Basic CCA Privacy Policy Statement

Clan Crawford Association (CCA) is committed to maintaining strong and meaningful privacy protections for members & participants. Our privacy policy is designed to inform you about the information we collect, how we use it, and your options about certain uses of information.

The Clan Crawford Association's privacy policy applies to website visitors, Crawford DNA participants, Heraldry Project participants, members of the CCA and contributors to our blogs and newsletters worldwide. We keep only those records necessary to the implementation of the Clan Crawford Association, legal commitments and IRS tax related requirements as a non-profit organization, our projects and the website.

When people leave a project or membership, most of their data is removed, though we may keep basic contact information for them (name, mailing and e-mail address and phone number) as history of their affiliation. The exception would be if someone requested in writing to have all information removed, in which case their account would be closed and all personal identifying information deleted.

In no case, do we ever provide or sell personal information, or even make personal information, including e-mail address available, without member consent or when it is understood as a necessary part of the transaction being requested. We may use aggregate information for reports on our membership or projects, but these do not disclose personal information.If you would like to read further, we describe in detail the Privacy Policy for the Clan Crawford Association and its various components.

Information we collect and how it is used

We collect and use information when you become a CCA member, when you join the Crawford Surname Y-DNA project, when you request to participate in the heraldry project, and/or when you visit our website. This information is used to manage access to members only files, provide expertise and recommendations for individuals seeking information about Crawford history and genealogy; establish and maintain member accounts and CCA billing records; contact you about your pedigree, coat of arms, or DNA results; and monitor website statistics. Information may also be aggregated or de-identified for annual reports and scientific uses.

Except as explained in our Privacy Policy, CCA does not sell, license or share information that individually identifies our members or participants with others outside of CCA, without your written consent or as a necessary aspect of a process you are engaged in. CCA may share certain non-personally identifiable information with outside universities or other projects, for example, to assist with connecting current genealogy and DNA results with other surnames and historic documents or ongoing research. Because we receive income for memberships and any project related fees via PayPal, we don't have access to credit card or bank personal information, and personal checks do not provide any personal information that is not already shared by other means.

Information regarding donations will remain private unless the donor would like and specifies by written communication (letter or e-mail) that he/she/they would like public recognition for their donation, in which case, this acknowledgement would most likely be made in the Newsletter and contain only such information as the donor agrees to make public.

Information security

CCA has technical, administrative and physical safeguards in place to help protect against unauthorized access to, use of, or disclosure of member and DNA information we maintain. Only authorized officers have access to any member information, thus the system is secure and not susceptible to hacking. Since we do not use credit cards, account information in our records are safe, with little attraction for hackers. 

You may correct inaccuracies in your information concerning your membership, depending on the context, by accessing your online account(s) and updating your information, or by calling or e-mailing the CCA Secretary(s).

Accessing and updating your information

If you need to update heraldry information, you should contact Raymond (raymond@crawfurd.plus.com) or Allen (allen@allencrawford.net) for changes.

Contact Y-DNA Project Administrators regarding any issues with the custom Y-DNA report on the CCA website by e-mailing them: Dave (nicolsoncrawford@gmail.com) or Bruce (argyll.crawford@gmail.com).

CCA Newsletter

The CCA Newsletter is an internal publication of the Clan Crawford Association, provided to members, with past issues accessible to them as part of their membership for as long as they remains members. Information published in the CCA Newsletter will include author information (name and e-mail). Otherwise, information is not available outside the Association. Responsibility for the content of an article ultimately resides with the author, as does the copyright rights to its contents. However, the Newsletter editors reserve the right to determine appropriateness for publication, and whether an article will be accepted for publication is the sole decision of the editorial staff of the CCA Newsletter. The Newsletter is a service to the membership and generally contains information of interest to Crawfords and articles and notifications pertinent to our clan and house. The most recent issue may be made available to none-members, usually posted for limited time on the website ABOUT page. Personal information, unless very pertinent to an article, is not available for distribution or use by any other person or entity, except by the subject’s written permission.

CCA Website

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from clancrawfordassoc.org (the “Site”).

Personal Information We Collect:

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site including applications for membership, we collect certain information from you, including your name, mailing address, shipping address, email address, and phone number. We refer to this information as “Order Information”. Payment information is collected by PayPal and as such the Site does not directly collect or store payment information.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How Do We Use Your Personal Information?

We use the Order Information that we collect generally to fulfill any orders or applications placed through the Site (including arranging for shipping and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We may also use information collected to target marketing campaigns to you based on your visit history.

Sharing Your Personal Information:

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Drupal to power our website--you can read more about how Drupal uses your Personal Information here: https://www.drupal.org/privacy. We also use CiviCRM to manage data relating to our members – you can read more about how CiviCRM uses your Personal Information here: https://civicrm.org/privacy-policy. We use PayPal.com to handle payments for any aspects of the Site and therefore PayPal.com will collect and handle your payment information, you can read more about how PayPal uses your Personal Information here: https://www.paypal.com/au/webapps/mpp/ua/privacy-full.

We may share your Order Information with partner suppliers to fulfill your order. This will not include payment information but may include your name, shipping address, e-mail address, and phone number if required.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-d....

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/persona...

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

We Do Not Track:

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Your Rights:

If you are a visitor to the Site, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

The overall CCA privacy policy meets European requirements, as the most stringent. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests as addressed within the privacy policy. Additionally, please note that your information may be transferred outside of Europe, including to Canada and the United States.

Data Retention:

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. They are securely stored with no pubic access.

CCA Heraldry Project

The Clan Crawford Association Heraldry Project is a unique and novel program that allows an individual to receive assistance in designing a coat of arms of his/her preference. As part of the process, basic information is collected at the time of ordering that provides contact with the person ordering the coat of arms. After the coat of arms is completed, we ask the individual to participate in a questionnaire whose arms and heraldic information is included in an Armorial Register containing the Crawford arms. The information included in the Clan Crawford Armorial Register, will consequently be in the public domain.

Since the information in the Armorial Register will be in the public domain, the applicant will have the opportunity to say whether he/she is willing to discuss further genealogical or DNA information with others on an individual basis. In other words, if a researcher particularly wants more information about the family of somebody on the Armorial Register, the person on the Register should indicate on the questionnaire whether they would be willing to receive a request from a researcher or from somebody who might want to know if he/she was a relative. One of the aims of the questionnaire is to coordinate with the Y-DNA project in identifying those belonging to the same lineages, so we hope you will agree to placing some of your family history on the Register. Should you want to be removed from the CCA Armorial Register, you may do so at any time.

CCA Partnership with FamilyTreeDNA.com

Individuals who are interested in following their ancestral DNA paths have three popular approaches to finding relatives and historic connections. The first method, which is very popular at present, is to have one’s autosomal DNA tested for family connections on both the father and mother’s side. This is advertised often on TV and magazines from companies such as “23 and Me” and “Ancestry.com”. For Family Tree DNA (to be referred to as FTDNA) this is termed “Family Finder”. The second method is to have one’s mitochondrial DNA tested which follows the female line back through time but is less useful for following lineages in a patrilineal society such as those descended from Scotland. The most useful at present, and the testing that we encourage, is evaluating Y-DNA from the male Y chromosome. CCA has partnered with Family Tree DNA (FTDNA) to assist in managing the Crawford Surname Project. Individuals who have taken Family Finder (autosomal), mitochondrial (mtDNA) or Y-DNA, can and do join the Crawford Surname Project.

CCA is dedicated to helping individuals who have joined the FTDNA Crawford Surname Project by providing services to help connect individuals with others who share a common lineage, and to make recommendations about future testing that may reveal more information about your lineage and its historic context.

Our administrators are strictly volunteers, and are not reimbursed in any way for their efforts on your behalf. Their only rewards are seeing new lineages identified, and sharing new science-based insight into the variety of Crawford lines. Recent law enacted in the European Union (General Data Protection Regulation, {GDPR}) has affected all companies and organizations that handle information about an individual’s DNA data or other personal information. As a result, strict new rules have been implemented and agreed to by CCA administrators.

Group Project Administrators Requirements:

FTDNA allows only identified Crawford surname project group administrators to have access to portions of your private information. To have access, they must agree to the following:

Administrator Information:

i. On the Crawford surname project pages, we are required to display the first and last name the administrators use to communicate with project members.

ii. We must keep their e-mail addresses current. If the e-mail address changes, we are required to update information as soon as possible, preferably within a few days.

iii. A list of all administrators, along with their groups, will be displayed publicly, as administrators may be able to view project members’ matches who are not members of that project.

iv. To view this information, follow this link to the surname project website at FTDNA: https://www.familytreedna.com/groups/crawford/about.

Crawford Surname Member Information:

All members of the Crawford surname project must be visible to each other, as is required by GDPR, when logged in to the project membership list.

Family Tree Hosted Group Platform and Pages

Crawford Surname Project Administrator Pages:

FamilyTreeDNA (FTDNA) provides to all Crawford administrators the Group Project Administrator Pages (GAP), a web-based interface for accessing and managing members’ results. Use of the GAP is limited to authorized individuals only. Personal data is only accessible through the GAP, particularly e-mail addresses and/or other identifying or personal information cannot be shared with other members of the project or with any other individuals without the member’s express written consent.

An important administrator feature in GAP is the ability of the administrators to group members’ results into subgroups. This feature allows administrators to organize member results in a manner that helps members see how they fit into the project, in what lineage they may belong, and how they may relate to known historic houses or persons. This tool is very valuable for the participants and the work of the administrators provides free labor and expertise to Family Tree and to the surname members.

Externally Hosted Group Project Pages:

CCA maintains an externally hosted separate dataset of participants’ Y-DNA results on the CCA website, that includes more information than FTDNA has and can provide (as noted above). CCA acknowledges that FamilyTreeDNA is not responsible or liable for any member information we share outside of FTDNA’s “myGroups” pages, and assumes that risk in order to better serve our participants. FTDNA requires us to conform to the following:

1. CCA acknowledges that we are required by FTDNA to:

   1. Conform to the FamilyTreeDNA privacy assurances;

   2. Specify on our website and in reports that the information is from FamilyTreeDNA;

   3. Regularly update lineage information being displayed, noting the date of our last update to the results;

   4. Promptly update the information of any project member that changes their privacy and sharing settings;

   5. Promptly remove member information upon their exiting the Crawford Surname Project or upon a direct request from the member to remove such information within the 30 days required by the GDPR, but preferably within 24 hours. Note, though, that information in previously published reports (e.g., articles in the distributed CCA Newsletter) cannot be un-published.

2. We commit that any information shared outside of FamilyTreeDNA will never:

   1. Include “guarded” DNA results such as the mtDNA Coding region, Factoids, and My Origins results; and/or

   2. Show any additional Genetic Information not already shown on the FTDNA myGroups pages without the express written consent from that project member. This will include information obtained by the individual tester from YSEQ.net, YFull and any other source of information about SNPs and personal SNP variants.

Administrator Access Levels:

You are in control of what information from your FTDNA account and tests is displayed on the reports in the project’s pages on the FTDNA site (including whether your information is publicly visible or only visible to other project members), and what may be included in our more involved Y-DNA reports on the CCA website & newsletter articles. The Y-DNA reports on the FTDNA website generally include kit number, last name, most distant known ancestor, country of origin, and the STR and SNP data from any FTDNA tests you may have ordered. The Y-DNA reports on the CCA’s “members-only” DNA pages generally include the same information, but also initials, and any Y-DNA test results from other companies that you submitted to the project administrators (see also below).

Your control over the display of your information is through your Settings in your FTDNA account after you have logged in to it, under “Privacy and Sharing” (for opting in/out of matching & sharing) and under the tab “Project Preferences” (for specifying access permissions for project administrators). The latter can be set for individual administrators or all administrators of the project, and provides three access level options: Minimum, Limited, and Advanced. The default setting when joining projects is Limited (and you can set your own default for all future project joins, as well).

If you choose “Minimum,” the administrators have only the access required to manage the project. They do not have access to your individual FTDNA pages, such as your Y-DNA matches, and cannot easily help you with DNA recommendations. This option is not recommended.

If you choose “Limited,” the administrators can visit your personal FTDNA pages to view genetic information & matches, along with certain personal information that may support project research and lineage identification. This will enable the administrators to help evaluate your lineage and provide recommendations. We are recommending every participant in the Crawford surname project allow administrators “Limited Access,” since that is the only way the CCA administrators can easily help with your genealogical research.

If you choose “Advanced,” our CCA Crawford surname group administrators will be granted the ability to manage your account, including but not limited to, ordering tests for you and modifying personal information. We do not normally need this kind of access but for some situations, it may be a necessary or desirable option. This option is not recommended outside of special circumstances, such as in the case of incapacitation of the kit owner.

Upon joining any project at FTDNA, you will have to agree to FTDNA’s terms for project participation. By joining the Crawford project, you are also agreeing to participate in helping each other in the project make genealogical connections. This should mean that you are willing to communicate and share pedigree information with others in the project and are willing to allow others to communicate and share their pedigree information with you who share a common lineage or are identified as a match based on STR or SNP data.

Group Project Administrator Use of Projects and Member Information

Administrators of a project agree to never:

1. 1. Share their administrator username or password with anyone, not even another administrator.

   2. Compromise the pseudonymization (i.e., use of kit numbers or other alphanumeric sequences) of the DNA test results of any project member.

   3. Use the Join Request feature for any other purposes than solely accepting a request for someone to join your project or explaining the criteria to join your project. The requester’s e-mail address should not be used for any other purpose.

   4. Use a DNA project to advocate a personal or political agenda or to promote a business or commercial interest.

   5. Use FamilyTreeDNA resources such as member lists, group pages, or bulk e-mail to promote or advertise competitors.

   6. Reverse engineer, hack, scrape, or otherwise attempt to exploit real or potential security flaws in the website.

   7. Change the name of the Group Project without permission from FamilyTreeDNA.

   8. Charge a fee for participation in the group project or access to a project website. It must be clear to members that they do not have to belong to the family association to be in the project, if the project is sponsored by a family association that charges a fee. Those members who are not in the family association must be treated the same as those who are.

   9. Use foul, demeaning, objectionable, defaming or discriminatory language when addressing project members, other administrators, FamilyTreeDNA employees, or when referring to FamilyTreeDNA products.

Administrators agree to never use their access to member data to:

1. 1. Publicly display, share, or change the contact information of any project member without explicit permission from the member.

   2. Share results with administrators of group projects of which the tester is not a member.

   3. Publish research or information that may disclose or identify a member’s personal information without the express written consent of the person tested. .

   4. Store any member’s e-mail address in the same file as their test results per GDPR requirement.

   5. Use member information or research for any commercial purpose without express written consent.

   6. Use member information or e-mail address to send any correspondence unrelated to the project.

   7. Post guarded DNA results to a public website or otherwise make them public. Guarded DNA results include mtDNA Coding Region results, Factoid results, and myOrigins results.

Member Information prohibited from being shared or displayed include:

1. 1. Full names (first and last or first, middle, and last)

   2. Kit numbers with full names

   3. E-mail addresses

   4. Physical or mailing addresses

   5. Phone numbers

How CCA Protects Your Privacy:

1. All reports shown on the publicly available Y-DNA tab of Clan Crawford Association follows the “my Groups” format of the FTDNA and directly links to their database.

2. If you are a member of the CCA, you have access to a “members only” page. That page contains the following Y-DNA information:

   1. FTDNA kit number;

   2. Last name and initials of the individual. Some individuals are listed on the CCA website who provided their Y-DNA information directly to CCA and it is not available to FTDNA.

   3. Most Distant Known Ancestor;

   4. Country of Origin;

   5. List of all known or reported SNP tests taken or pending whether the information was prepared by FTDNA or a different laboratory;

   6. Haplogroup clade and most recent “terminal” SNP tested;

   7. Lineage SNP’s position on the Y-SNP tree;

   8. STR results up to 111 loci, with mutations shown in color;

   9. Mutation rate for each locus.

3. The page also contains written reports and comparisons of lineages not available to non-members. You do not have to be a member to access the general Y-DNA surname project public page or to participate in the surname project or receive help and assistance from the Administrators.

How CCA Uses Your Information:

1. Evaluates DNA matches using statistical tests identified under our CCA protocols to find and combine new lineages or create new additions to existing lineages.

2. Provides relevant updates to the members on the latest developments in connecting paper genealogical trails from known ancient Crawford lineages in Scotland with DNA information from members worldwide.

3. Identify individuals who have joined the Crawford Y-DNA project but who have no direct paternal-line ties to Crawford. These individuals may have maternal or other connections and are placed in a category ZZZ so that their DNA is not mistakenly evaluated with known Crawford Y-DNA.

4. Some individuals have voluntarily provided their GEDCOM or other paternal lineage genealogical information to CCA. This information is not available to the public but is available only to CCA members.

Aggregate Information:

The DNA administrators periodically provide reports about all or some lineages updating the extent of knowledge that has been accumulated over the life of the surname project. Information that has been combined with that of other Crawford surname members will be utilized such that any charts or comparisons will only use kit numbers and/or initials as a pseudonym to identify specific individuals in phylogenetic trees or discussions.

How CCA Shares Your Information:

CCA does not share your DNA information with anyone else, be they commercial companies, medical groups, law enforcement, non-profit organizations, etc. Occasionally some aggregated reports may be shared with university researchers who have interest in the historic role of our Crawford ancestors in Scotland’s history. No individual or personal information is provided with aggregated reports.

If you choose to leave the Crawford project, any personal information, including DNA data, CCA has on file will be removed (although, as noted above, any information previously published cannot be un-published). Crawford group administrators are notified by e-mail from FTDNA when someone leaves the Crawford project.

Thank you for your interest in the Clan Crawford Privacy Policy,

CCA Executive Committee & Board

[Executive Committee aproval obtained 9/15/18; Board approval obtained 9/30/18]