Effective as of July 1, 2014 (last updated September 6, 2018)
- what information we may collect from or about you, and how we collect such information;
- how we use such information; and
- what rights and choices you have regarding such information.
1. CHILDREN’S PRIVACY
We recognize the need to provide additional privacy protection for children on the CFCI website. To register for CFCI, you must be a verified teacher or financial professional. CFCI verifies a teacher identity through several methods including visiting a school’s online teacher directory and/or contacting a teacher’s supervisor.
If under 13 years of age, please get consent from your parent, guardian, or teacher.
We do not collect any personal information on children under 13 years of age. Younger visitors should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information.
For information about how we protect the privacy of children in the European Economic Area (“EEA”), please see Section 9 (“Notices to Individuals in the European Economic Area”).
If you know anyone who is in violation of our age requirements, please email firstname.lastname@example.org.
3. INFORMATION WE MAY COLLECT ABOUT YOU
Personal Information: This refers to information that can be used when Teachers set up an Account on our website. This includes first and last name, email address, school name, school city and state and account login information (i.e., username and password). It also includes information that may be uniquely linked to a User as a result of his/her visit to the CFCI website, such as server log file data and session information (which is explained in more detail below). You may need to provide your username and password) in order to access certain areas and features on the CFCI website.
Non-Personal Information: This refers to any information that does not identify a User personally. For example, we may gather demographic and/or other aggregate data about our Users as a group. Also, we may use online survey and feedback forms to gather opinions, comments, suggestions, etc. about the CFCI website on an anonymous basis from our Users; occasionally, we report quoted feedback from Users, but we do not attribute feedback to individual Users unless we have permission from a User to use his or her name along with the feedback. We collect and use non-personal information to administer and monitor the CFCI website, to analyze CFCI website traffic and usage patterns and trends, to improve the functionality of the CFCI website, and to enable us to personalize and better Users’ experience on the CFCI website. When we report information about the Site to our partners and investors, we report non-personal information only.
4. HOW WE USE INFORMATION ABOUT YOU
We will use your information only for the purposes for which it was collected. Those purposes include:
- Member Registration (website registration): Certain areas and features on the CFCI website are accessible only to registered Members, such as Assessments. To register as a Member, you will be asked to provide your first and last name, email address, school name, school city and state, and set up a Username and Password. If you register as a Member, we will use your personal information for all purposes related to your membership (pursuant to our agreement with you as a member) and your use of the CFCI website as a Member, including, without limitation: providing administrative, maintenance and support services to Member accounts and responding to Member inquiries, requests and complaints. Only individuals who are verified Teachers or Financial Professionals are able to set up Accounts on the CFCI website.
- Survey and Feedback Forms: We may use online survey and feedback forms to gather opinions, comments, suggestions, etc. about the CFCI website from our Users. Survey and feedback forms may be completed and submitted by Users anonymously without disclosing any personal information. However, should you choose to voluntarily disclose personal information to us, we will collect and use such information pursuant to our legitimate interests to understand your comments, communicate with you regarding your feedback, and make changes to our services accordingly. We may post your feedback on the CFCI website or in our marketing communications. If we want to include any identifiable personal information with your feedback, we will first obtain your permission.
- CFCI Stories: You have the option to share your CFCI stories with us. When you share your personal information in online forums, that information will be posted publicly so that anyone who uses the online forum can see your information. When you submit a CFCI story, we may publish that story with your permission.
5. WHEN WE SHARE INFORMATION ABOUT YOU
We do not knowingly share or sell your personal information with third parties for their direct marketing use. We will only share your personal information with third parties with your consent, at your direction, or in the following circumstances:
- To contractors, service providers, and other third parties we use to support our business activities and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- When Required by Law: We may disclose your personal information to third parties if doing so is required by law or, in our good faith belief, is reasonably necessary to:
- Comply with legal process;
- Respond to claims that any User Postings violate the rights of third parties;
- Respond to an emergency; or
- Protect the rights, property or safety of CFCI, its Users, and/or the public.
6. USER CHOICES AND OPT-OUT
We offer you choices and opportunities to opt out of certain uses of your personal information. In addition, you have certain rights with regard to the personal information we collect about you.
- Membership Cancellation. You may at any time request to cancel and have your membership account removed from the CFCI website, provided that your request to cancel is in writing and sent to CFCI via email email@example.com.
- Access and Modification of Your Personal Information. As a Member, you may log into your account at any time to modify, update and correct your account information. However, you understand and acknowledge that certain personal information (e.g., your name and email address) cannot be deleted without CFCI having to cancel your membership account. You may email us firstname.lastname@example.org or use the contact information in Section 12 below if you have any questions about modifying, updating or correcting your personal information. If you are located in the EEA, you may have additional rights. Please see Section 9 (“Notices to Individuals in the European Economic Area”) for an explanation of these additional rights.
Cookies are small data files that websites and online services send to and store on your computer or mobile device through your web browser. Cookies enable websites and online services to recognize your browser and record certain information about your visits. While the cookies we use may change from time to time as we improve and update the CFCI website, they generally fall into the below categories of use:
We may also use web beacons (also known as clear GIFs or pixel tags) – which are small bits of code embedded in web pages or in emails – to deliver or communicate with cookies, to count users who have visited a web page, and to understand usage patterns. We may include web beacons in emails to help us recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
8. LINKS TO THIRD PARTY WEBSITES
9. NOTICES TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA
EEA Children’s Privacy: We take appropriate steps to obtain parental or guardian consent prior to collecting personal information from children under 13 or 16 years old (depending on where you are located in the EEA). Younger visitors should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information.
Member Registration (website registration): Only Verified teachers and Finance Professionals are able to register on the CFCI website. Children are not able to register for the CFCI website.
Marketing Communications: We will obtain your consent to receive marketing communications prior to sending you such communications. You can opt-out at any time by using the “opt out” or “unsubscribe” means provided in the marketing mailings you received. You may also email us at email@example.com.
Individual Rights related to Personal Information: You may email firstname.lastname@example.org or use the contact information in Section 12 below to request that we:
- Delete your Personal Information: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide the CFCI website to you).
- Change or Correct your Personal Information: You can also ask us to change, update or fix your personal information in certain cases, particularly if it’s inaccurate. As a Member, you may log into your account at any time to modify, update and correct your account information.
- Object to, or Limit or Restrict, Use of your Personal Information: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal information is inaccurate or unlawfully held). You also have the right to withdrawal your consent at any time.
- Right to Access and/or Take Your Personal Information: You can ask us for a copy of your personal information and can ask for a copy of personal information to be provided in machine readable form.
10. DATA TRANSFERS TO THE UNITED STATES
11. SECURITY AND DATA RETENTION
We understand the importance of protecting the security and integrity of personal information that our Users have shared with us. We maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. For example, we encrypt the transmission of your information using secure socket layer (SSL) or similar technologies. We also have in place internal policies and procedures that govern our use and disclosure of your personal information.
Despite the steps we take to protect your personal information, we do not warrant or guarantee the security of any information you transmit to, from or on the CFCI website. Therefore, we urge you to keep your account login information in a safe place and not to divulge it to anyone. Also, remember to sign off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or an Internet cafe.
We will maintain your personal information for as long as you have an account or as necessary to deliver the CFCI website to you or to your school. We may anonymize your personal information after you have deactivated or deleted your account so that we can use this anonymized information for our internal business purposes.
12. CONTACT US
510 Waverley Street
Palo Alto, CA 94301 USA Email: email@example.com
CFCI is the data controller with respect to the personal information collected through the CFCI website. If you are located in the EU and you are unhappy with our resolution of your privacy-related inquiry or request, you have the right to lodge a complaint with your Supervisory Authority.