Privacy Policy
Last Updated: January 12, 2023
We recognize that your privacy is very important. This privacy policy covers the policies of Free The Work (f/k/a Free The Bid) (“FTW”) on the collection, use, and disclosure of your information, including any personally identifiable information or other data collected that could directly or indirectly identify you (“Personal Data”) when you access the FTW platform (the “Site”), or anytime you use our other products or services excluding Invoke products or services (the Site and other FTW memberships, programs, products and services excluding Invoke products or services, altogether, the “Services”).
Each time you use our Services, you consent to the collection, use and storage of the collected information as described in this Privacy Policy. Please read it carefully and contact us at [email protected] if you have any questions.
1. What information do we collect?
Account Registration Information. If wish to register for an account, we may collect your name, email address, phone number (optiona), employer and position title (where applicable) and password. Users using our Services through their registered accounts will be referred to as “members” in this Privacy Policy.
Registering for Events Through Event Marketing Platforms or On-line Forms. If you register for an event through an event marketing platform, such as EventBrite, or an on-line form platform, such as Typeform, we may have access to some of your third-party account information from that service (EventBrite), as well as information you put in the registration form, such as your name, email address, job title, company, how you identify and other information as requested on that form, as authorized by that service. You should review such third party platform’s data policy for more information about its data privacy collection practices.
Profile Information. Depending on your account type you may be able to create a profile of which we may collect the following information where applicable: photo, role/title, professional contact information (phone number and/or email address), genres/types of work you specialize in, biography, social media links, videos of your original work (and related information), and, for businesses searching for talent--your location, how you intend to use our Services, and your commitments. When you provide us with information regarding your identity (e.g. race, gender, orientation, etc.), by selecting the tags that most accurately describe yourself, we make your identity information searchable in our database by the members so they can discover you. You can always choose not to provide the identity information by selecting “Prefer not to say” or for those information which you have opted in to provide, opt-out later by using the opt-out features provided in your account settings. For talent, depending on your account type, when you provide us with professional background information (which includes role, format skills, location, union affiliation, representation, diversity business classification), and provide us with such information via tags selected, your tags will be searchable in our database by the members so they can discover you. You can always opt-out of being searchable by tags by removing those tags from your profile.
Data From Others. Other parties may provide us with information. For example, if you are a photographer and you grant us access to your images on your Instagram account, we will access the images on your Instagram account to the extent your privacy settings on the Instagram app permit so that we can display the images on your Free the Work profile. Instagram will provide us with an authentication token to access your account and media ID of your images from Instagram. Please note that the authentication token and media ID do not identify you personally and will not be treated as Personal Data under this Privacy Policy.
Project Data. Depending on your account type, you may be able to manage projects utilizing the project management tools on our Services. During the process, we may collect information related to the projects input by you, which may include project name, creators bid or booked, creators profile information, project description, budget, format, production location, project shoot date, collaborator notes, and other information related to project management.
Payment Information. As part of our Services, our third party payment processing service provider, Stripe, may collect credit card information from you.
Automatically Collected Online Usage Activity
As is true of most websites, we gather certain information automatically when you visit our Site. FTW uses technology to provide online customer support and data to improve or customize your user experience. These technologies help us track and analyze user traffic and activity, administer and update our Site, to improve our performance. This information helps us understand your needs and suggest products and services relevant to you.
Log Files
We keep track of activity on our Site via log files stored on our web servers. We collect information such as IP address, browser type and version, and pages you view. We also keep track of how you got to our Site and any links you click on to leave our Site. Once you leave our Site, we do not track you. We use your website activity to assist us in offering you a personalized Site experience, assist you with technical support, diagnose problems with our server, administer our websites, and to tailor our product and offerings to you.
Web Beacons
We access and set cookies using web beacons, also known as single-pixel GIFs which are invisible graphical images. These web beacons provide us useful information regarding our Site such as which pages users access. When we send you emails, we may include a single-pixel GIF to allow us to determine the number of people who open our emails. When you click on a link in an email, we record this individual response to allow us to customize our offerings to you.
Cookies
To collect this information, a cookie is set on your computer or device when you visit our Services. Please see section below “How We Use Cookies” for more discussion on this topic.
In some countries, including countries in the European Economic Area (“EEA”), United Kingdom and Switzerland, the information referenced above in this paragraph may be considered personal information under applicable data protection laws. You can set your browser to remove or reject cookies; however some Services may not work properly without cookies.
Mobile Device Data. When you access our Services through a mobile device, we also collect certain mobile device information automatically, including, but not limited to, the type of mobile device you use, your mobile operating system, and the type of mobile Internet browsers you use.
Program & Activity Updates. We collect your name and email address if you sign up to receive emails, invites and newsletters from us regarding our programs and activities.
Services and Customer Support. We collect information such as your name and email address to the extent necessary for us to provide the Services that you have requested and/or to provide customer support.
2. How we use cookies?
Cookies are small text files which are transferred to your computer or mobile device when you visit a website or app. We use them to remember your preferences, improve your user experience, and help us understand how people are using our Services, so we can make them better. Cookies can be session cookies, which expire once you close your web browser. Cookies can also be persistent cookies, which stay on your device or a set period of time or until you delete them. FTW uses the following types of cookies:
Using our Services without cookies is also possible. In your browser, you can deactivate the saving of cookies, limit them to particular websites, or set the browser to notify you when a cookie is sent. You can also delete cookies from your PC hard drive at any time (file: "cookies"). Please note that in this case you will have to expect a limited page presentation and limited user guidance. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/
3. How do we use the collected information?
We use the information we collect for the purposes described in this Privacy Policy, as covered in any agreement that incorporates this Privacy Policy, or as disclosed to you in connection with our Services. For example, we will use your information to:
Electronic Communication. Consistent with the above purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email or text message to provide you with the Services. Message and data rates may apply for any text messages sent to you from us and to us from you, and we are not liable for the cost of any such messages. You are not required to provide us with your phone number. By providing us with your phone number during account registration or at any time during your membership term, you consent to receiving text message from us. You can opt-out by texting “NO” or “STOP” when prompted by the text message.
Aggregate Data. In an ongoing effort to better understand and to serve the users of our Services, we may conduct research on our user demographics, professional backgrounds, interests and behavior based on Personal Data and other information that has been provided or received by us. This research may be compiled and analyzed on an aggregate basis shared with members or third parties and this aggregate information does not identify you personally and will not be treated as Personal Data under this Privacy Policy.
Legal Basis For Processing. When we process your Personal Data we will only do so where at least one of the following applies:
Data Processing Agreement. We offer members with qualifying accounts our standard FTW Data Processing Agreement with Standard Contractual Clauses/Model Clauses and GDPR clauses as standard. We understand that some of our members prefer to have a written agreement as regards data processing and transfers, in addition to FTW’s Terms of Service and Privacy Policy. To receive a copy of the DPA please contact us [email protected]
4. Is Information Collected by or Disclosed to Third Parties by using the Services?
We do not share, sell or rent to third parties your information except as described in this Privacy Policy. Examples of instances in which we share your information are provided below:
Users may follow FTW on Facebook, Instagram, Twitter and other social media platforms as made available from time to time. Users should click on the hyperlinks for each site to review the applicable privacy policies for more detail about information collected from these sites.
6. How Does FTW Comply with the Children’s Online Privacy Protection Act?
Our Services are directed toward a general audience and are not directed at nor intended for use by children. We do not knowingly collect information from children under the age of 13 without parental consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.
7. GDPR+ Data Protection Rights
If you are located in countries that are within the European Economic Area (the “EEA”), Switzerland or UK, GDPR and its Swiss and UK GDPR counterparts give you rights with respect to your personal data, subject to any exemptions provided by the law, including the following rights:
You can usually access, correct, or delete your personal data by contacting us at [email protected]. We will consider all such requests and provide our responses as soon as we can. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include circumstances where we need to keep processing your personal information for our legitimate interests or to comply with a legal obligations. Users located in EEA, UK or Switzerland also have the right to make a complaint to a government supervisory authority.
8. Cross-Border Data Transfers
Sharing of information laid out in Section 4 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. FTW may also subcontract processing to, or share your Personal Data with, third parties located in countries other than your home country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Our Services are hosted on Firebase backed by Google Cloud Platform. Like FTW, helping to protect the confidentiality, integrity, and availability of customer data is of the utmost importance to Google, as is maintaining customer trust and confidence. Google is certified under the US-EU and US-Swiss Privacy Shields and, in compliance with the Privacy Shield Principles, act as our agent with regard to data privacy. Google relies on the Standard Contractual Clauses approved by the EU Commission, as amended from time to time, for data transfers. For more details of Google's privacy and security processes, please visit https://policies.google.com/privacy. By using our Services, you consent to your personal information being transferred to our servers as set out in this policy.
Where our Services allow for users located in the European Economic Area (“EEA”), UK or Switzerland, and when we transfer their Personal Data to countries outside of the EEA, UK or Switzerland as processors, we transfer the Personal Data in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures in place such as the Standard Contractual Clauses approved by the EU Commission, as amended from time to time. Standard Contractual Clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
9. California Privacy Rights
Shine the Light Law. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. We do not share your personal information with third parties for direct marketing purposes.
California Privacy Rights Act. As a nonprofit, we are not subject to California Privacy Rights Act (the “CPRA”), as CPRA is applicable to for-profit businesses only. Regardless, we do not sell personal information. However, we will closely monitor the development of the CPRA and other privacy laws that may apply to our activities and will implement reasonable administrative, technical and physical security measures for compliance.
10. How long does FTW retain information collected?
We follow generally accepted standards to store and protect the Personal Data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate. We retain Personal Data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records. If you have any questions about the security or retention of your Personal Data, you can contact us at [email protected].
11. What is FTW’s Security Policy?
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. However, although we endeavor to provide reasonable security for information we process and maintain, no security system can ever by 100% secure.
12. How Does FTW Respond to “Do Not Track” Signals?
“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, FTW does not respond to or alter its practices when a Do Not Track signal is received.
13. How Will I Be Notified of Changes to Your Privacy Policy?
If FTW makes material changes to its Privacy Policy, it will notify you by: (i) changing the Last Updated Date at the top of the Privacy Policy, (ii) sending an email to its users, and/or (iii) adding a statement to the Site.
14. Contact Us
If you have any questions regarding privacy while using our Services, or have questions about our practices, please contact us via email at [email protected].
Each time you use our Services, you consent to the collection, use and storage of the collected information as described in this Privacy Policy. Please read it carefully and contact us at [email protected] if you have any questions.
1. What information do we collect?
Account Registration Information. If wish to register for an account, we may collect your name, email address, phone number (optiona), employer and position title (where applicable) and password. Users using our Services through their registered accounts will be referred to as “members” in this Privacy Policy.
Registering for Events Through Event Marketing Platforms or On-line Forms. If you register for an event through an event marketing platform, such as EventBrite, or an on-line form platform, such as Typeform, we may have access to some of your third-party account information from that service (EventBrite), as well as information you put in the registration form, such as your name, email address, job title, company, how you identify and other information as requested on that form, as authorized by that service. You should review such third party platform’s data policy for more information about its data privacy collection practices.
Profile Information. Depending on your account type you may be able to create a profile of which we may collect the following information where applicable: photo, role/title, professional contact information (phone number and/or email address), genres/types of work you specialize in, biography, social media links, videos of your original work (and related information), and, for businesses searching for talent--your location, how you intend to use our Services, and your commitments. When you provide us with information regarding your identity (e.g. race, gender, orientation, etc.), by selecting the tags that most accurately describe yourself, we make your identity information searchable in our database by the members so they can discover you. You can always choose not to provide the identity information by selecting “Prefer not to say” or for those information which you have opted in to provide, opt-out later by using the opt-out features provided in your account settings. For talent, depending on your account type, when you provide us with professional background information (which includes role, format skills, location, union affiliation, representation, diversity business classification), and provide us with such information via tags selected, your tags will be searchable in our database by the members so they can discover you. You can always opt-out of being searchable by tags by removing those tags from your profile.
Data From Others. Other parties may provide us with information. For example, if you are a photographer and you grant us access to your images on your Instagram account, we will access the images on your Instagram account to the extent your privacy settings on the Instagram app permit so that we can display the images on your Free the Work profile. Instagram will provide us with an authentication token to access your account and media ID of your images from Instagram. Please note that the authentication token and media ID do not identify you personally and will not be treated as Personal Data under this Privacy Policy.
Project Data. Depending on your account type, you may be able to manage projects utilizing the project management tools on our Services. During the process, we may collect information related to the projects input by you, which may include project name, creators bid or booked, creators profile information, project description, budget, format, production location, project shoot date, collaborator notes, and other information related to project management.
Payment Information. As part of our Services, our third party payment processing service provider, Stripe, may collect credit card information from you.
Automatically Collected Online Usage Activity
As is true of most websites, we gather certain information automatically when you visit our Site. FTW uses technology to provide online customer support and data to improve or customize your user experience. These technologies help us track and analyze user traffic and activity, administer and update our Site, to improve our performance. This information helps us understand your needs and suggest products and services relevant to you.
Log Files
We keep track of activity on our Site via log files stored on our web servers. We collect information such as IP address, browser type and version, and pages you view. We also keep track of how you got to our Site and any links you click on to leave our Site. Once you leave our Site, we do not track you. We use your website activity to assist us in offering you a personalized Site experience, assist you with technical support, diagnose problems with our server, administer our websites, and to tailor our product and offerings to you.
Web Beacons
We access and set cookies using web beacons, also known as single-pixel GIFs which are invisible graphical images. These web beacons provide us useful information regarding our Site such as which pages users access. When we send you emails, we may include a single-pixel GIF to allow us to determine the number of people who open our emails. When you click on a link in an email, we record this individual response to allow us to customize our offerings to you.
Cookies
To collect this information, a cookie is set on your computer or device when you visit our Services. Please see section below “How We Use Cookies” for more discussion on this topic.
In some countries, including countries in the European Economic Area (“EEA”), United Kingdom and Switzerland, the information referenced above in this paragraph may be considered personal information under applicable data protection laws. You can set your browser to remove or reject cookies; however some Services may not work properly without cookies.
Mobile Device Data. When you access our Services through a mobile device, we also collect certain mobile device information automatically, including, but not limited to, the type of mobile device you use, your mobile operating system, and the type of mobile Internet browsers you use.
Program & Activity Updates. We collect your name and email address if you sign up to receive emails, invites and newsletters from us regarding our programs and activities.
Services and Customer Support. We collect information such as your name and email address to the extent necessary for us to provide the Services that you have requested and/or to provide customer support.
2. How we use cookies?
Cookies are small text files which are transferred to your computer or mobile device when you visit a website or app. We use them to remember your preferences, improve your user experience, and help us understand how people are using our Services, so we can make them better. Cookies can be session cookies, which expire once you close your web browser. Cookies can also be persistent cookies, which stay on your device or a set period of time or until you delete them. FTW uses the following types of cookies:
- Strictly Necessary Cookies: These cookies are necessary to allow us to operate our Services as you have requested.
- Performance/Analytics Cookies: We use cookies and other similar technologies to analyze how our Services are accessed, is used, or is performing. We use this information to maintain, operate, and continually improve our Services. We may also obtain information from our email newsletters or other communications we send to you, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters' effectiveness and helps us ensure that we're delivering information that you find interesting.
- Functional Cookies: These cookies help us remember your preferences and settings to enhance your user experience.
Using our Services without cookies is also possible. In your browser, you can deactivate the saving of cookies, limit them to particular websites, or set the browser to notify you when a cookie is sent. You can also delete cookies from your PC hard drive at any time (file: "cookies"). Please note that in this case you will have to expect a limited page presentation and limited user guidance. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/
3. How do we use the collected information?
We use the information we collect for the purposes described in this Privacy Policy, as covered in any agreement that incorporates this Privacy Policy, or as disclosed to you in connection with our Services. For example, we will use your information to:
- Provide and deliver products or services, including software updates;
- Operate and improve our operations, systems, products, and services;
- Understand you and your preferences to enhance your experience, for example, recommend talents to you (if you are a business searching for talent), or allow you to be searchable by other members (by selecting the tags provided or selecting the option to be searchable);
- Respond to your comments and questions and provide customer service;
- Provide service and support, such as sending confirmations, invoices, technical notices, updates, security alerts, and administrative messages and providing customer support and troubleshooting;
- Communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by FTW and our selected partners;
- Enforce our terms and conditions or protect our business, partners, or users; or
- Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity
Electronic Communication. Consistent with the above purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email or text message to provide you with the Services. Message and data rates may apply for any text messages sent to you from us and to us from you, and we are not liable for the cost of any such messages. You are not required to provide us with your phone number. By providing us with your phone number during account registration or at any time during your membership term, you consent to receiving text message from us. You can opt-out by texting “NO” or “STOP” when prompted by the text message.
Aggregate Data. In an ongoing effort to better understand and to serve the users of our Services, we may conduct research on our user demographics, professional backgrounds, interests and behavior based on Personal Data and other information that has been provided or received by us. This research may be compiled and analyzed on an aggregate basis shared with members or third parties and this aggregate information does not identify you personally and will not be treated as Personal Data under this Privacy Policy.
Legal Basis For Processing. When we process your Personal Data we will only do so where at least one of the following applies:
- Provide our service to you: Most of the time, the reason we process your Personal Data is to perform the contract that you have with us. For example, if you create an account, we process your account registration data to provide customized and personalized Services to you. If you choose to make your playlist public, or upload videos of your original work, we make the playlists viewable by other members and your videos discoverable by other members interested in your talent. If you want to be eligible for discovery on projects that connect you with your authentic voice, and provide information about your identity by selecting the tags that most accurately describe yourself, we make your identity information searchable in our database by the members so they can discover you. When you input search data, we process the search data information to provide you with results you are seeking (for example, the talents you may be interested in hiring). When you provide our third party payment processor with payment information, our third party payment processor processes the information to process your payment.
- Legitimate interests: We may use your Personal Data where we have legitimate interests to do so. For instance, we analyze users’ behavior on our Services to continuously improve our Services and for market research purpose. We track aggregate data to provide us with insights as to our progress in terms of achieving our nonprofit mission. We make recommendations we think might interest you based on your preferences, for example, talent, public playlists, videos, etc. We process Personal Data for administrative, fraud detection and other legal purposes.
- Consent: From time to time, we may ask for your consent to use your Personal Data for certain specific reasons. You may withdraw your consent at any time by utilizing the opt-out features available in your account settings, or by contacting us at the address provided at the end of this Privacy Policy.
- Legal Compliance: When it is necessary for us to use your Personal Data to comply with a legal obligations.
Data Processing Agreement. We offer members with qualifying accounts our standard FTW Data Processing Agreement with Standard Contractual Clauses/Model Clauses and GDPR clauses as standard. We understand that some of our members prefer to have a written agreement as regards data processing and transfers, in addition to FTW’s Terms of Service and Privacy Policy. To receive a copy of the DPA please contact us [email protected]
4. Is Information Collected by or Disclosed to Third Parties by using the Services?
We do not share, sell or rent to third parties your information except as described in this Privacy Policy. Examples of instances in which we share your information are provided below:
- Information you choose to share in public areas on our Services.We may share your information when we have your permission, including when you choose to share information through your public profile, which may include name, professional contact information (phone number and/or email address), profile picture, playlists you choose to make public, videos made by you and, for businesses searching for talent, how you intend to use our Services, your commitments and other information you choose to provide in your public profile. For talent, depending on your account type, you may be searchable in our database by the members through the tags you selected regarding your professional background (which may include roles, skills, format, affiliation, representation, location, social media links, biography, mini bio, diversity business classification).You can always opt-out of being searchable by tags by removing those tags from your profile. These public profile information may be shared by members to third parties by email, text and social media channels.
We may offer you the ability to post information, exchange ideas and take actions (e.g., upvote, like, etc…) through certain public areas in our Services. Because your posts and information shared through those public areas can be seen by others, we caution all users to consider what they post and not to disclose any personal information. FTW will not be responsible in the event that you disclose personal information in your posts, through our public services or during any other communication with other website users. - Third party service providers. We, like many businesses, sometimes engage other companies to perform certain business-related functions on our behalf so that we can focus on our core business. Examples of these services include, but are not limited to, website evaluation and data analysis, social media management, AI marketing automation and distribution, site search and discovery services and, where applicable, data cleansing, and payment processing and authorization and order fulfillment, marketing and promotional material distribution. We authorize them to use this Personal Data only in connection data security and privacy standards.
- Business transfers. We may sell, assign, buy, transfer or otherwise acquire or dispose of certain of our businesses or corporate assets. In the event of such or similar event, Personal Data we collected from you may be part of the transferred assets. We may also share Personal Data with our auditors, attorneys or other advisors in connection with the forgoing corporate transactions. You acknowledge and agree that any successor to or acquirer of us will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.
- Links to Third Party Platforms. We may provide you with the option to connect with third party services, including websites, applications and services through “plug-ins,” widgets, buttons and other third party features on and connect with our websites, communications or products. To do so, we may share your account registration data with such third party platforms to enable them to authenticate your account. We may also share your Project Data with such third party platforms to integrate multiple tracking tools. Third party platforms which we link to, may have information practices that are different from ours. This Privacy Policy does not apply to the activities of the third parties when they are collecting or using data for their own purpose or on behalf of others. We are not responsible for the activities of these third parties. We encourage you to review their privacy policies to understand how they use your information.
- Aggregate Data. In an ongoing effort to better understand and to serve the users of our Services, we may conduct research on our user demographics, professional backgrounds, interests and behavior based on Personal Data and other information that has been provided or received by us. This research may be compiled and analyzed on an aggregate basis, shared with members or third parties and this aggregate information does not identify you personally and will not be treated as Personal Data under this Privacy Policy
- Website Analytics. We may use analytics providers such as Google Analytics to track all user interactions with content on the site for the purposes of monitoring the performance. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/. For opt-out options specific to Google Analytics, please visithttps://tools.google.com/dlpage/gaoptout
- Legal requirements. We may disclose your Personal Data if required to do so by law (including, without limitation responding to a subpoena or request from law enforcement, court or government agency or other public authorities) or in the good faith belief that such action is necessary (i) to comply with a legal obligation, (ii) to protect or defend our rights, interests or property or that of other customers or users, (iii) to act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) to protect against legal liability or potential fraud, as determined in our sole discretion.
- Your consent. If we intend to use any of your Personal Data collected in any manner that is not specified herein, we will inform you of such anticipated use prior to or at the time at which such Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use. In short, we will honor the choices you make regarding your Personal Data and will inform you about any other intended uses of such information.
Users may follow FTW on Facebook, Instagram, Twitter and other social media platforms as made available from time to time. Users should click on the hyperlinks for each site to review the applicable privacy policies for more detail about information collected from these sites.
6. How Does FTW Comply with the Children’s Online Privacy Protection Act?
Our Services are directed toward a general audience and are not directed at nor intended for use by children. We do not knowingly collect information from children under the age of 13 without parental consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.
7. GDPR+ Data Protection Rights
If you are located in countries that are within the European Economic Area (the “EEA”), Switzerland or UK, GDPR and its Swiss and UK GDPR counterparts give you rights with respect to your personal data, subject to any exemptions provided by the law, including the following rights:
- Request access to your Personal Data;
- Request correction or deletion of your Personal Data;
- Object to our use and processing of your Personal Data;
- Request that we limit our use and processing of your Personal Data; and
- Request portability of your Personal Data.
You can usually access, correct, or delete your personal data by contacting us at [email protected]. We will consider all such requests and provide our responses as soon as we can. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include circumstances where we need to keep processing your personal information for our legitimate interests or to comply with a legal obligations. Users located in EEA, UK or Switzerland also have the right to make a complaint to a government supervisory authority.
8. Cross-Border Data Transfers
Sharing of information laid out in Section 4 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. FTW may also subcontract processing to, or share your Personal Data with, third parties located in countries other than your home country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Our Services are hosted on Firebase backed by Google Cloud Platform. Like FTW, helping to protect the confidentiality, integrity, and availability of customer data is of the utmost importance to Google, as is maintaining customer trust and confidence. Google is certified under the US-EU and US-Swiss Privacy Shields and, in compliance with the Privacy Shield Principles, act as our agent with regard to data privacy. Google relies on the Standard Contractual Clauses approved by the EU Commission, as amended from time to time, for data transfers. For more details of Google's privacy and security processes, please visit https://policies.google.com/privacy. By using our Services, you consent to your personal information being transferred to our servers as set out in this policy.
Where our Services allow for users located in the European Economic Area (“EEA”), UK or Switzerland, and when we transfer their Personal Data to countries outside of the EEA, UK or Switzerland as processors, we transfer the Personal Data in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures in place such as the Standard Contractual Clauses approved by the EU Commission, as amended from time to time. Standard Contractual Clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
9. California Privacy Rights
Shine the Light Law. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. We do not share your personal information with third parties for direct marketing purposes.
California Privacy Rights Act. As a nonprofit, we are not subject to California Privacy Rights Act (the “CPRA”), as CPRA is applicable to for-profit businesses only. Regardless, we do not sell personal information. However, we will closely monitor the development of the CPRA and other privacy laws that may apply to our activities and will implement reasonable administrative, technical and physical security measures for compliance.
10. How long does FTW retain information collected?
We follow generally accepted standards to store and protect the Personal Data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate. We retain Personal Data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records. If you have any questions about the security or retention of your Personal Data, you can contact us at [email protected].
11. What is FTW’s Security Policy?
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. However, although we endeavor to provide reasonable security for information we process and maintain, no security system can ever by 100% secure.
12. How Does FTW Respond to “Do Not Track” Signals?
“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, FTW does not respond to or alter its practices when a Do Not Track signal is received.
13. How Will I Be Notified of Changes to Your Privacy Policy?
If FTW makes material changes to its Privacy Policy, it will notify you by: (i) changing the Last Updated Date at the top of the Privacy Policy, (ii) sending an email to its users, and/or (iii) adding a statement to the Site.
14. Contact Us
If you have any questions regarding privacy while using our Services, or have questions about our practices, please contact us via email at [email protected].