We have adopted this policy in order to address specific privacy concerns, and it applies to how we collect, use and disclose personal information of individuals who visit our website.
What Information Do We Collect?
You can visit our website without telling us who you are or revealing personal information about yourself, including your e-mail address. Our web server and third-party analytics programs may collect anonymous information related to your visit to our website, which may include: IP address and domain used to access our website, your approximate geographical location, websites visited before or after your visit to an LHM site, device and browser information, the website you visited to access our website, the entry and exit pages on our site, as well as any additional pages viewed on our site. We use this information to monitor our website's performance (such as number of visits, average time spent, page views, etc.) and for our own operational and advertising purposes, such as working to continually upgrade our website and delivering ads to you for programs in which you may have an interest.
This information may be captured using automated tracking technologies such as browser cookies , flash cookies, and web beacons, and may also be collected through the use of third party tracking services (such as Google Analytics) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our website.
In addition, we collect the personal information that you submit to our website, such as your name, address and any other information that you choose to provide. Collection may occur, for example, when you:
- Contact us through our website;
- Create an account (examples: e-mail subscriptions, sections and downloads which require a password, online shopping with LHM)
- Make a donation or purchase order, resulting in an appropriate receipt;
- Receive and review online information about our ministries;
- Apply for a position or to volunteer through our website;
- Request resources, book an event, or
- Correspond with an employee or representative of LHM.
Where you request information from us, we may use the e-mail address that you provide to send you information about our ministry and resources that may be of interest to you. If you have agreed to receive communications from us, such as by e-mail, you may ask us to remove you from the list at any time by using the Unsubscribe link on our subscription e-mails.
Personal Information About Users Under 18 Years of Age Not Collected
We note, however, that we will only knowingly receive, process, and store information on those who are under the age of 13 with parental consent. We take steps to maintain the privacy of that information. We do not share it with any third-parties who do not have a reasonable need for such information related to the provision of the Site Services. We aim to collect the minimum amount of information necessary to provide the Services to individuals under the age of 13. The following type of information may be kept: name, email address, age range, physical address, and phone number. Parents of children under the age of 13 have the right to review and ask for the deletion of the personal information kept on their child(ren). You can request access to this information by contacting us at the contact information listed on the bottom of this policy.
What about Online Advertising?
We promote and encourage support of our ministry activities and resources by occasionally using advertising space on third-party websites including Remarketing with Google Analytics. When you visit some websites, we or a third party may place one or more types of cookies on your computer in order to recognize your computer. Because we advertise about our ministry activities on third-party websites, we are able to compile anonymous information over time about the types of pages, content, and ads you or others who use your computer visited or viewed. This anonymous information is used for many purposes. For example, it helps us try to ensure that you do not see the same advertisements repeatedly. We also use this anonymous information to help select and display targeted advertisements on third-party websites that encourage support of our ministry activities.
We use non-personally identifiable information from interest based advertising or audience data from third parties (such as age, gender, and interests) to get a broad understanding of the demographics of our website audience.
Third-party companies also may collect anonymous information about your activity on our websites and applications and on third-party websites and applications using online tracking technologies, such as cookies and web beacons. Tracking data collected by these third-party companies is used to decide which advertisements you see on third-party websites and applications, but does not identify you personally.
This data collection is through Google's Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting). Third-party vendors, including Google, may show these ads on sites across the Internet.
Together with third-party vendors, including Google, we may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.
You may choose not to receive targeted advertisements from many ad networks, data exchanges, marketing analytics and other service providers by visiting the Ad Preferences Manager.
Our web site may use SessionCam for analysis. SessionCam is a product that has been developed by SessionCam LTD. SessionCam may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data. Data collected by SessionCam from Lutheran Hour Ministries websites is for Lutheran Hour Ministries internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.
Linking to Other Websites
Our website may contain links to other websites. To allow you to interact with third-party websites on which you may have accounts (such as social media websites) or join communities on such websites, we may provide links or embed third-party applications that allow you to login, post content, or join communities from our websites.
Why Do We Collect and Use Personal Information?
The personal information collected through our website is used and disclosed for our ministry purposes. For example, we may collect, use and disclose your personal information to:
- Establish, maintain and manage our relationship with you and fulfill orders that have been requested;
- Be able to review the products and services that we provide to you so that we may work to improve our ministries;
- Be able to comply with your requests;
- Protect us against error, fraud, theft and damage to our property; and
- Enable us to comply with applicable law or regulatory process (for example, we may collect personal information to satisfy the obligations imposed on us by various regulators).
- Communicate with you about our ministry and resources which may be of interest to you.
We do not sell, rent or lease your personal information to other organizations. In order to fulfill the ministry and organizational purposes for which you provided us your personal information, it may be shared with our employees, other Lutheran organizations and any parties who require such information to assist us with establishing, maintaining and managing our relationship with you and providing ministry products and services. For example, LHM depends on certain information technology, data processing services, and consulting services to affiliated organizations and ministry partners (in the US or abroad) to provide ministry services. As a result, your personal information may transit through or be collected, used, processed, stored or disclosed under the control of LHM or one of our affiliated organizations or ministry partners. Where your personal information is provided to ministry partners or service providers, we use confidentiality agreements that restrict the use of your information to the purpose for which it is provided.
Please note that we may collect, use or disclose your publicly-available personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
How Do We Protect Your Information?
LHM maintains safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
LHM uses Internet Encryption Software, Secure Socket Layer (SSL) Protocol when collecting or transferring sensitive data such as credit card or banking information. Any information you enter is encrypted at your browser, sent over the public Internet in encrypted form, and then de-crypted at our server. Once we receive your credit card information, it is accessible only to a small number of trusted LHM employees who have been specially trained in processing this information. Credit card information is only stored on our servers, in encrypted form, for the length of time needed for a specific transaction. For example, credit card information for online purchases is passed directly to the credit card processing center immediately and is not stored on our servers at all; credit card information for one-time online donations is stored only as long as is needed for processing the gift; while credit card information for automated recurring donations is stored, in encrypted form, until the recurring gift schedule is cancelled or the credit card expires, whichever is sooner.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make every reasonable effort to ensure its security on our systems. The security of your personal information is important to us. Please advise us immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information (e-mail, name, address) changes, please keep us informed of such changes. We will replace or append your accounts with the updated information.
Inquiries or Concerns?
Lutheran Hour Ministries (LHM) Board Policy Manual's Governing Principles and Integrity and LHM's Employee Handbook require directors, officers, volunteers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of LHM, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
It is the responsibility of all directors, officers, volunteers and employees to comply with LHM's policies and to report violations or suspected violations in accordance with this Whistleblower Policy. It is the responsibility of all directors, officers, volunteers and employees to fully cooperate with an investigation.
The Code of Ethics addresses LHM's 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 the Director of Human Resources or anyone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code of Ethics to Jim Dankenbring, Attorney at Law, if they involve the Executive Director or President of the Board; to the Director of Human Resources, if the violations involve any other employee; or to the Executive Director, if the violations involve the Director of Human Resources. These parties have specific and exclusive responsibility to direct the investigation of all reported violations.
Acting in Good Faith:
Anyone filing a complaint concerning a violation or suspected violation of the Code of Ethics must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code of 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 and may result in disciplinary action, up to and including termination.
Violations or suspected violations may be submitted on a confidential basis 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.
Handling of Reported Violations:
Jim Dankenbring, Attorney, the Director of Human Resources, or the Executive Director, depending on the focus of the violation, will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
No director, officer, volunteer or employee who, in good faith, reports a violation of the Code or participates in an official investigation 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 LHM prior to seeking resolution outside LHM.