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Formidable Fund Privacy Policy

Last Updated: September 2024

1. Introduction

This Privacy Policy (the “Policy”) explains how Formidable Fund (“Formidable Fund” or “we”/ “our”/ “us”) collects, uses, shares, and otherwise processes the personal information we collect about consumers. This Policy details what information we collect, how we use it, and the choices and rights you have regarding its use. Our aim is to give you the necessary insights to make informed decisions about your interactions with us, including online. By using our Online Services (defined below) and providing your personal information to us, you give us permission to process your personal information as described in this Policy. If you do not agree with the data collection practices described in this Policy, do not access or use our Online Services. 

2. Scope of This Policy

This Policy describes the various contexts and circumstances in which we collect personal information, including through our “Online Services”. These Online Services include:

  • Digital Interactions: This encompasses your online engagements with us, which may occur through our Online Services, including:

    • Our Websites:  Any that link to this Policy, such as www.formidablefund.org.

    • Social Media and Affiliates: Interactions on our social media pages.

    • Other Digital Platforms: Includes interactions such as subscribing to our electronic communications.

  • Third-Party Information Gathered in the Online Context: This policy also extends to information we may collect about you from third parties related to your use of our Online Services, even in the absence of direct interactions with us.

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Our Online Services may contain links to and from the websites of third parties, including to those of our non-profit fiscal sponsor, the Edward Charles Foundation and everyday.org, when you make a donation. If you follow a link to any of these websites, please note that we are not responsible for the privacy or data security practices of these third parties. These third-party websites have their own privacy policies and we do not accept any responsibility or liability for these policies. For detailed privacy information related to a third party, please contact the third party directly.

3. How We Obtain Information

We obtain the information we collect about you through various means and sources, including:

  • Direct Interactions. We collect personal information when you provide it directly to us, such as when you submit an application via the website, or otherwise provide us with information via phone, email, or online communications. The information collected online may be entered into our systems and combined with other information we collect about you directly or from third parties. We may also share this data with our service providers, affiliates, fiscal sponsor partner, and others. Please see below for more information about how we share your personal information.

  • Automatically Using Data Collecting Tools. We may use various data collecting tools, such as cookies, to collect certain information about your use of our Online Services. These tools can help us maintain and improve our site.

  • Third-Party Sources. We may collect personal information from third parties, including social media platforms, public forums and databases, and other relevant parties based on your interactions with us.

4. Information Collected and How We Use It

We collect and use personal information for several purposes, including to provide our Online Services and continually improve them. The personal information we collect, and how that information is used, depends on how you interact with us, the choices you make when engaging with us, and the Online Services you use.

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This section provides an overview of the types of personal information we may collect about you and the general purposes for which they are used in particular contexts. Please note that the actual information collected, and its use, may vary depending on your interactions with us and the Online Services you use.

4.1 Personal information We Collect Directly From You

This section describes the personal information we collect about you or, if you are a parent or legal guardian submitting information on behalf of your child, about your child when you provide it directly to us through our Online Services, or in an electronic communication.

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4.1.1 What We Collect or Process

  • Contact Information (Identifiers). We collect your name, email address, telephone number, and any other personal identifier you provide in a form or online communication. For parents or legal guardians submitting applications on behalf of their child, this will include the child’s identifiers, such as name and age.

  • Submitted Content. If you upload, submit, or transmit content, including videos, to us using our Online Services, such as our application form, we will collect any personal information contained within that content. We ask that you ensure that you respect the privacy of any individuals whose personal information may be in the content you transmit to us.

  • Taxpayer Identification Information. If we decide to award a grant, we will need to collect information regarding the grant recipient’s taxpayer status, including the recipient’s name, address, and social security number.

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4.1.2 How We Use It

  • To Communicate With You. We will use your personal information to facilitate our communications with you. For example, we will use your email address to verify your submission and communicate with you about your application. The length of time we maintain your contact information and your communications varies depending on the context.

  • To Process Your Application and Initiate Grant Disbursement. We use the personal information submitted by you to process and review your application for a grant, and, together with our fiscal sponsor, to decide and facilitate grant disbursement.

  • Business Operations: We use personal information to perform business operations, such as document management and record keeping, training and development, strategic decision making, auditing and compliance, maintaining the security and integrity of our Online Services, including protection against fraudulent or illegal activities. This includes validating your identity as necessary.

  • Quality Assurance and Improvement: We use personal information to maintain and improve the quality and safety of our services.

  • Additional Uses Described: In any other way we may describe when you provide the information or any other purposes for which you provide your consent.

4.2 Personal information Collected Using Online Data Collecting Tools

We collect, use, and disclose personal information gathered in connection with your online interactions with us, including your use of our websites and their features. We also collect personal information in connection with electronic communication services like email and electronic messaging, and our social media pages (though not the platforms on which they are maintained). When you use our Online Services, we collect some information automatically and combine it with other information we collect about you. We utilize third parties to assist with this collection. In such cases, your personal information is made available to other entities for processing on our behalf or at our direction.   

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Some of this information is collected and logged because of your access to our servers, by various technologies such as cookies, web beacons, scripts, tags, and other software code that store and transmit personal and other information (collectively “data collecting technologies”). 

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4.2.1 What We Collect or Process Using Data Collecting Technologies​

  • Identifiers and Contact Information. We collect identifiers associated with you or the device you are using to access our Online Services, such as IP addresses, Cookie IDs, and other similar identifiers.  

  • Device and Browser Data. We collect information about your device and the software and systems you use to access our Online Services, such as your browser type/version, screen size/resolution, and other information contained in your browser’s communication with our website.

  • User Interaction Data. We may collect data about how you navigate to/from our Online Services (such as the URLs that referred you to our website), browsing activity on our Online Services (such as the web pages you viewed and buttons you clicked), and other metrics associated with your access and use of our Online Services.

  • Electronic Communication Records. We collect records related to your electronic communications with us, including email records, call records and recordings/logs, and other electronic messages and communications.

  • User Preferences. We may record your online preferences, such as communication preferences, general location information, and privacy choices and configurations. We do this to facilitate such preferences.

 

4.2.2 How We Use It 

  • To Provide Our Online Services in a safe and secure manner, such as to present our website and its content to you, to communicate with you about changes to our Online Services, to validate your identity as necessary to ensure the security of our services and systems, and to maintain and improve the security and performance of our Online Services.

  • Communications and Support, such as to review and respond to your requests or inquiries, provide updates, notices, and requested communications, request feedback, or as necessary to fulfill our obligations to you.

  • For Our Legitimate Business Operations, such as to make strategic decisions concerning our business operations, enforce, and review compliance with, the legal terms that govern our offerings, comply with our legal obligations, protect the rights, safety, and property of the online services, our users, and third parties, and anonymize, aggregate, or de-identify your personal information (so it can no longer identify you) in furtherance of conducting research and analysis.

  • To Send You Promotional Materials, such as updates, newsletters, surveys, or other information regarding contests, events, and/or other Formidable Fund services that may be of interest to you based upon information you have provided to us. Promotional materials may be conveyed in emails or, if you have provided your consent, by SMS/text message.

  • With Your Consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. 

 

4.2.3 Third Parties Who Provide Online Services

We may use third-party services for various purposes, including but not limited to website functionality and support. Below are some specific third parties that we may use. To learn more about the types of entities who deploy cookies on our websites, please review “Disclosure of Personal information.”​

  • Font and Content Providers. Various third parties assist us in providing content and features for our Online Services. Because these services send the content to your browser on our behalf, they typically have access to information about your device and browser, including your IP address, the URL of the pages you visit, and information about your device. They use this information to ensure that the content is delivered to you in the correct format and size.

  • Functionality Providers. Third parties assist us in providing various online functionality, such as any accessibility tools, online chat tools, and consent management tools.

  • Web Hosting Providers. Our website hosting and infrastructure providers will receive personal information about your device, including your IP address, device, and browser information, as well as your activity on our websites, in order to provide the hosting services.​

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4.2.4 Your Privacy Choices Regarding Tracking Technologies

  • “Do Not Track” Signals. Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. Like many websites, we do not currently respond to ‘Do Not Track’ browser settings or signals. For more information about DNT, please see eff.org/issues/do-not-track.

4.3 Data Collected from Other Parties

We obtain information from businesses which provide us with our business and Online Services, such as our marketing service providers, fraud prevention service providers, vendors that provide services on our behalf, and publicly available sources. We also create information based on our analysis of the information we have collected from you. We use this information for our business operations purposes, including offering and improving our services, providing customer support, accounting purposes, and to enforce our terms and policies. Please see “Disclosure of Your Personal information” to learn more about how we process personal information via our business services providers.

4.4 Other Purposes for Processing Personal information

While less frequent, there are other scenarios where we may use or disclose your personal information:

  • Audits Involving External Entities: Sharing data with external organizations, including those we collaborate with or those that evaluate our business operations, to ensure compliance with industry standards, certifications, or legal obligations.

  • Legal Obligations: Fulfilling legal obligations such as responding to subpoenas, court orders, or other binding government requests. In the rare event of litigation, we may use your data to establish, exercise, or defend legal claims.

  • Reorganization: In the event of a business transaction such as a sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, your personal information may be shared or transferred. This also includes any subsequent integration activities post-transaction.

  • Business Transfers: In the event of a divestiture, investment, or other asset transfer that is not part of a broader business transaction like a merger or acquisition, your personal information may be shared or transferred.

  • With Your Consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. 

5. Disclosure of Your Personal information

We may disclose the above information to the following types of parties:

  • Authorized Persons and Agents. We may disclose personal information to marketing, and other services providers with whom we interact on your behalf.

  • Our Fiscal Sponsor. In order to facilitate the award of grants to successful applicants, we may disclose personal information, including taxpayer status information of grant recipients, to our fiscal sponsor which manages, and controls grant disbursement.

  • Business Services Providers. These are persons or entities with whom we have a relationship to provide business operations services and support. These companies, known as “service providers,” are contractually obligated to use your data only for the service they're providing and cannot use it for anything else. These providers may include the following:

    • IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.

    • Business Operations Providers. These include service provider with whom we partner to provide day-to-day business operations, including security vendors, business software service providers, and similar entities.

    • Professional Service Providers. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

  • Marketing Providers. These may include direct marketing, affiliate marketing program providers, marketing consultants, and similar services providers.

  • Law Enforcement/Government Agencies. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.

  • Corporate Transaction Disclosures. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

  • Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it.

6. Data Retention

We retain your personal information only as long as needed to fulfill the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you have any questions about the specific retention periods for different types of your personal information, please feel free to contact us using the Contact Information provided below.

7. Your Privacy Choices

You can control the collection and use of personal information for some of our processing activities. Below are the avenues through which you can manage the types of communications you receive from us:

  • Email: To opt out of promotional emails, you may follow the ‘unsubscribe’ instructions located at the bottom of each email. Alternatively, you may contact us directly using the information provided in the Contact Information section. Please be advised that opting out of promotional communications will not preclude you from receiving emails related to your applications for a grant.

  • Text Messages: To discontinue receiving automated text notifications, simply reply ‘STOP’ to any of our messages, or use any alternative opt-out keyword we may have provided.

  • Mail Promotions: Should you wish to be removed from our mailing list for physical promotions and solicitations, please send a written request to our customer service department using the address provided in the Contact Information section of this Policy. Ensure your full name and mailing address are included in your correspondence.

8. Security

We implement recognized physical, technical, and organizational safeguards tailored to protect the confidentiality, integrity, and availability of the specific categories of personal information we collect and process. These safeguards are designed to prevent unauthorized or unlawful access, destruction, loss, alteration, or disclosure of your personal information. However, despite our best efforts, no controls can provide absolute protection against all security threats, and we cannot guarantee that unauthorized access or loss will never occur. We have procedures in place to deal with any suspected data security breach. We will notify you and/or any applicable regulator of a suspected data security breach where we are legally required to do so in accordance with any legally prescribed timeframes.

9. Children's Policy

Our Online Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under 13 has directly provided us with personal information, please use our Contact Information. If we become aware that we have collected personal information from a child under the age of 13, we will take steps to promptly delete such information.

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If you provide us with personal information about children under the age of 13, you acknowledge and agree that you are the child’s parent or legal guardian and have the necessary authority to provide such information to us.

10. Updates to This Privacy Policy

We reserve the right to modify this Policy at any time to reflect changes in our practices, services, or legal obligations. Any modifications will be effective upon the date specified in the updated Policy. If we make material changes to this Policy that significantly affect your rights or the way we use your personal information, we will notify you through the most appropriate channels. Generally, this will be done by updating the date at the top of this page. However, other notification methods may include sending an email to the address you have provided, posting a notice on our Online Services, or other methods as required by law.  Your continued use of our Online Services following the posting of changes constitutes your acceptance of such changes.

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We will indicate the date of the last revision at the top of this Policy. We encourage you to periodically review this Policy to stay informed about how we are protecting your personal information.

11. Contact Information

If you have any questions or concerns about this Policy or our data practices, you can reach out to us through the following means:

Email: privacy@formidablefund.org

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