Privacy Policy
Introduction
This privacy policy (this “Policy”) describes the personal data that Fair Play Policy Institute (“we,” “us,” “our”) collects in connection with your use of our website at www.fairplaypolicy.org (the “Site”), and how we use, share, retains, or otherwise processes this personal data. This Policy is incorporated into our Terms of Use.
By visiting the Site, you acknowledge that you have read this Policy, which we may update at any time. If we update this Policy, we will post the updated version here. Any such changes will be effective as to you when you first access the Site after we post the changes here. If we make any material changes in the way we collect, hold, use, process or share your personal data, we will endeavor to provide you with appropriate notice. This Policy sets out:
• the types of personal data that we collect from individuals when they use the Site;
• the purposes and legal basis for our processing and use of individuals’ personal data;
• how we may disclose or use personal data;
• how we transfer personal data outside of the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”); and
• individuals’ rights with respect to our use or disclosure of their personal data.
You may send us, using the contact information below, any queries you may have regarding how (1) our policies may apply to your personal data; (2) to exercise your right to question or object to our use of your personal data, in accordance with applicable laws; or (3) to access, correct, or delete your personal data.
What Personal Data Do We Collect
Information relating to an identified or identifiable person, such as a name, mailing address, email address, phone number, or other identifier that permits contacting a specific individual, constitutes “personal data.” We collect certain personal data when you use the Site, as described below. We do not request or require, or provide opportunities for you to submit, personal data on the Site, nor do we collect personal data by means of the Site, other than as set forth below or as otherwise specified on the Site from time to time.
• We provide you with the opportunity to submit your email address to sign up for our newsletter. If you do so, we will use your email address for the purpose of providing you with our newsletters and/or other information that we believe you will find relevant.
• We may record details of visits to the Site, such as traffic data, IP addresses, location data, weblog information about the computer or other device you use to interact with the Site, the type of operating system and browser you use, access times, pages viewed, URLs clicked on, and the pages visited before navigating to the Site, using cookies or other technologies, as set forth below. Cookies are small text files stored by your browser on your computer or other device when you visit websites, which allow for the collection of certain information about your use of the websites. Some of these cookies are essential, but you have the choice to refuse the use of all non-essential cookies through your browser settings or by clicking on the options on the Site. To find out more about cookies please visit: www.allaboutcookies.org or www.youronlinechoices.eu.
• If you make a purchase through the Site, our third-party payment processor will collect your payment card information to fulfill your purchase. We do not receive or store your payment card information. To learn more about how our current payment processor, Stripe, manages personal data, please see their privacy policy.
• We provide training programs that you or your employer may purchase through the Site. To the extent that you participate in one of our training programs, we may receive personal data that you provide as part of the training, such as name, email, job title, and home address, which we use for the purpose of facilitating the training program.
•If you apply to be a “Fair Play Facilitator,” you will need to provide the information we request on the Site’s webform, such as your name, email address, phone number, mailing address, link to your website or LinkedIn profile, profession and insurance information. We use this information to evaluate and process your application and for the purpose of promoting our Fair Play Facilitators.
• We collect personal data when you communicate with us through our Site, such as when you submit a support request or inquiry.
Who Controls the Personal Data that We Collect
We are a data controller with respect to your personal data. We ‘control’ the personal data we collect through the Site and make certain decisions as to how to use and protect it, but only to the extent that we have informed you about such use or as otherwise permitted by applicable law.
How and With Whom Do We Share personal data
We may share your personal data:
• among any affiliated organizations;
• with service providers, suppliers and subcontractors for the purpose of providing the Site and the services accessible on the Site;
• with analytics and search engine providers, such as Google Analytics to help us improve and optimize the Site (to learn more about Google Analytics and how Google collects and processes data, see www.google.com/policies/privacy/partners);
• if we transfer or acquire any businesses or assets or merge any business or operations into or with those of another person or entity, in which such data may be one of the assets transferred in such transaction;
• to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend against legal claims, to protect our and others’ rights, property, or safety, and for the purposes of crime and fraud prevention and remediation;
• as required to conduct our operations and pursue our legitimate interests; or
• to any other party with your consent.
We will not sell your personal data or otherwise provide it to third parties for their marketing purposes.
How We Use Personal Data
We use personal data for the following purposes:
(a) to provide the Site and related products and services to you, including to fulfill your orders and requests and process your applications (e.g., to become a Fair Play Facilitator);
(b) to improve our Site and keep it functioning properly;
(c) to respond to your inquiries and provide customer support;
(d) to send you emails and other information as permitted by law;
(e) to personalize your experience with the Site;
(f) to maintain the security of the Site;
(g) to comply with applicable laws or regulations, including to respond to valid legal process, such as a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law; and
(h) as otherwise described in this Policy.
Retention of Personal Data
We retain personal data as long as needed to fulfill the purposes described in this Policy.
Links to Third Party Sites
We provide links on the Site to third-party sites. Because we do not control the information policies or practices of these third-party sites, you should review their privacy policies to learn about how they may collect and use your personal data. If you choose to visit social media platforms such as Instagram, LinkedIn or Facebook through the links on the Site, the information you provide on or through those platforms will be shared with those platforms and may, in some cases, be viewed by the general public. We do not control user-posted content on social media websites and are not responsible for any third-party use of information that you have posted, transmitted or otherwise made available there. For the avoidance of doubt, this Policy applies solely to information collected by us through the Site.
Security
We use reasonable technical, administration, and physical controls to help protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Despite our efforts, no data security measures can guarantee security. If you believe the security of your personal data has been compromised, please notify us immediately using the contact information below.
Transfers of Personal Data Outside the EEA, Switzerland or UK
In some cases, disclosure of personal data to other persons will involve transferring personal data from a country in the EEA, Switzerland or UK to a country which has been held not to provide a level of protection of personal data equivalent to that provided in such locations. In particular, personal data from the EEA, Switzerland or UK, if any, will be transferred to, stored in and processed in the United States. If we transfer your personal information out of the EEA, Switzerland or UK to a country not deemed to provide an adequate level of personal information protection for purposes of applicable data protection laws such that additional safeguards are required, the transfer will be performed only with your consent, to pursue our legitimate business interests, or as otherwise permitted by applicable laws.
Your Rights
You may have certain legal rights with respect to our use, processing and sharing of your personal data, as described below, depending on where you reside. We make the rights described below available to all users, regardless of whether you reside in a jurisdiction that expressly provides for a particular right. There may be limitations to these rights under applicable law. If you wish to contact us to exercise any of these rights, please contact us as set forth at the end of this Policy.
• Access: You may request a copy of the personal data that we have collected, used, or shared about you, and why we collected, used or shared that personal data, including the categories of personal data collected, the specific items of personal data collected, the categories of sources from which we collected personal data, the purposes for which we use the personal data, the categories of third parties with whom we share the personal data, and the categories of information that we disclose to third parties.
• Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes.
• Objecting/Deletion: You have the right to object to processing of your personal data and to ask us to block, delete or restrict your personal data, subject to certain exceptions. Once we receive your request and verify your identity, we will delete your personal data from our records and direct our service providers to delete your personal data from their records, unless an exception applies under applicable law. You may also request that we limit our use of your sensitive personal information, if applicable.
• Portability: You have the right to request that your personal data be provided to you, or to another data controller, in a commonly used, machine-readable format.
• Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory or other governmental authority.
We will not deny you services, charge you a different price, provide a different level or quality of services or otherwise discriminate against you just because you exercised any of these rights; however, if you decline to provide your personal data or ask us to delete it or stop disclosing it, we may be unable to provide you with certain services.
Only you, or a person whom you authorize to act on your behalf, may make a request related to your personal data. The request must: provide sufficient information for us to reasonably verify you are the person about whom we collected personal data or an authorized representative of such person; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use personal data provided in a request only to verify your identity or authority to make the request.
Do Not Track
We do not respond to Do Not Track (“DNT”) signals from web browsers. DNT is a preference that users can set in their web browser to inform websites that they do not want to be tracked.
Children
The Services are not directed to persons under 18. We do not knowingly collect personal data from children under 13. If a parent or guardian of a child under the age of 13 becomes aware that their child has provided us with personal data without such parent or guardian’s consent, they should contact us and we will delete such information from our files.
Interpretation
All references herein to “include” or “including” shall be deemed to mean “include without limitation” or “including without limitation,” as the case may be.
Contact Us
If you have any questions about this Policy, or wish to communicate with us regarding your personal data, you may contact us by email at info@fairplaypolicy.org.