.  You can also adjust the settings in your browser to refuse all cookies.  If you do not want us to have any of your PII, do not submit any of your PII to us.  Please keep in mind that if you refuse cookies you may not be able to use certain Service functionality.

How do we store and safeguard information?

RustyBrick takes steps consistent with commercially reasonable industry standards to secure PII collected from you from loss, misuse, unauthorized access and accidental destruction while under our control.  However, please note that despite our efforts to protect information provided to us, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or unauthorized acts.

Does RustyBrick provide links to other Services?

RustyBrick may provide links to items of possible interest to Subscribers and/or Members, or such links may be provided by Subscribers.  The collection and use of your PII and other information by any such third party websites, or by any third party websites you navigate to from the Service, shall be subject to the policies and procedures of such third party websites and not those contained in this Privacy Policy.   The information collected by our service providers in executing transactions you have requested through the Service (including without limitation credit card settlement companies) is subject to the privacy policies of such third parties.

What are our policies regarding children?

The Service is intended for general use of persons who have reached the age of consent in their jurisdiction of residence, and it certainly is not targeted to anyone under thirteen (13) years of age.   RustyBrick does not knowingly collect PII from anyone under thirteen (13) years of age from any source that has not agreed to do so in full compliance with to the Children's Online Privacy Protection Act of 1998, as amended, and all related regulations (“COPPA”).  If we learn that PII from anyone under thirteen (13) years of age has been posted to the Service in a manner that we understand does not comply with COPPA, we will endeavor to promptly delete such information. 

Do we have a mechanism to address access to and removal of PII and complaints about the handling of information that we collect?

You have a right to know which PII RustyBrick holds about you, and to correct or delete such data if the Subscriber in whose account your PII has been submitted grants you permission to so correct or delete such data.  

If you wish to access or remove PII that you have submitted to RustyBrick, please send us an email requesting such access or removal to privacy@shulcloud.com.  If you are a Member and wish to access or remove PII that your Subscriber has posted to the Service, please contact your Subscriber with such request. If you have questions or concerns about, or wish to opt out of any of our information collection, data sharing, onward transfer, or other information handling practices, please contact us at privacy@shulcloud.com or write to us at RustyBrick, Inc., 250 West Nyack Road, Suite 200, West Nyack, NY 10994.

Do we respond to Do Not Track Signals?

The Service does not have the capability to respond to “Do Not Track” signals received from various web browsers.

What additional information do Subscribers and Members located in EU member states need to know?

As part of our participation in the EU-US Privacy Shield Framework, we are required to provide you with the following information: 

RustyBrick complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  RustyBrick has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view its certification page, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, RustyBrick commits to resolve complaints about our collection or use of your PII.  Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact RustyBrick at privacy@shulcloud.com. This is enforced by the Federal Trade Commission (the “FTC”).

RustyBrick has further committed to refer unresolved Privacy Shield complaints to BBB EU PRIVACY SHIELD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of BBB EU PRIVACY SHIELD are provided at no cost to you.

If your complaint is not resolved through these channels, under limited conditions, EU individuals may be able to invoke binding arbitration before a Privacy Shield Panel.

The FTC has jurisdiction over RustyBrick's compliance with Privacy Shield.

RustyBrick collects PII from Subscribers and Members located in the European Union including without limitation name, email, mailing addresses, family data and synagogue billing information for the purpose of providing membership management data storage and solutions for Subscribers.

Members can opt out of email or paper mailings from their synagogue Subscribers and also remove their data by logging into their Subscriber synagogue's web sites.  Each Subscriber is obligated by agreement with RustyBrick to make its Members aware that each such Member’s PII is being shared with and stored by RustyBrick through the Service.  

Please review on the following link if you wish to review the entire BBB Privacy Shield privacy policy.