Youth Under the Age of 13
We are a 501(c) (3) non-profit organization and are exempt from compliance with the Children’s Online Privacy Protection Act (COPPA). Nevertheless, we choose to protect the privacy of children under the age of 13 within the spirit of COPPA in a number of ways.
Youth under the age of 13 are not permitted to create accounts or share Personally Identifiable Information (“PII”) on our Sites.
If we learn that we have personal information obtained directly from a child under 13, we will delete that information as soon as possible.
1. Agreement to the Policy
2. Types of Information We Collect
We collect Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”) to facilitate the operation, funding, and management of FIRST Global programs.
a. Personally Identifiable Information (“PII”):
This refers to information that lets us know the specifics of who a person is. It includes a first and last name, title, mailing address (including zip code), email address, phone number, and to facilitate certain transactions, credit card information.
b. Non-Personally Identifiable Information (“Non-PII”):
This refers to information that does not by itself identify any specific person. Through the use of cookie technology or otherwise, we may track and collect Non-PII about your computer and software when you visit one of our Sites. This information may include: (i) your Internet Protocol (“IP”) address; (ii) your domain server; (iii) your type of computer; (iv) your type of web browser; (v) your access times; and (vi) the web sites you came from and navigate to next.
This information is anonymous information that does not personally identify you. For more information on cookies, see Section 8 below.
3. How We Collect and Use Information
a. Collection and Use of PII
We only collect PII when you provide it to us. You may provide certain PII to us when you: (a) register for any FIRST Global program or event; (b) subscribe to our newsletter; (c) send e-mail messages, submit forms, or transmit other information by telephone or letter; (d) order products; (e) submit your credit card or other payment information; (f) visit other points on the Sites that state that such information is being collected; or, (g) attend a FIRST Global event or a FIRST Global Affiliate/Operational Partner activity.
When you engage in certain activities on any of our Sites, we may ask you to provide PII by filling out and submitting an online form. Depending upon the activity, some of the PII may be mandatory and some may be voluntary. If you do not provide the mandatory PII with respect to a particular activity, you or your child will not be able to engage in that activity.
By entering personal information into FIRST Global Sites you agree to allow FIRST Global to collect, use, and disclose the information to implement, manage and evaluate FIRST Global programs and efforts, as well as to communicate with you about FIRST Global programs and efforts. FIRST Global sometimes uses third parties to help implement, manage and evaluate programs and efforts and such third parties will have access to this information strictly for these purposes under the same standards of privacy and security as FIRST Global staff. FIRST Global systems are designed to support our policy that participants (including students, coaches, mentors, and volunteers) and parents (for participants under age 18) should be the only people to modify the information we keep on them.
b. Collection and Use of Non-PII
We, or entities that provide direct service to us, may track and collect Non-PII about your computer and software when you visit a Site. This may be done at different places on that Site in several ways, including through the use of cookie technology or through other means.
We will primarily use Non-PII to: analyze and enhance the operation of our Programs and Sites, improve our marketing and promotional efforts, statistically analyze use, improve our product and service-offerings, gather demographic information, customize and improve our Sites’ content, layout, and services, diagnose problems with our servers, software, and administer our Sites, often with the assistance of our vendors.
4. How We Share Information
We do not rent or sell PII or Non-PII to others. We may share PII and Non-PII with FIRST Global Affiliate/Operational Partners and organizations who implement FIRST Global programs locally, vendors, affiliates, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate our Site, handle communications, implement, manage and evaluate FIRST Global programs, or complete transactions you request. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Sites; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.
5. How You Can Update and Correct Information
Users of our Sites have the ability to access and edit the PII they provide to us. PII may be changed by logging in to a user’s account, or by requesting a change in writing. Requests in writing should be sent to email@example.com.
Please include your name, address, and/or e-mail address when you contact us regarding an update or correction to PII. We reserve the right to confirm your identity before updating or correcting PII. We encourage you to promptly update your PII if it ever changes.
6. Your Choices on the Collection and Use of Information
We may, from time to time, send you e-mails regarding our programs and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and select third parties, we may occasionally send you direct mail about programs and services that we feel may be of interest to you. Only FIRST Global (or permitted agents working on behalf of FIRST Global and under confidentiality agreements) will send you these direct mailings, and only if you indicated that you do not object to these offers.
If you do not wish to receive information or other material from us, you may “opt-out” of receiving these communications by sending us an e-mail at firstname.lastname@example.org.
You also have choices with respect to cookies, as described below in Section 8. By modifying your browser preferences, you generally have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Sites may not work properly.
7. How We Protect Information
We use current industry standard, security measures to protect your PII. Access to PII is available through a unique customer ID and password selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your PII resides on a secure server to which only select FIRST Global personnel and Service Providers have secure access.
You may opt to display PII in Volunteer, Team Registration, blog, or forum areas of the Site. PII submitted to these areas can be read, collected, or used by other users, and could be used to send you unsolicited messages. We are not responsible for the PII you choose to submit in these areas. You are solely responsible for maintaining the confidentiality of your password and account information. Please be careful and responsible whenever you are online.
In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third-party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order. For security, this information is encrypted during communication.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. While we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations of the Internet that are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through our Sites cannot be guaranteed; and, (c) any such information and data may be viewed or tampered with in transit by a third party.
When you use any of our Sites, we may store cookies on your computer in order to facilitate and customize the experience. A cookie is a small data text file, which a web site stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your log-in name to welcome you back to a Site. Our cookies: (a) make your use of our Sites easier; (b) make our Sites run more smoothly; (c) track authenticated users visiting our Sites; and, (d) help us to maintain secure Sites. You are always free to decline our cookies if your browser permits, but some parts of our Sites may not work properly in that case. Once you close your browser, the “cookie” disappears.
We may use an outside company to display information on our Sites. As part of their service, they will place a separate cookie on your computer. Except as provided herein, we will not provide any third-party with any of your PII or information about your transactions with or through FIRST Global. We and third-parties we hire will collect and use Non-PII about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to particular information.
9. Privacy Policies of Third-Party Sites
We may authorize links to any part of one or more of our Sites from other nonprofits, government agencies, and others who wish to help extend our mission. We ask that you contact us to let us know of your intentions to link to one or more of our Sites, and indicate the purpose of the link. No link may present or display a product or activity in a way that states or implies endorsement by FIRST Global. FIRST Global does not endorse any commercial organizations, candidates for elected office, or products.
FIRST Global Sites feature links to other organization sites including those of our sponsors. We do not routinely “out-link” to private, commercial or other similar web sites, other than current sponsors of programs and services offered by FIRST Global. However, on a case-by-case basis, we will consider requests from such groups or persons to out-link to their web sites. FIRST Global will grant such requests only where it is determined that such links will clearly support our mission and where we have concluded that such links will not in any way jeopardize our reputation, independence, objectivity, or mission.
From time to time, FIRST Global may unilaterally decide to out-link to private, commercial, or other web sites. The same criteria described above will apply. FIRST Global reserves the right to remove any such links at any time.
10. Your Use of Our Training Materials, Forums, Blogs, and various Social Media
For the educational use of our members, FIRST Global offers online training materials. The training materials contain original and copyright-protected works of FIRST Global and others. Our Sites also contain forums where training materials are posted and where users may submit their own comments, opinions, and images (“Submissions”).
By making a Submission to, or through one of our Sites, training materials, related forums, or blogs, you grant FIRST Global an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, blog, publicly perform, transmit and distribute such Submission, alone or as part of other works, in any form, media, or technology whether now known or hereafter developed.
You warrant and represent that you shall not transmit, post or upload any Submission that is, in whole or in part, libelous, scandalous, inflammatory, discriminatory, defamatory, false, threatening, vulgar, obscene, pornographic, profane, abusive, harassing, invasive of another’s privacy, hateful or bashing, aimed at gender, race, color, sexual orientation, national origin, religious views or disability, or otherwise unlawful, or that violates or infringes on the privacy, publicity, intellectual property, proprietary, or contractual rights of any person or entity. By posting the pictures of others, you warrant and represent that you have those persons’ (or if the person is under the age of majority, the person’s parent or guardian’s) consent.
You agree to defend, indemnify, and hold harmless FIRST Global, its directors, officers, employees, agents, and sponsors from and against any claims, actions or demands, including, without limitation, reasonable legal and accounting fees arising out of, or resulting from, your use of our Sites or the services made available on or through our Sites, and/or your breach of this User Agreement.
FIRST Global does not warrant or represent the truthfulness, accuracy or reliability of any content, information or material contained in any Submissions. Your reliance on any Submissions shall be at your own risk.
Users of our training materials, Sites and related forums agree at all times to abide by legal protections and a professional honor system. Users agree that in downloading, using or referring to the contents of any document included in the training materials, Sites or related forums (whether in writing or verbally), they will give full attribution to the author.
12. Special Notification for California Residents
Users who reside in California and have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at email@example.com. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
13. Privacy Issues Specific to Children Under 13
FIRST Global is particularly aware of privacy issues specific to the collection of personal information of children under the age of 13. FIRST Global does not collect data directly from youth under age 13. If we become aware that a child under age 13 has shared PII on our Sites, we will delete the data and deactivate the associated account.
This section applies to all donor-related information received by FIRST Global, both online and offline, from any donor.
Unless authorized by the donor or mandated by law, FIRST Global will not sell, share or trade our donors’ names or personal information with any other entity, nor send mailings to our donors on behalf of other organizations. The only exception would be if the donor notified us that the donor’s employer will match the donation and the donor requests that we reach out to obtain the matching gift, in which case we may disclose the donor’s contact information (name, postal address, email address and telephone number) and donation information (donation amount and supported projects) to the employer. We are not responsible for the privacy practices of donors’ employers. For more information regarding the handling of information by an employer, please refer to the employer’s privacy policies.
To the extent donations are processed through a third-party service provider, our donors’ information will only be used for purposes necessary to process the donation.
15. How to Contact Us
325 Commerce Street
Alexandria, VA 22314