Privacy Policy

Updated: 12/22/2021

  1. Introduction

The Community Action Organization of Western New York (hereafter “CAO”, “we”, “us” or “our”) is committed to safeguarding the privacy of our consumers and website visitors (hereafter “consumer,” “you,” or “your,”). As such, this Privacy Policy (“Privacy Policy”) covers CAO’s handling, use and disclosure of information collected from you through the website (

  1. Acceptance

You should review this Privacy Policy carefully, and be sure you understand it, prior to using the website or otherwise providing any information to CAO in connection with the use of information and services offered through the website. If you use the website, provide information to us, or pay us for services through the website, it will be deemed to be acceptance by you of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use or otherwise provide any information to CAO and should immediately terminate your use of the website. For purposes of this Section, accessing the website only to review this Privacy Policy is not deemed to be use of the website.

  1. Information

In this Privacy Policy, the following information is covered:

(a)        “Analytical Information” means all Non-Personal Information obtained through the use of cookies, web beacons, Ad-IDs or other tracking technologies, local shared objects (used to store your preferences or display content) and server log files (used to track, among other things, (i) your search terms, (ii) your computer’s access date and time, browser, connection speed, Internet service provider, language, location, manufacturer, visit details, and operating system, and (iii) whether or not you opened e-mail messages and other electronic communications from CAO, and if you did, the times they were opened);

(c)        “Collected Information” means all (i) Personal Information and (ii) Non-Personal Information collected by CAO;

(d)       “Non-Personal Information” means all information collected by CAO, whether electronically or manually, through (i) the CAO website, and (ii) e-mail messages and other electronic communications that you may send to CAO, that is not Personal Information (including, but not limited to, any Analytical Information);

(e)        “Personal Information” means all information collected by CAO, whether electronically or manually, through (i) the website, and (ii) e-mail messages and other electronic communications that you may send to CAO, that relates to an individual and that identifies, or can be used in conjunction with other readily-accessible information to identify, such individual (including, but not limited to, name, e-mail address, physical address, phone number, device ID or other persistent identifiers tied to your computer or device).

  1. Electronic Communications

Whether or not you have previously sent CAO an e-mail message, you consent to CAO sending you e-mail messages and other electronic communications (a) in connection with your use of the website, (b) in connection with payments made to CAO through the website, or (c) for any other legitimate business purpose (including, but not limited to, marketing). Since CAO endeavors to send e-mail messages and other electronic communications only to individuals desiring to receive them, you can unsubscribe to such e-mail messages or other electronic communications at any time by contacting CAO as set forth in Section 18 or by following the directions contained in such e-mail messages or other electronic communications.  Any request to unsubscribe to e-mail or other electronic communications will likely be effective within 48 hours after your request is received by CAO.

  1. Collection of Information

Except for any Collected Information obtained automatically through the website and addressed below, no Collected Information is obtained from you, unless it is voluntarily provided. For example, CAO collects the full name, email address, postal address, phone number, and other identification and contact data from volunteers and job applicants, as well as from consumers or other individuals and companies who sign-up to receive information about CAO, its programs and its services. Consumers may provide information to CAO when paying for programs and services, making donations, responding to surveys and requesting further information about CAO.


Regardless of the method used to obtain Collected Information, CAO will only collect and retain Personal Information in a manner that is consistent with: (1) all applicable privacy and security laws, (2) the purposes for which the Personal Information is provided and (3) CAO’s other legitimate business purposes (including, but not limited to, marketing). You are responsible for obtaining any approvals, authorizations, consents, permissions and permits that are required in connection with your providing CAO with any information (including, but not limited to, any information relating to a third party). You represent and warrant that all information was obtained by you in accordance with all applicable laws and that you have the right to provide CAO with such information for the purpose of paying for programs and services, making donations and otherwise interacting with the website.

  1. Payment Processing

CAO uses a third party vendor to process donations and payments made by consumers for the programs and services. We do not collect or process payment information internally. However, CAO ensures that obligations substantially no less protective than those set out in this Privacy Policy are imposed on our third party vendor by way of contract or other legally binding agreement, in particular providing sufficient guarantees that technical and organizational measures are implemented in such a manner to meet the requirements of this Privacy Policy and the relevant data protection laws.

  1. How We Use and Collect Analytical Information

Analytical Information is collected automatically through the website. The website utilizes cookies to save your preferences and track your interaction with it. Your browser may provide you with the ability to block cookies as well as the ability to delete already existing essential and nonessential cookies.  If you block or delete cookies you may not be able to receive the benefits of certain features of the website.

Analytical Information will only be used by CAO (a) to record your use of the website or services, (b) to diagnose problems with the website or services, (c) to improve the website or services and make them more useful to you and other users, (d) to monitor and analyze trends, usage, and activities in connection with our products; (e) for marketing, advertising, administrative, analytical, research, optimization, and other purposes.; and (f) for other legitimate business purposes of CAO. From time to time, we may use third parties to deliver ads to you over the internet.  For example, Google Analytics is one of the providers we use to collect Analytical Information. These data analytics and online advertising providers may combine and use data collected through your use of the website with data they collect over time and across different websites for their own purposes. You can learn about how Google collects and processes data at You can learn about the controls Google offers to manage the collection and use of your information at We recommend that you review these notices at the links provided above.

  1. How We Use Personal Information

CAO does not sell Personal Information.  However, all Personal Information may be used by CAO for any legitimate business purpose. If CAO expressly states in this Privacy Policy or in another writing that any Personal Information will only be used for a specific purpose, CAO will only use such Personal Information for such purpose, unless you subsequently consent to its being used for another purpose.

Specifically, we may use your Personal Information, including information from individuals acting in their capacity as business representatives, to: (a) process, verify, and complete transactions, and send you information about programs and services; (b) send transactional messages, including providing updates pertaining to a program, and responding to your comments, questions, and requests; (c) provide customer service and support; (d) send news about our programs and services; (e) investigate and prevent fraudulent transactions and other illegal activities; and (f) comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.

  1. Disclosing Collected Information

Any Collected Information obtained by CAO, whether or not for a specific purpose, may be transferred to third parties designated by CAO (including, but not limited to sub-contractors or vendors engaged by CAO to perform administrative and technological functions) for any purposes for which CAO could use such Collected Information. If Collected Information is so transferred, CAO will have no responsibility for any action of the third party to whom or which such Collected Information is transferred.

Specifically, disclosure of collected information may be made to the following persons or entities:

(a)        Service Providers. We engage service providers to perform functions and provide services to us. We may share Collected Information, including Personal Information, with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures. CAO will, to the extent practicable, limit disclosures to service providers to the minimum necessary to accomplish the intended purpose of such use disclosure or request.

(b)       Authorized Personnel. CAO employees may have access to Collected Information as necessary in the normal course of our business.

(c)        Business Transfers. In the future, we may choose to buy or sell assets, or have engaged in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether continuing operations or as part of bankruptcy, liquidation or similar proceeding. In these types of transactions, customer information is typically one of the business assets that is transferred.

(d)       Government, Law Enforcement or Third Parties. CAO may disclose any Collected Information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange Collected Information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of CAO and its personnel.

  1. Third-Party Sites

CAO’s website may contain links to, or be accessible from, websites provided by third parties (individually a “Third-Party Site”). Your use of a Third-Party Site will be subject to its terms of use and other provisions, and you are responsible for complying with such terms and other provisions. This Privacy Policy does not cover the privacy policies or practices of any Third-Party Site, and CAO is not responsible for any information you submit to, or is otherwise collected by, any Third-Party Site. CAO is only responsible for Collected Information obtained by it (a) through your authorized use of the website, or (b) from other sources in the ordinary course of its business. You should consult each Third-Party Site for its privacy policy or practice before submitting any information to, or otherwise using, such Third-Party Site.

  1. Children

The website is not intended for children under 13 years of age.  However, if a parent or guardian of a child who is under 13 years of age discovers that Personal Information of such child has been submitted to CAO through the website without the parent’s or guardian’s consent, CAO will use commercially reasonable efforts to remove such information from the website and servers at the parent’s or guardian’s request.  To request the removal of such Personal Information, the parent or guardian must contact CAO as set forth in Section 18, and provide all information requested by CAO to assist it in identifying the Personal Information to be removed.

  1. Security of Collected Information

CAO will protect Collected Information from loss, misuse and unauthorized access, alteration, destruction and disclosure as required by all applicable laws, including privacy and security laws. CAO will, at a minimum, use commercially reasonable efforts to protect Personal Information from loss, misuse and unauthorized access, alteration, destruction and disclosure. We implement reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your Collected Information, including Personal Information. Since no transmission of information over the Internet or electronic storage of information is completely secure, it is possible that Collected Information could be lost, misused or accessed, altered, destroyed or disclosed without authorization, even if CAO uses such reasonable efforts.

  1. Users from Other Jurisdictions

The website and business operations are controlled and operated by CAO from Western New York. If you are not a resident of the United States or you are located outside the United States, you should not use the website or transmit Personal Information unless you are in compliance with all applicable law. If you choose to use the website or provide information to us, please note that we may transfer Personal Information provided by you for processing in the United States. By providing Personal Information to us for the purpose of placing you or your company on our contact lists, you consent to the transfer of Personal Information to the United States.  The transfer of that Personal Information to the United States is necessary for CAO to provide requested information and services.

We do not represent or warrant that the website is appropriate, lawful, or available for use in any particular jurisdiction. Those who choose to access the website or pay for programs and services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.

  1. Applicable Law

This Privacy Policy, and any disputes arising out of or related hereto, shall be governed exclusively by the laws of the State of New York, without regard to its conflicts of laws rules.  The state and federal courts located in the City of Buffalo and County of Erie, New York shall have exclusive jurisdiction to adjudicate any dispute arising out of or relating to this Privacy Policy.  Each party hereby consents to the exclusive jurisdiction of such courts.  If there is any conflict or inconsistency between any provision of this Privacy Policy and any provision of any applicable law, the latter shall control.

  1. Severability

Whenever possible, each provision of this Privacy Policy shall be interpreted to be effective and valid under applicable law. If, however, any such provision shall be prohibited by or invalid under such law, it shall be deemed modified to conform to the minimum requirements of such law, or if for any reason it is not so modified, it shall be prohibited or invalid only to the extent of such prohibition or invalidity without the remainder of such provision, or any other provision of this Privacy Policy, being prohibited or invalid.

  1. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the website, along with the updated effective date. Your continued use of the website and/or purchase of products following the posting of changes constitutes your acceptance of such changes.

  1. Expenses

Except as provided in this Privacy Policy, or any applicable law, you are solely responsible for all fees and disbursements of any attorney or other advisor retained by you in connection with enforcing your rights under this Privacy Policy.

  1. Our Contact Information

If you have any questions, feedback or to report a violation regarding the Privacy Policy, or the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights as described herein, please do not hesitate to contact us as follows:


Mail: 45 Jewett Ave, Buffalo, NY 14214