FIRST GLOBAL PRIVACY POLICY

FIRST Global takes your privacy seriously.  As a nonprofit and a mission-driven youth-serving organization, we are compelled to understand who we are serving, how our programs are performing, and make improvements so that we can achieve our goals of making FIRST Global accessible to youth who want to be part of the fun, exciting and life-changing experience. Thus, we need to collect certain pieces of data from you to ensure we are meeting our goals and responsibilities as a youth-serving nonprofit organization.

 

This FIRST Global Privacy Policy describes how FIRST Global (“FIRST Global,” “our,” “we,” “us,”) collects, uses and protects the personal data that users (“user,” “your,” or “you”) provide to us at any of our web sites where this Policy is posted (the “Sites”). This Privacy Policy also applies to personal data which FIRST Global obtains by other means, as described below.

TREATMENT OF DATA FOR MINOR YOUTH

We are a 501(c) (3) non-profit organization and are exempt from compliance with the United States Children’s Online Privacy Protection Act (COPPA).  Nevertheless, we choose to protect the privacy of children under the age of 13, residing outside of the European Union, within the spirit of COPPA, and those residing in the European Union as provided by the European Union General Data Protection Regulation (GDPR).

 

Youth under the age of 13 residing outside of the European Union, and under the age of 16 for youth residing in the European Union, are not permitted to create accounts or provide personal data on our Sites.

 

If we learn that we have personal data obtained directly from a child under 13 who resides outside of the European Union, or under 16 for those residing in the European Union, we will delete that data as soon as possible.

1. AGREEMENT TO THE POLICY

By accessing or using any of our Sites, you agree to be bound by all of the Site’s terms and conditions including this Privacy Policy. If you do not agree to these terms and conditions, please do not access or use any of our Sites.

2. WHAT PERSONAL DATA DOES FIRST GLOBAL COLLECT:

FIRST Global collects the following personal data for the uses explained in section 4:

Name, mailing address, email address, phone number, date of birth, gender, race, ethnicity, employer, allergies, dietary restrictions, your affiliations with FIRST Global partners, FIRST Global Alumni status, FIRST Global program history, secondary or emergency contacts, credit card information, and your Internet Protocol (“IP”) address.  For youth participants, we also collect data on grade in school, graduation data, school name, and school identification number. (FIRST Global does not collect race or ethnicity data from residents of the European Union.)

3. HOW DOES FIRST GLOBAL COLLECT THE DATA:

We collect data when you provide it to us directly or indirectly through a third party and by “cookies” (as described in section 8, below). You may provide certain data 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) access certain forms or request information on our Sites; (g) visit other points on the Sites that state that such information is being collected; (h) attend a FIRST Global event or a FIRST Global Affiliate/Operational Partner activity; (i) apply for a grant through a third party vendor; (j) register for housing for a FIRST Global event or for the FIRST Global Challenge through a third party vendor; (k) complete a paper consent and release form; and/or (l) make a donation to FIRST Global.

 

When you engage in certain activities on any of our Sites, we may ask you to provide data by filling out and submitting an online form. Depending upon the activity, some of the data may be mandatory and some may be voluntary.  If you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity.

4. HOW DOES FIRST GLOBAL USE THE DATA:

By entering personal data into FIRST Global Sites or providing it to FIRST Global (directly or indirectly through third parties), you agree to allow FIRST Global to collect and use the data for the following purposes:

 

  1. To register you as a FIRST Global program participant or volunteer.
  2. To manage events: We and our local FIRST Global representatives (FIRST Global Affiliate and Operational Partners, Regional Directors, and organizations who implement FIRST Global programs locally) use personal data to identify your region for program participation, event registration, badging, volunteer management and general event management.
  3. To ensure the safety of FIRST Global participants: FIRST Global contracts with certified background screening agencies to conduct background screening on volunteers and staff. To conduct background screening, these agencies use your personal data and secure all data collected according to the process outlined on their privacy policy.  FIRST Global may receive the last 4 digits of your social security number (if provided), name, and screening status and uses this data only to determine eligibility to volunteer in any role at FIRST Global and may keep this data in a secured file.
  4. To communicate with you as a participant in FIRST Global programs: FIRST Global uses personal data to communicate with you about FIRST Global program information and related opportunities.
  5. e. To process transactions:  FIRST Global uses personal data to engage in interactions with you including to communicate with you about your registration status, payment of team registration, processing of sponsorship information, newsletter subscriptions, event information and to process orders, registration fees or donations.
  6. To provide support or other services: FIRST Global uses personal data to provide you with support or other services that you have requested.  We may use your data to respond directly to your requests for information including registering for newsletters, registering a FIRST Global team, registering for trainings or webinars and other specific requests.  We may pass your data along to the appropriate local FIRST Global representative in your geographic area to respond to your request.
  7. To improve our programs, products and services: FIRST Global uses data to evaluate and improve our programs, understand who we are serving, assess program impact, report aggregate/de-identified data, monitor growth, improve the delivery of FIRST Global programs, improve our marketing and promotional efforts, improve our product and service-offerings, 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. FIRST Global sometimes uses third parties to help implement, manage and evaluate programs and efforts, and may share personal data with those third parties only for the purposes outlined in this policy.
  8. To improve quality and facilitate use of our Sites. FIRST Global may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies, to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of our Sites (for example, to facilitate navigation and the login process, enhance security, and preserve order information between sessions).
  9.  To solicit donations for FIRST Global or local FIRST Global organizations.
  10. To assist with travel to FIRST Global events: FIRST Global may provide assistance with travel arrangements to events, including to the FIRST Global Challenge.  Personal data including your name, gender, date of birth and passport information may be required to process visas and manage your travel arrangements to events.

5. HOW LONG DOES FIRST GLOBAL RETAIN DATA:

FIRST Global will retain your data for as long as needed or permitted to fulfill the purposes and uses described in this Policy. When we no longer need your data, and there is no need to keep it to comply with our legal obligations or protect our legal rights, we will either delete it from our systems or depersonalize it so we cannot identify you.

6. HOW DOES FIRST GLOBAL SHARE DATA:

FIRST Global does not rent or sell data to others. We may share personal data through secure data processes with local FIRST Global representatives (FIRST Affiliate/Operational Partners, Regional Directors, and organizations who implement FIRST Global programs locally), employers (when permission is given), vendors, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate our Sites, handle communications, implement, manage or evaluate FIRST Global programs and events, 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 order; and provide order information to third parties that help us provide customer service.

 

Any Service Provider who has access to personal data is required to protect this information in a manner that is consistent with this Privacy Policy and may not use it for any purpose other than to carry out the services they are performing for FIRST Global.

 

Except as otherwise provided in this Privacy Policy, FIRST Global will keep your personal data private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with the law or legal process served on us; (b) provide you the products, services and/or information that you may have requested; (c) protect our rights or property; (d) enforce our rights; (e) protect the interests of users of the Site or any other person; (f) operate or conduct maintenance and repair of our equipment; (g) detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law; and/or (h) otherwise comply with applicable laws.

7. HOW DOES FIRST GLOBAL PROTECT INFORMATION:

FIRST Global uses technical and organizational measures to protect data including, but not limited to: conducting third-party security audits, firewalls, maintaining security patches on external systems, a log auditing system to identify breaches, and ensuring that all web connections are over HTTPS.  Access to personal data is available through your user identification and password selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone and no one at FIRST Global or who represents FIRST Global will ever ask for your password. In addition, your personal data resides on a secure server to which only select FIRST Global personnel and Service Providers have secure access.

 

You may opt to display personal data in community-based sites such as Forums, Team/Event Finders and FIRST Global social media sites (e.g., Facebook, Twitter, Instagram, Linked-In, Snapchat, Twitch). Personal data 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 personal data you choose to submit in these public areas. You are solely responsible for maintaining the confidentiality of your password and account information. Please be careful and responsible whenever you are online.

 

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.   While we strive to protect your personal data, 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.

8. COOKIES:

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 website 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. You can at any time use your browser setting to delete cookies from your system. 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 personal data about your transactions with or through FIRST Global. We and third parties we hire will collect and use data 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 POLICY OF THIRD-PARTY SITES:

We may maintain links to other websites on our Sites. Links to alliances and sponsoring organizations are examples of these links. This Privacy Policy only applies to FIRST Global.  Other sites accessible through our Site have their own privacy policies and data collection use and disclosure practices.  Please consult each site’s privacy policy.

10. YOUR USE OF OUR TRAINING MATERIALS, FORUMS, BLOGS, AND VARIOUS SOCIAL MEDIA:

FIRST Global may offer online training materials.  The training materials may 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, blogs, or FIRST Global Media, you grant FIRST Global an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, blog, publicly perform, transmit and distribute such Submission (except to the extent it contains personal data), 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 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 Privacy Policy.

 

FIRST Global does not warrant or represent the truthfulness, accuracy or reliability of any content, information or material contained in any Submission.  Your reliance on any Submission 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.

11. HOW YOU CAN RECTIFY INCORRECT INFORMATION:

You have the ability to access and edit the personal data you provide to us. Data may be changed by logging into your FIRST Global user’s account, or by requesting a change in writing.  Requests in writing should be sent to info@first.global.

 

Please include your name, address, e-mail address, and/or phone number when you contact us regarding an update or correction to data.  We reserve the right to confirm your identity before updating or correcting personal data. We encourage you to promptly update your personal data if it ever changes.

12. HOW YOU CAN OBJECT TO CERTAIN USES OF YOUR DATA:

We may, from time to time, use your name or email to send you information regarding our programs, services and related opportunities as outlined in section 4.

 

If you do not wish to receive email from FIRST Global you may “opt-out” of receiving these communications by exercising your right to “opt out” by using the unsubscribe feature in the email or sending us an e-mail at info@first.global.

 

You also have choices with respect to cookies, as described 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.

13.  HOW YOU CAN EXERCISE YOUR RIGHT TO BE FORGOTTEN:

You may request that your personal data at FIRST Global be deleted, by emailing info@first.global.  You will need to provide your name, email address and/or phone number at the time of your request.  We reserve the right to confirm your identity before taking any action to delete your data. FIRST Global will assess each request to be forgotten on a case by case basis to determine the extent to which data can be deleted.  In some cases we will remove personal data from your record but may retain de-identified information using processes such as pseudonymization.  In some cases, such as when data has been collected as part of the Consent and Release forms or youth protection screening, personal data cannot be deleted.

14. HOW YOU CAN EXERCISE YOUR RIGHT TO DATA PORTABILITY:

You have the right to receive a copy of the personal data you have provided to FIRST Global in a machine readable format by emailing info@first.global.

15. TRANSFER OF DATA TO OTHER COUNTRIES:

Because we are a global organization, FIRST Global may share your personal data with FIRST Global representatives (FIRST Global Affiliate/Operational Partners, Regional Directors, and organizations who implement FIRST Global programs locally) in other countries in order to carry out the activities specified in this policy. By submitting your personal data to FIRST Global through FIRST Global Sites, or in connection with your interactions with FIRST Global offline, you consent to such transfers and to the processing of this information in other countries.

16. SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS:

Users who reside in California and have provided their personally identifiable information to us may request information about our disclosures of certain categories of personal identifiable information to third parties for their direct marketing purposes. Such requests must be submitted to us at info@first.global.  Within thirty days of receiving such a request, we will provide a list of the categories of personal identifiable 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.

17. FIRST GLOBAL DONOR PRIVACY POLICY:

This section applies to all donor-related information received by FIRST Global, both online and offline, from any donor.

 

FIRST Global collects and stores donor information including name, address, email address, phone number, and donation amounts. Unless authorized by the donor or mandated by law, FIRST Global will not sell, share or trade our donors’ personal data 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.

18. CHANGES TO THIS PRIVACY POLICY:

We reserve the right to change this Privacy Policy at any time.  Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, posting the revised Privacy Policy at any of our Sites. You acknowledge and agree that it is your responsibility to review the Site you are using and this Policy periodically, and to be aware of any modifications.  Your continued use of a Site after any such modifications will constitute your; (a) acknowledgment of any modified Policy; and (b) agreement to abide and be bound by any modified Policy. To the extent that any modifications to this Policy materially alters how FIRST Global will use information collected under prior version of the Policy, FIRST Global will provide you notice by email using your email on file, and where required by law, will obtain your consent.

19. HOW TO CONTACT US AND HOW TO LODGE A COMPLAINT:

If you have any questions about this Privacy Policy, the practices of any of our Sites, or your dealings with any of our Sites, contact us via email info@first.global or by sending a letter to:

 

FIRST Global
325 Commerce Street
Alexandria, VA 22314
info@first.global

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