Last Modified: November 1, 2018

The Wisconsin Evangelical Lutheran Synod (WELS), along with its subsidiaries and affiliates, including the WELS Church Extension Fund (“WELS CEF”), WELS Foundation, and WELS Investment Funds (unless otherwise indicated collectively, “WELS”, “we”, “our”, “us”) owns and operates the wels.net website, and its associated websites, however accessed (collectively, the “Site”). WELS understands that you are aware of and care about your own personal privacy interests, and WELS takes that seriously. This Privacy Policy describes WELS’ policies and practices regarding the collection and use of your personal data on our Site. By becoming a user of the Site or our Services through the Site or by otherwise submitting Personal Data to us on the Site, you give your consent to the collection and use of your personal data by WELS as explained in this policy.

Collection and Use of Personal Information

What Information We Collect
The information we collect varies depending on the type of activity you are performing on our Site or how you use the services. At times we will collect personal information from you and in other instances our Site will collect other information in order to deliver our services or as part of operating this Site. WELS may collect personal information from you when, for example, you request a financial product or service, make a charitable donation, request information from us or ask that we contact you, or apply for a job. The types of personal information we may collect include your name, address, email address, mobile number, credit or debit card information, social security number, and date of birth. We aggregate and de-identify personal information for data analytics and other business purposes. Such aggregated and de-identified information is not deemed personal information.

In addition, we collect personal information such as your name, address, e-mail, phone number, demographic information, professional organization membership, and military status when you apply for employment with us through this Site. We may also collect information relating to your education and employment history when you submit that information as part of an employment application. Not all requested information is required, however, and we specifically indicate what information is required in order to submit your employment application.

Other Information We Collect
Besides the information you choose to submit, our systems collect certain types of data automatically. This information gives us insight on how our Site is being used, as well as helps us understand how we may improve it in the future and does not necessarily individually identify you. We may collect information about your device, operating system, web browser, ISP, IP address, advertising identifiers, click activity, referring website, or region or general location where your computer or device is accessing the internet, to better serve you and to help us improve our Site and services. WELS may also use your IP address to help diagnose problems with its server and to administer its websites, analyze trends, track visitor movements, and gather broad demographic information that assists WELS in identifying visitor preferences. We may also collect information through cookies or other similar tracking technology to provide you with a personalized buying experience, facilitate our marketing efforts, or analyze how we can best provide you targeted information or promotions. This typically entails automatically gathering data such as any of the content you view on our website.

How We Use Your Information
WELS uses the information we collect on this Site to provide you with services requested or as required for membership, customize your online experience, and to improve the Site, our organization, and our products and services. More specifically, we use your information to:

  • Deliver our services as requested, including membership services
  • Provide informational, educational, or devotional content, including newsletters
  • Register you for and provide information about events or training; provide certification and training and event-related information
  • Consider you for employment
  • Communicate with you about our Site, services, or events
  • Provide you with information about benefits, events, goods, or services that may interest you
  • Present you with marketing relating to our Services and more relevant display advertisements, and to share promotional events
  • Conduct research and analysis to improve our Site and services
  • Manage our services offerings, and assess the effectiveness of our marketing efforts
  • Analyze and improve the content and functionality of our Site and services
  • Improve our products, services, or organization
  • Prevent, detect, or investigate security concerns, including fraud
  • Comply with applicable laws, regulations, or industry requirements
  • Fulfill any other purpose for which you provide it or consent

If at any time you wish not to receive any future marketing communications, or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note, however, that as a user of services, we will send you administrative communications that are reasonably necessary to the service, such as billing or service notifications.

How We Share and Disclose Your Information
We may share your information for our business purposes, examples of which are below.

  • We may share information with third parties if you give us consent or permission to share the information. For example, we may list your personal information in our Yearbook or other member directory as requested or approved by you.
  • We may share information with third parties who perform functions on our behalf, including support service providers, such as Site hosting, payment processing, data storage, marketing analysis, email and postal delivery, product and service delivery, analytics services, or other functions.
  • We may share information in accordance with a business transaction. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, other business transaction, we may share information subject to confidentiality arrangements.
  • We may share information to prevent, detect, or investigate security concerns, including fraud.
  • We may share information to comply with applicable laws, regulations, or industry requirements.
  • We may share your information with law enforcement if required by law or in order to prevent fraud or other potential wrongdoing.
  • We may share your personal information with our affiliates so that they may provide you information about products and services that may interest you to the extent allowed by applicable law.
  • We do not share your personal information with other non-affiliated third-party companies for those companies to market their services or products to you.
  • We may disclose or share your personal information in connection with an employment application to verify the information you provide

We may share de-identified or aggregated information collected from our Site with our affiliates or third parties to improve our products and services or our Site or for any other business purpose. WELS does not sell personal information to anyone and does not share it with any third parties for their marketing purposes.

How We Use Cookies and Web Beacons
Cookies are pieces of data that a website transfers to a user’s hard drive for record-keeping purposes. Web beacons are transparent pixel images that are used in collecting information about website usage, e-mail response, and tracking. WELS websites may use cookies and web beacons to provide enhanced functionality (e.g., user ID and password prompts and conference registration) and to aggregate traffic data (e.g., what pages are the most popular). These cookies may be delivered in a first-party or third-party context. WELS may also use cookies and web beacons in association with e-mails delivered by WELS. You have many choices in regard to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

Google Analytics
WELS websites may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), as well as other analytics tools. Google Analytics uses “cookies,” which are text files placed on your computer, to help a website analyze how users use the site. The information generated by the cookie about your use of a website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purposes of evaluating your use of a website, compiling reports on website activity for website operators, and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of WELS websites. By using WELS websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Your California Privacy Rights / Do Not Track
California residents visiting our Site may request that we not automatically gather and track information pertaining to their online browsing movements across the Internet. We do not track users through cookies or other tracking technologies across the internet. Third parties may collect information about you across different websites, including our website. California Law also permits California residents to opt-out of our disclosure of personal information to third parties for their direct marketing purposes or to learn the categories of recipients and information disclosed. We do not share your personal information with third parties for their marketing purposes.

Your Access to and Control Over Your Information
We enable you to have access to and control over the accuracy of your personal data. You can access, correct, update, amend, delete or request deletion of your personal data by emailing us at dpo@wels.net or by contacting us at the contact information listed below. We will respond to your request within 30 days.

We will retain your personal data for as long as your account is active or as needed to provide you Services. Moreover, we will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Leaving Our site And/Or Linking To Third Parties
Because our Site is secure, your browser URL will inform you if you are leaving a secured portion of the Site. When you leave this Site and go to another linked site, we are not responsible for the content or availability of the linked site. Please be advised that we do not represent either the third party or you, if you enter into a transaction on the third-party site. Further, the privacy and security policies of the linked site may differ from those practiced by us.

WELS websites provide links to social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or share information from a WELS website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data. As with any other third-party site, these social media sites linked on our Site are not subject to our Privacy Policy.

Children Under 13 Years Old
This Site is not directed at or intended for use by children under 13 years old. WELS does not knowingly attempt to solicit or receive information from children under the age of 13 without the consent of a parent or guardian. If WELS is made aware of such a situation, WELS will delete such information and/or attempt to contact a parent or guardian.

FOR USERS IN THE EUROPEAN ECONOMIC AREA AND SWITZERLAND

General Data Protection Regulations (GDPR) Information

WELS as Controller
WELS obtains and processes personal information in different capacities. When you provide us with your information through our Site or to use our services, we serve as a data controller. When we act as a data controller, we determine how personal information will be utilized, in accordance with this Privacy Policy.

WELS is headquartered in Wisconsin, in the United States. WELS has appointed an internal data protection officer for you to contact with any questions or concerns about WELS’ personal data policies or practices. WELS’ data protection officer is:

Martin A. Spriggs
WELS Chief Technology Officer
N16W23377 Stone Ridge Drive
Waukesha, WI 53188 USA
dpo@wels.net
+1 414-256-3200

Our Legal Basis for Processing Your Personal Data
We process the personal information you provide relating to the services and Site in order to perform our contractual obligations to provide you services. We also process your personal information based on our legitimate interests to provide our services and Site to you, to develop and improve our services and Site that we provide to you, to prevent fraud, and/or comply with law enforcement requests. Where we ask for consent, we process certain personal information based on your consent.

Data Subject Rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office.

Access and Control of Your Information

We enable you to have control over the accuracy of your personal information. You may be able to access and review your personal information by logging into the Site and visiting your account profile page. You may also send us an e-mail at dpo@wels.net to request access to the personal data we hold about you.

Right to Rectification
You have the right to correct your personal data if incorrect, which also includes the right to have incomplete personal data completed. You may be able to do so by logging into your account and deactivating any incorrect or incomplete information and adding the corrected and/or completed information. You can also contact us at dpo@wels.net.

Data Portability
When we process your personal data by automated means that you have provided to us based on consent or through a contract, you have the right to get a copy of that data in a structured, commonly used and machine-readable format and have that transferred to you or to third party.

Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal information:

  • During the pending period of time where we verify the accuracy of any personal data that you claim is inaccurate
  • Where the processing of your personal data is unlawful, but you oppose erasure and instead request that we restrict the use of your personal data
  • If we no longer need your personal data but it is required for you to make or defend legal claims
  • During the pending period of time where we verify our legitimate interest to process your data when you object to such processing

Erasure of Personal Data
You have the right to delete the data collected through our Site and may be able to do so by logging into your account and either deleting your account or deleting the specific personal data. There may be instances where we may not be able to delete your data or where we retain a copy of your data, for example, where we may need it to comply with a legal obligation or to protect the rights of others. You can also contact us at
dpo@wels.net.

How Long We Keep Your Personal Data
We retain your personal data for as long as necessary to provide the services and Site to you.

How to Exercise Your Rights
To exercise the rights stated above, please email dpo@wels.net. You can also exercise many of your data rights through your account.

Right to Complain to Supervisory Authority
If you believe that WELS is processing your personal data in an incorrect or unlawful manner, please contact us at dpo@wels.net For those located in the European Union, you also have a right to file a complaint with a Supervisory Authority.

INTERNATIONAL TRANSFER OF INFORMATION COLLECTED

Information WELS collects from you will be stored and processed in the United States. If you provide us information, it will be transferred to, processed, and accessed in the United States. This Privacy Policy shall apply even if we transfer Personal Data from non-United States countries to other countries.

YOU CONSENT TO ANY AND ALL INFORMATION YOU PROVIDE AND SUBMIT VIA THE SITE BEING SENT TO THE UNITED STATES OF AMERICA. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. WELS relies on derogations for specific situations as set forth in Article 49 of the GDPR. YOU ARE ALSO INFORMED THAT THE UNITED STATES PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015 (Case C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL DATA TO THE UNITED STATES, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY.

Data Security and Storage
To help protect the privacy of data and personally identifiable information you transmit through use of the Site, WELS maintains technical, administrative, and physical safeguards. WELS updates and tests its security on an ongoing basis. Access to your personal data is restricted to those WELS employees who need to know that information to provide benefits or services to you. In addition, WELS trains its employees about the importance of confidentiality and maintaining the privacy and security of your information. WELS commits to taking appropriate disciplinary measures to enforce its employees’ privacy responsibilities.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at dpo@wels.net.

Changes to the Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by indicating an update to the Privacy Policy on our homepage and updating the Last Modified date above. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of this Site after we email you or indicate that we made changes to the Privacy Policy is deemed to be acceptance of those changes.

Contact Us
Please feel free to contact us if you have any questions about the Privacy Policy or the information practices of this Site: dpo@wels.net