Last Review and Update: April 15, 2014
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.
If you are under the age of 13, you need your parent’s permission to use our Sites. Unless we receive your parent’s verifiable consent you may not provide us with any personal information (such as name, address, telephone number, email address, picture of yourself) on any of our Sites.
If we learn that we have personal information obtained from a child under 13 without the required parental consent, we will delete that information as soon as possible.
For more information on how FIRST addresses the privacy of children under 13, see Section 13 (Privacy Issues Specific to Children under 13) below.
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 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 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 event or a FIRST affiliate 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 Sites you agree to allow FIRST to collect, use, and disclose the information for the management of FIRST programs and efforts, as well as to communicate with you about FIRST programs and efforts. FIRST sometimes uses vendors to help manage programs, efforts, and communications, and such vendors will have temporary access to this information strictly for the conduct of FIRST programs or activities under the same standards of privacy and security as FIRST staff. FIRST 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 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 vendors, affiliates, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate our Site, handle communications, conduct FIRST 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 customerservice@usFIRST.org.
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. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions that have taken place on any of our Sites. In addition, it may be impossible to completely delete your information without some residual information because of backups.
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 (or permitted agents working on behalf of FIRST 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 customerservice@usFIRST.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 that only selected FIRST personnel and Service Providers have access to via a password.
You may opt to display PII in Volunteer, Team Contact, Team Up, Jr.FLL Showcase, Alumni Community 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. 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. FIRST does not endorse any commercial organizations, candidates for elected office, or products.
FIRST 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. However, on a case-by-case basis, we will consider requests from such groups or persons to out-link to their web sites. FIRST 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 may unilaterally decide to out-link to private, commercial, or other web sites. The same criteria described above will apply. FIRST 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 offers online training materials. The training materials contain original and copyright-protected works of FIRST 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 World Tube, you grant FIRST 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, 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 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 customerservice@usFIRST.org. 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 is particularly aware of privacy issues specific to the collection of personal information of children under the age of 13. In connection with children under the age of 13, this policy explains:
a. The kinds of personal information FIRST collects (see Section 2);
b. How such information is used (see Section 3); and,
c. How such information is disclosed or shared with third parties (see Section 4).
Parents should also be aware of the following in connection with FIRST collection and use of their children’s personal information:
d. Parental Notification, Verification and Consent:
FIRST will not knowingly collect PII from children under the age of 13 without first obtaining parental consent. Prior to providing any PII (other than a name and a parent’s email address) children under the age 13 must have a parent or legal guardian complete, sign, and return (by e-mail or regular mail) a Parental Consent Form to FIRST at:
200 Bedford St.
Manchester, NH 03101
e. Parental Choice on the Collection and Use of Information:
Parents may allow for the collection and use of the child’s information without consenting to the disclosure of the information to third parties other than those who are acting on behalf of FIRST to help operate our Sites, handle communications, and conduct FIRST programs. Parents can review a child’s personal information, ask to have it deleted, and refuse to allow for any further collection or use of the information at any time. Parents can access, change, or delete a child’s personal information by accessing the child’s account at the Site, or by contacting FIRST at the email or physical address above.
For security reasons, FIRST will not post a child’s specific address or last name on any FIRST Site.
14. How to Contact Us
200 Bedford St.
Manchester, NH 03101
FIRST DIRECT NOTICE AND PARENTAL CONSENT FORM
We, at FIRST, take the privacy and security of personal information very seriously. This notice gives parents additional information about the practices of FIRST in collecting and using personal information from children under 13 years of age with regard to the FIRST web site www.usfirst.org (the “Sites”).
We are sending you this notice because your child may want to provide personal information to us. We collect Personally Identifiable Information ("PII") and Non-Personally Identifiable Information ("Non-PII") to facilitate the operation, funding, and management of FIRST programs.
a. Personally Identifiable Information (“PII”):
This refers to information that lets us know the specifics of who a person is. It includes 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) domain server; (iii) type of computer; (iv) type of web browser; (v) access times; and, (vi) the web site addresses you just came from and navigate to next. This is anonymous information that does not personally identify you. Non-PII assists us to design and arrange our web pages in the most user-friendly manner and to continually improve our Sites.
FIRST will not knowingly collect any PII from children under the age of 13 without first obtaining parental consent. Prior to providing any PII (other than name and a parent’s email address) children under age 13 must have a parent or legal guardian complete and return (by e-mail or regular mail) a signed Parental Consent Form to FIRST.