PERSHING SQUARE PHILANTHROPIES

PRIVACY POLICY

Last Updated: February 6, 2025

This “Privacy Policy” describes the privacy practices of the Pershing Square Philanthropies: Pershing Square Foundation, The Bill Ackman and Neri Oxman Foundation and The Oxman-Ackman Family Fund (individually and collectively referred to herein as “PSP”, “us”, “we”, or “our”). In this Privacy Policy, we explain what personal information we collect, how we use and protect your personal information, with whom we may share it and the rights that you may have in connection with it.

This Privacy Policy applies to personal information we collect, including through our website www.pershingsquarephilanthropies.org (the “Website”), events and programs registrations, mobile applications, social media pages, online portals, surveys, job applications, and grant applications. This Privacy Policy is incorporated into our Website Terms of Use located at https://pershingsquarephilanthropies.org/terms-of-use.

By using our Website and/or by providing personal information to us (by any means, whether directly to us when applying for employment or grants, attending events or programs, on our Website, visiting our social media pages, completing surveys, or in any other interaction with PSP), you consent to our use of your personal information in accordance with this Privacy Policy.  

By using our Website or otherwise providing us with your personal information, you are accepting the terms of this Privacy Policy and agreeing that we may use your personal information as described herein. If you do not agree to the terms of this Privacy Policy, please do not use the Website or otherwise provide us with your personal information.

Personal Information We Collect

We may obtain personal information from you in various ways, including when you or your organization provides it to us, as well as when you visit our Website. You may provide personal information to us online, by telephone, when you attend our events or visit our facilities in person, when you respond to mail or email solicitations from us, when you complete our surveys, and when you sign up for newsletters. When you visit our Website, we may automatically collect certain personal information from you.

The types of personal information we may collect from you are described below.

Information you provide to us

When you contact us

When you contact us via phone, email or in person for any reason, including when you contact us regarding activities or events, register for our programs, activities, initiatives and events, complete our surveys, interact with our Website, or in conjunction with any other context in which you knowingly provide information to us, we may collect the following types of information from you:

·       Name, address, date of birth, email address and telephone number;

·       Organization name, address, email address and telephone number;

·       Demographic information

·       Preferences, information about a disability or requests for accommodations to the extent disclosed to us; and

·       Other information or content that you may choose to provide.

When you provide information via our Website

When you submit personal information to us via our Website, we may collect the following types of information from you:

·       Contact information, such as your name, address, email address, and telephone number; and

·       Any other information that you may choose to provide (e.g., in an online form on the Website).

When you apply for employment

If you apply for employment with us, we may collect the following types of information during the application process:

·       Name, address, email address, and telephone number;

·       Resume, work history, work authorization status, education, skills, professional licenses, permits or certifications and references;

·       Optional demographic information, such as gender identity, race/ethnicity, sexual orientation and religious affiliations; and

·       Any other information you choose to provide during the application process.

When you apply for a grant

If you choose to apply for a grant from PSP, or if your employer or organization includes information about you in a grant application, we may collect the following types of information during the application process:

·       Name, address, date of birth, email address, telephone number;

·       Citizenship information and visa information;

·       Resume, work history, qualifications, education, skills, professional licenses, permits or certifications and references;

·       Tax identification/national identification numbers, bank account information for payments;

·       Optional demographic information, such as gender identity, race/ethnicity, disability and sexual orientation; and

·       Any other information you choose to provide during the application process.

When you are a third-party supplier

If you are a third-party who provides products or services to PSP, we may collect the following types of information from you:

·       For individual suppliers: name, address, email address, telephone number, citizenship information, visa information, W-9, tax identification numbers, bank account information for payments.

·       For organizations that are suppliers: organization name, address, email address and telephone number, W-9, tax identification numbers and bank account information for payments; and

·       Other information that you may choose to provide. 

When you interact with our social media pages

When you visit our social media pages, we may collect the following types of information from you:

·       Name and social media handle;

·       Internet Protocol addresses and device identifier(s) (such as an Apple ID); and

·       Other information that you publicly post on your social media pages.

When you interact with us in person

In addition to the types of information described above, we may collect additional types of information when individuals interact with us in person, such as when individuals visit our offices or attend one of our events. The types of personal information we collect in these contexts include:

·       Photos and audio and/or visual recordings of our events; and

·       CCTV security footage of the public areas inside and outside of our offices.

Personal information automatically collected

Subject to applicable consent requirements for non-essential cookies, we use web cookies to collect such activity information. Web cookies are small text files used to collect information that allow us to understand how users interact with our Website. In this Policy, web cookies are referred to as “cookies”.

The cookies we use fall into the following categories:

Unless otherwise required by law, necessary cookies will be placed when you visit the Website. If you opt-out of functional or analytics and performance cookies when you visit the Website by exercising (or changing) your consent preferences, those cookies will not be placed. Further, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If, however, you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly, including, for example, as described in the Functional Cookies section in the table set forth above. Please note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness. 

Personal information we receive from third parties

We may receive the following personal information about you from third parties:

• Information about your participation in events (e.g., from event organizers providing services to us);

• Information from service providers, consultants, or vendors providing services to PSP;

• Work and qualification information and/or contact information submitted by your employer or organization in connection with a grant application or reporting;

• Employment verification;

• Education information; and

• Reference information.

How We Use Your Personal Information

To provide our services

We use your personal information to provide our services in the following ways:

·       to operate, maintain, administer and improve our Website, events and other charitable activities;

·       to publish our newsletters, magazines, survey results and other communications;

·       to review and respond to grant applications, proposals and other documents submitted to us;

·       to analyze the effectiveness of our grants;

·       to better understand your needs and interests;

·       to provide support and maintenance for the Website;

·       to provide marketing and notifications regarding our grants, programs, events and other services;

·       to respond to your requests, questions and feedback; and

·       to fulfill any other purpose for which you provide us with your personal information.

To manage our recruiting and to process employment applications

We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and to process employment applications, such as by evaluating a job candidate for an employment activity and to monitor recruitment statistics. We will only use personal information collected in an employment application to assess your candidacy for employment and not for other purposes.

To comply with law

We may use your personal information as we believe necessary or appropriate to comply with any applicable court order, law, regulation and legal processes, including to respond to any government or regulatory request.

With your consent

We will request your consent to use your personal information where required by law, such as where we use non-essential cookies. You have the right to withdraw your consent at any time in the manner that was indicated when we requested the consent or by contacting us at privacy@pershingsquarephilanthropies.org.

To create anonymous data for analytics

We may create anonymous data from your personal information to track Website traffic in order to better understand how visitors use the Website. We make personal information into anonymous data by excluding or deleting information that makes the data personally identifiable to you.

For compliance, fraud prevention and safety

We may use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our service[s]; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Disclose Your Personal Information

We do not sell your personal data or share your personal data for cross-contextual targeted advertising. However, we may disclose your personal data in the following circumstances:

To affiliates

We may disclose your personal information to our subsidiaries and affiliates for purposes consistent with this Privacy Policy.  In addition, the three PSP entities may share your personal information amongst themselves.

To contractors and service providers

We may employ third-party companies and individuals to administer and provide our services on our behalf (such as customer support, hosting, email delivery, database management services and job applicant management systems, as well as external reviewers and advisers who help us process and make determinations regarding grant applications). These third parties may use your information only as directed by PSP and in a manner consistent with this Privacy Policy. Contractors and service providers are prohibited from using or disclosing your information for any other purpose.

In connection with a business transfer and to professional advisors

If (a) we or our subsidiaries or affiliates are or may be acquired by, merged with, or invested in by another company, or (b) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or other reorganization of our business, we may transfer the personal information we have collected about you to the other company.

To professional advisers

We may disclose your personal information to professional advisers, such as lawyers, bankers, auditors, accountants and insurers, where necessary in the course of the professional services rendered to us, including as part of the business transfer process as described above.

For disclosures about grant recipients

We may publish information on our Website or elsewhere about recipients of our grants, including name and amount of funding, and may disclose this type of information directly to third parties. You have the option to request that such information not be published or disclosed, subject to our other rights to disclose personal information under this Privacy Policy. For example, you acknowledge and agree that PSP will be required to disclose any grants paid to you by PSP in its regulatory and legal filings.

For compliance with laws and law enforcement; protection and safety

We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with any applicable court order, laws, regulation and lawful requests and legal processes, such as to respond to subpoenas; (b) enforce the terms and conditions that govern the Website; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Exercising Your Rights

To the extent provided by applicable laws, you may have the right to opt out of the sale of your personal information or targeted advertising; obtain confirmation that we hold personal data about you; access, correct, or delete your personal data; withdraw any consent you previously provided to us; object to or restrict our processing of your personal data in any other context; deactivate, block, anonymize, or delete personal data as appropriate; or request and receive a copy of the personal data you have provided us and to transmit this data to a third party. To exercise any of these rights, please contact us at privacy@persq.org or at the address set forth below.  If you are an EEA, EU, Swiss, or UK data subject, you also have the right to lodge a complaint with the applicable EEA, EU, Swiss, or UK supervisory authority -- in particular, in the country of your habitual residence, place of work or place of the alleged infringement -- if you consider that the processing of your personal information has been or is unlawful.

To keep your personal information safe, if we cannot ascertain your identity or if we have reasonable doubts concerning your identity, then prior to processing your request, we may ask you to submit additional information for the purposes of verifying your identity.

You will not be charged or have to pay a fee to exercise your rights regarding your personal information, including your right to access your personal information, your rights to correction or deletion of your personal information and your right to object.  However, if your request is manifestly unfounded or excessive, in particular because of its repetitive character, we may charge a reasonable fee or refuse your request.

Marketing communications

We do not currently provide marketing-related emails, other than a curated newsletter that we post on Substack.  Users who no longer wish to receive that newsletter may unsubscribe on Substack from receiving our newsletter.

Choosing not to share your personal information

You may choose not to provide personal information to us. However, we may not be able to provide services to you if we are required to collect your personal information or if we need your personal information in order to provide the services. We will tell you what information you must provide to receive our services by designating it as required or through other appropriate means.

Security

We implement physical, technical, and organizational security measures designed to safeguard personal information. These measures are designed to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure alteration, and destruction. Please be aware that despite our efforts, no measures can guarantee security.

Children

Our Website is not intended for children under 16. If you become aware that a child has provided us with information without parental or guardian consent, please contact us at privacy@persq.org.

International Transfer

Your personal information may be processed, transferred to, and maintained on servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. Where required by applicable law, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us at privacy@persq.org.

Where required by applicable local law, our legal bases for processing your personal information are as follows: 

• Performance of a contract: We process personal information where necessary for the performance of our contractual obligations to you. For example, when you submit a grant application, sign-up to attend an event, or engage in another transaction with us.

• Compliance with legal obligations: We process personal information where necessary to comply with the legal obligations to which we are subject. For example, to cooperate with public and government authorities, courts, or regulators in accordance with our legal obligations, to the extent this requires the processing or disclosure of personal information to protect our rights.

• Legitimate interests: We process personal information where necessary to serve our legitimate business interests when those interests are not outweighed by the interests and fundamental rights and freedoms of the individual. For example, to ensure that we can effectively manage and communicate regarding our business, to perform investigations or compliance audits, to improve our services, to exercise or defend our rights, and for business administration purposes. You can contact us at privacy@persq.org for information about how we assess whether we are permitted to use your personal information under this legal basis.

• Consent: Where required by applicable law, we process personal information based on your consent. If we have obtained your consent, you may have the right to withdraw your consent under applicable local law. To exercise this right, please contact us at privacy@persq.org. 

Other Sites and Services

Our Website may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services and are not responsible for their information practices or other actions. We encourage you to read the privacy policies of the other websites you visit and services you use.

Retention Period

We will retain personal information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the personal information was collected or processed as outlined in this Privacy Policy unless a longer retention period is required or allowed by applicable law. Notwithstanding the foregoing, we may maintain donor and grant recipient information for an indefinite period, unless prohibited by applicable law.

California Users – Shine the Light Disclosure

California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. We do not currently share the personal information of California residents with third parties for their own direct marketing purposes. However, if you have further questions about our privacy practices and compliance with California law, please contact us at privacy@persq.org.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. You should periodically review this page for the latest information on our privacy practices. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected about you, we will provide you with notice in advance of such change by highlighting the change on the Website or otherwise communicating such change to you and, where required by law, we will seek your consent to such change.

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at privacy@persq.org, or write to us at:

Pershing Square Philanthropies

Attention:  Legal

787 11th Avenue, 9th Floor

New York, NY 10019