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•      Non-PII is anonymous information that cannot be used to identify an
                              individual.    Non-PII  is  often  used  to  track  how  visitors  navigate  your
                              website,  which  pages  were  viewed  most  often,  what  other  websites
                              they  have  visited,  and  similar  data.    You  should  also  identify  the
                              technologies  and  methods  your  organization  uses  to  collect  PII  and
                              non-PII.  Disclosing the methods used to collect this information can
                              increase trust and confidence in your organization and help individuals
                              decide whether to share their information with you.


                              (iv)   How Collected Information Is Used

                       Your privacy policy should describe exactly how you will and will not use the
               information you collect.  Use this as an opportunity to sell them on your website’s
               features and services.  For instance, some organizations use cookies to track what
               articles are read so that they can suggest related articles.


                       Because e-mail spam is such a problem, the first question individuals usually
               have  for  an  organization  is  “Will  you  give  my  e-mail  address  to  anyone  else?”
               Individuals are usually most comfortable when their e-mail addresses are used only
               by the organization they directly give them to.  However, there are many situations
               where organizations can benefit from sharing e-mail addresses.  Whether you plan
               to share information or not, it is vital that your privacy policy accurately describes
               your  practices  and,  in  the  process,  reassures  individuals  so  they  will  continue  to
               provide the information you need to successfully provide services you offer.


                              (v)    How Consumers Can Opt Out


                       Generally  speaking,  it  is  a  best  practice  that  PII  only  be  collected  with  the
               individual’s consent.  If PII is collected without the consumer’s consent, your privacy
               policy should clearly explain how the consumer can opt out of your data collection
               process.  The actual  steps for opting out  depend on the type  of information you
               collect and the technologies you use to do it.

                       If  you  allow  third-party  advertising  companies,  such  as  24/7  Real  Media  or
               DoubleClick,  to  run  advertisements  on  your  site,  you  should  consider  telling
               consumers about these companies’ information collection process and, if offered,
               how to opt out of such data collection.  However, you do not have to provide the
               exact  instructions:    simply  point  individuals  to  the  appropriate  page  on  the  third
               party’s  website.    Alternatively,  if  the  third-party  advertiser  is  a  member  of  the
               Network Advertising Initiative (“NAI”), point your customer to the NAI opt-out page

               at http://optout.networkadvertising.org.





               WASHINGTON NONPROFIT HANDBOOK                -268-                                       2018
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