Privacy Policy

Our Privacy Commitment

Last Updated: December 14th, 2018

The Family Online Safety Institute (“FOSI”) respects the privacy rights of our online visitors and recognizes the importance of protecting all information that you may choose to share with us. To further this commitment, we have adopted this online privacy policy (“Privacy Policy”) to guide how we collect, store, and use the information you provide us via this website (“Website”).

FOSI is a valid licensee, and participating member, of theEntertainment Software Rating Board's Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had our Website where this Privacy Policy is posted reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, we are subject to audits of our Website and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

Table of Contents

Q1. What information does this Privacy Policy cover? Q2. What types of information do we collect about you? Q3. How is your personally identifiable information used and shared? Q4. What choices do you have about the collection, use, and sharing of your personally identifiable information? Q5. What are your California Privacy Rights? Q6. Where do we store your personal information? Q7. What kinds of security measures do we take to safeguard your personal information? Q8. How can you update your personal information and profile? Q9. How can you ask questions, or send us comments, about this Privacy Policy? Q10. How will you know if we amend this Privacy Policy?

Q1. What information does this Privacy Policy cover?

This Privacy Policy applies to information collected on the Website where this Privacy Policy is posted, and does not apply to any other information collected by FOSI through any other means. This Privacy Policy applies to our use, sharing and processing of information collected on and after the date that this Privacy Policy is posted.

Please note that this Privacy Policy applies only to information submitted and collected online, and does not apply to information that may be collected by FOSI offline. Finally, the terms of this Privacy Policy are subject to all applicable laws.

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Q2. What types of information do we collect about you?

With the exception of your Internet Protocol (IP) address, we do not require personal information to access our Website. If you prefer not to disclose personal information, you may not be able to enjoy certain features of our Website. Personal information is information that identifies you and may be used to contact you. 


CHILDREN

We do not knowingly collect personal information from children under 16. We take kids' privacy seriously and encourage parents to play an active role in their children's online experiences at all times. If it is discovered that we have unintentionally collected information from a user under the age of 16, we will delete the child's information. If parents believe that we have unintentionally collected their child’s personal information, they should contact us to request the deletion of the information at fosi@fosi.org.


INFORMATION YOU PROVIDE US

Except as otherwise set forth in this Privacy Policy, FOSI only collects personal information from you on a voluntary basis. When you submit personal information to FOSI, it will take the form of customer or technical support inquiries.

The information we collect includes personal information such as your:

  1. Name; and
  2. Email address.

Additionally, we and our third-party service providers may also collect other types of non-personal information (known as demographic information) such as your country and occupation. This demographic information may be associated with your personal information. 


INFORMATION COLLECTED THROUGH THIRD PARTIES

In certain instances, we collect information from you through our third-party service providers. FOSI, like many other website operators, uses Google Analytics for the purpose of analyzing our user base and improving the performance of our Website and services. If you wish to learn more about Google Analytics, including how to opt-out, please visit https://tools.google.com/dlpage/gaoptout

We use MailChimp as a third-party email service provider, and may collect your IP address and general location information (such as city and state) from them. Additionally, your credit card information may be shared with us if you submit a donation to us via PayPal or register for one of our events through Eventbrite.


INFORMATION COLLECTED THROUGH TECHNOLOGY

We collect information through technology to make our Website more interesting and useful to you. For example, when you visit our Website, we collect your IP address. At times, we also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our Website. We will mask your IP address so that it does not remain in its original form.

Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.


COOKIES

Our Website uses cookies. Cookies are pieces of information that a website sends to your computer while you are viewing the website. We and other companies use cookies for a variety of purposes.  You can choose to have your computer warn you each time a cookie is sent, or you can choose to turn off all cookies. You can do this through your browser (like Google Chrome or Firefox) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your settings. If you turn cookies off, you may not have access to some of features that make your web experience smoother and some of our services may not function properly. By using our Website you agree, and we will assume you consent, to receive cookies through our Website unless you change your browser settings to disable cookies. You can withdraw your permission to receive cookies at any time by changing your browser settings to disable cookies.  For Google Analytics cookies, please see the opt-out information identified above.

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Q3. How is your personally identifiable information used and shared?

Whatever the purpose may be, we will only collect personal information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives. We will maintain the personal information we collect only as long as reasonably necessary to fulfill the purposes for which it was collected, after which we will securely delete it absent a legal obligation to maintain possession (e.g., tax obligations). FOSI will only share information with third parties as described in this Privacy Policy. We may share personal information and non-personal information with certain third parties selected by us to help support our operations, including improving our Website, software or the services we provide our customers. These third parties may have access to your information only for purposes of performing tasks on our behalf, and they are contractually required to protect your information consistent with this Privacy Policy.


OPERATIONAL USES

We may also use your personal information for other purposes such as "Operational Uses." For example, we may use your information to send you administrative communications either about your account with us or about features of our Website.

We occasionally employ other companies to perform services necessary to our internal operations. For example, we have partnered with other companies to personalize our web pages and analyze customers' interaction with our Website. While providing their services, these companies may access your personal information. These companies have agreed to securely store and maintain the personal information received from us and will only use the information for the designated purpose.


AGGREGATE INFORMATION

Finally, we may take your personal information and make it non-personally identifiable. We do this either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (e.g., your name) that make the information personally identifiable to you. This process is known as de-personalizing your information. Given the non-personal nature of this information, no restrictions apply under this Privacy Policy on our right to de-personalize your personal information. We may use de-personalized information in any way and share it with third parties without your consent.


SALE OF BUSINESSES

If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personal information in the same way required by this Privacy Policy (including any amendments to this Privacy Policy). The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.


THIRD PARTY USE

Our company does not share and has not reserved the right to share personal or demographic information with third parties for their direct marketing purposes.


DISCLOSURES REQUIRED BY LAW AND DISCLOSURES TO HELP PROTECT THE SECURITY AND SAFETY OF OUR WEBSITE AND OTHERS

We will disclose personal information when we believe in good faith that disclosure is required by law (e.g., court order or subpoena) or to help enforce:

  1. Our Terms of Use;
  2. Protect your safety or security, including the safety and security of your property; or
  3. Protect the safety and security of our Website or third-party websites.

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Q4. What choices do you have about the collection, use, and sharing of your personally identifiable information?

If you have any questions about any of our third-party service providers, please e-mail us at fosi@fosi.org. In certain cases, we may still retain your information to resolve disputes, enforce our Terms of Use, or comply with legal requirements; in these instances, your personal information will be blocked from use for any other purpose.

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Q5. What are your California Privacy Rights?

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please write us:

Family Online Safety Institute

Attn.: Privacy Policy

1440 G Street, NW

Washington, D.C. 20005

fosi@fosi.org

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Q6. Where do we store your personal information?

Personal information collected through the Website is stored on servers hosted by Heroku. This data may be transferred outside of your country to the United States. To ensure the protection of personal information collected in and transferred out of the European Economic Area, Heroku has certified to comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce and enforced by the Federal Trade Commission. For additional information, please click here.

Additionally, some of your personal information may be transferred to our third-party service providers, Eventbrite and Mailchimp, in the United States.  Both Eventbrite and Mailchimp have also certified to comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. For additional information, please click here.

FOSI is committed to resolving any complaints regarding your privacy and our collection and use of your information. For inquiries or complaints regarding the processing of personal information transmitted to FOSI from the European Union, European Economic Area or Switzerland, please contact us by sending a letter to: Family Online Safety Institute; Attn: Privacy, 1440 G Street, NW, Washington DC 20005, or by emailing us at fosi@fosi.org.

Additionally, at any time, a European Union or Swiss individual may submit a complaint directly to his or her local European Union data protection authority or the Swiss Federal Data Protection and Information Commissioner, as applicable.

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Q7. What kinds of security measures do we take to safeguard your personal information?

The security and confidentiality of your information is extremely important to us. That's why we have technical, administrative and physical security measures in place to protect your personal information from unauthorized access and improper use. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our best efforts, no security measure is ever perfect or impenetrable. Specific security measures we currently implement to prevent unauthorized physical or electronic access to web users' personal:

  • Web user data is stored behind a firewall.
  • Data is stored in a secure physical environment (e.g. behind locked doors)
  • Data is stored in a database accessible to authorized employees on a need-to-know basis only
  • Users or employees must have a unique password before gaining access to user data

We maintain written security policies to which all employees must adhere.

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Q8. How can you update your personal information and profile?

You are entitled to know what personal information we hold about you and to have any inaccuracies in your personal information corrected. You can access and update or request the deletion of the personal information you previously gave us; request a portable copy of your personal information; or object to our processing of your personal information, which you may do by e-mailing us at fosi@fosi.org.

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Q9. How can you ask questions, or send us comments, about this Privacy Policy?

If you have questions or wish to send us comments about this Privacy Policy, please contact us with questions or comments at:

Family Online Safety Institute

Attn.: Privacy Policy

1440 G Street, NW

Washington, D.C. 20005

fosi@fosi.org


Special contact information for EU residents:

Family Online Safety Institute

Attn.: Stephen Balkam, Data Protection Officer

1440 G Street, NW

Washington, D.C. 20005


As aforementioned, FOSI is a licensee of the ESRB's Privacy Certified Program. If you believe we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at https://www.esrb.org/privacy/contact.aspx or 


ESRB

Attn: Vice President, Privacy Certified Program

420 Lexington Avenue, Suite 2240

New York, NY 10170

privacy@esrb.org

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Q10. How will you know if we amend this Privacy Policy?

We may amend this Privacy Policy at any time. If we make any material changes in how we collect, use, or share your personal information, we will send you a private message and/or prominently post a notice of the changes on the Website covered by this Privacy Policy. If we make any material changes to this Privacy Policy that retroactively impact the way in which we use or disclose personal information already collected from you, we will attempt to notify you directly and obtain your sent to those changes.

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