Effective Date: July 30, 2026

Footsteps, Inc. (“Footsteps,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the information you provide to us, whether through our website (the “Site”), our programs and services, or direct communications with us. This Privacy Policy applies to information collected through the Site, our programs and services, and direct communications with Footsteps. This Privacy Policy does not apply to information collected through websites, applications, or services operated by third parties. This Privacy Policy explains how we collect, use, share, and safeguard information and should be read together with our Terms of Use, which govern your use of the Site.

In this Privacy Policy, “personal information” means information that identifies or could reasonably be linked to an individual.

1. Information We Collect

a. Information You Provide

We collect personal information that you voluntarily provide when you communicate with us, request information, make a donation, subscribe to receive updates, apply for a program, scholarship, or service, participate in our programs, or otherwise interact with Footsteps. Depending on the nature of your interaction with us, we may collect:

• Name
• Date of Birth
• Email address
• Telephone number
• Mailing address
• City, state, and zip code
• Donation information, including the last four digits of your credit card
• Employment, educational, career, and income information
• Citizenship status
• Information regarding family status, household information, and living situation
• Information regarding community or religious background
• Information regarding your lifestyle and recreational activities
• Information regarding criminal background
• Information relating to your participation in Footsteps programs or services
• Information you provide in scholarship or program applications
• Other information that you choose to provide

For individuals seeking services from Footsteps, we may collect additional information through telephone screenings, intake interviews, applications, and other communications. This information may include information relating to personal circumstances, educational needs, employment status, housing needs, family composition, government benefits, physical disabilities, mental health conditions, sensitive personal circumstances, or other information relevant to determining eligibility for and providing services.

For individuals receiving financial assistance, scholarships, reimbursements, stipends, grants, or other payments, we may collect payment and banking information necessary to issue payments, including account information, routing information, mailing information, and other payment-related information. 

We may maintain records of communications with you, including emails, intake notes, applications, correspondence, and notes or summaries from telephone screenings or calls, for operational, program administration, compliance, and recordkeeping purposes.

Some of the information described above, including information regarding religious background, age, gender, pronouns, sexual orientation, race, ethnicity, veteran status, physical disabilities, mental health conditions, or other sensitive personal circumstances, may be considered sensitive personal information under applicable law. Where required by applicable law, we will obtain any necessary consent before collecting or processing such information. 

b. Communications and Newsletters

If you subscribe to receive newsletters, updates, event notices, or other communications from Footsteps, we may use your contact information to send those communications. You may opt out at any time by following the unsubscribe instructions included in our emails or by contacting us.

c. Automatically Collected Information

When you navigate through and interact with our Site, we and our service providers may automatically collect certain technical information, including:

• IP address
• Referring website
• Browser type
• Operating system
• Device information
• Date/time/pages visited and usage data

2. How We Use Your Information

We use your information to:

• Respond to inquiries and provide requested services
• Connect users with Footsteps programs and resources
• Provide users with referrals to outside organizations when we do not provide the services sought
• Evaluate and administer programs, services, scholarships, and other assistance 
• Maintain member and donor records and support organizational reporting, program evaluation, and planning
• Communicate with users about updates, services, events, donations, or other opportunities
• Improve the Site and its functionality
• Comply with legal, regulatory, and operational requirements

Footsteps does not collect, use, or sell personal information for the purpose of training large language models. 

3. Sharing of Information

We do not sell personal information. We also do not share personal information for cross-context behavioral advertising or targeted advertising purposes.

We may share information:

• With service providers, contractors, and authorized reviewers that assist with our operations, programs, communications, donation processing, scholarship administration, data management, and website functionality;
• When required by law, regulation, or legal process; 
• To enforce or apply our terms of use;
• To protect the rights, safety, or security of Footsteps, its programs, participants, donors, or others; 
• In connection with a merger, acquisition, reorganization, dissolution, asset sale, financing, transfer of assets, or other organizational transaction involving Footsteps, including disclosures to prospective or actual purchasers, successors, or other transaction participants; and
• With your consent.

4. Third-Party Services

We use third-party service providers to assist with our operations and programs. These providers may include, for example, customer relationship management/database providers, online form and application platforms, email communications platforms, payment processors, banking/payment facilitation providers, website analytics providers, cloud productivity tools, and information technology service providers. These providers may process, store, or otherwise access information on our behalf.

For example, donations made through the Site are processed through third-party payment processors. Footsteps does not store complete payment card information used to make donations.

We are not responsible for the privacy practices of third-party websites, services, or platforms, and we encourage you to review their privacy policies.

5. Cookies and Tracking Technologies

When you interact with our Site, we and our service providers may use cookies, Google Analytics, and similar technologies to:

• Operate and maintain the Site
• Improve Site functionality and performance
• Understand how visitors use the Site
• Analyze website traffic, visitor interactions, and usage trends

Google Analytics may collect information about your use of the Site and may use cookies and similar technologies to facilitate that collection. You may adjust your browser settings to refuse or limit cookies, although certain features of the Site may not function properly as a result.

6. Data Security

Footsteps takes the security of personal and sensitive information seriously. We implement reasonable administrative, technical, and physical safeguards designed to protect such information, from unauthorized access, use, or disclosure. These safeguards may include access controls, multi-factor authentication, encryption and security features offered by our service providers, security testing, and use of vendors that maintain appropriate security and compliance practices. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, support our programs and operations, comply with legal obligations, maintain organizational records, resolve disputes, and enforce our agreements. Because many members and donors continue to engage with Footsteps over time, certain member, donor, and program-participant records, including information relating to household members and dependents, may be retained for extended periods, including indefinitely, to support program administration, donor relationship management, organizational reporting, and operational needs. In determining retention periods, we consider legal obligations, operational needs, reporting requirements, and the nature of the information maintained.

8. Your Choices About Your Information

You may:

• Contact us to update or correct your information.
• Opt-out of receiving marketing, newsletter, or other non-essential communications.

Please note that we may retain certain information as necessary to support our programs and operations, comply with legal obligations, maintain records, and protect our rights. You may unsubscribe from marketing or newsletter communications by following the instructions included in those communications. 

9. Children’s Privacy

The Site is not directed to children under the age of 13. We do not knowingly collect personal information from children through the Site.

In connection with our programs and services, we may receive limited information regarding children under the age of 13 from parents, guardians, or other authorized adults, including a child’s name, gender, and relationship to a participating household, when necessary to administer programs, track participation, support participating families, or maintain member records.

10. Your State Privacy Rights

Footsteps is based in the United States, and information we collect may be processed and stored in the United States. Depending on your state of residency, you may have certain rights related to your personal data. The availability and scope of these rights vary by state and may be subject to exceptions and limitations under applicable law. 

To exercise any of your state rights, please email us at the contact information at the bottom of this policy.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any updates will be posted on this page with a revised effective date. Your continued use of the Site following the posting of changes constitutes acceptance of the revised Privacy Policy.

12. Contact Us

To exercise your rights or ask questions or comments about this Privacy Policy, contact us at:

Footsteps
114 John Street, #930
New York, NY 10272 

(212) 253-0890 

[email protected]