November 16, 2018

COPPA

PFG SUPPLEMENT TO PPP FOR COPPA PRIVACY

(“COPPA POLICY”)

PFG specially values the privacy of children as users of Site and PFG App. This COPPA Policy is designed to comply with the Children’s Online Privacy Protection Act  and contains important information about how we collect, use, and disclose the personal identifiable information of children under age of 13 years (“Children”) who use the PFG website at www.passportforgood.com (“Site”) and the PFG computer programs (“Software”) which are either, web enabled at the Site or mobile enabled by way of the PFG mobile application for IOS and Android (“PFG App”).

This COPPA Policy is supplemental to the PPP https://www.passportforgood.com/privacy-policy/.

This COPPA Policy applies to the information we collect from Children through use of the Site and PFG App.

PFG will handle Children’s personal identifiable information as described in this COPPA Policy.

PFG will handle Children’s data, other than personal identifiable information as described in the PPP.

Any personal identifiable information we collect from non-Children (e.g., teens and adults) will be treated in accordance with the PFG Privacy Policy (“PPP”) https://www.passportforgood.com/privacy-policy/.

Who Will Collect?

PFG operates the Site and the PFG App and will collect Children’s personal identifiable information as described in this COPPA Policy. We can be contacted at:

Mailing Address: 333 Broadway – 4th Floor, Troy, New York 12180

Email Address: support@passportforgood.com

Phone Number: (844) 557-4461

What Do We Collect and Why?

As described in further detail below, we collect some personal identifiable information from Children to accomplish the intended purpose of the Site and the PFG App, including, identifying and tracking volunteer hours and these opportunities in a Children’s communities.

We do this to encourage volunteerism and provide Children an easy and reliable method of tracking, verifying and documenting such participation.

How Do We Collect?

We may collect personal identifiable information about Children directly from Children, as well as automatically through a child’s use of the Site and the PFG App. We will not require a child to disclose more personal identifiable information than is reasonably necessary to use the Site or the PFG App. We do provide parents with a copy of a notice of our privacy policies through the PFG Client and also post such on the Site and the PFG App.

Specific Collection

From Children, we specifically collect their usernames, date of birth, address, phone number, email address, school, and graduation year, clubs and organizations of which the child is a member or volunteer, profile photograph (optional), and the identity and location of the organization for which the child performs services.

We Collect Statistics

We may automatically collect statistical information about a child’s use of the Site and the PFG App through cookies and other technologies.  Usage of a cookie is in no way linked to personal identifiable information.  The child may always choose not to accept cookies, but he or she may not be able to use the Site or the PFG App.

What Else We Collect?

We collect data about Children’s performance and activities through his or her use of the Site or the PFG App. This data is for internal use only and if applicable, before we analyze or use any activity data for any purposes, we de-identify and/or aggregate such data.

How We Use

We use personal identifiable information collected from Children for the following purposes:

  • To provide the Site and PFG App for their intended use; and
  • To respond to customer service and technical support issues and requests.

We de-identify and/or aggregate the information we collect from Children before we use it for any other purposes.

Unique Identifiers. We only collect and use unique identifiers, such as IP addresses, as necessary to operate the Site and PFG App, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users of the Site and PFG App. We never use unique identifiers to track users across third-party apps or websites.

Aggregate or De-identified Information. We may use aggregate or de-identified information about Children for research, analysis, and similar purposes. When we do so, we strip out names, email, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:

  • To better understand how users access and use the Site and PFG App;
  • To improve the Site and PFG App and respond to user desires and preferences; and
  • To conduct research or analysis, including, research and analysis by third parties.

How We Share

We do not sell Children’s personal identifiable information, and a child may not make his or her personal identifiable information public through the Site or PFG App. PFG will only disclose Children’s personal identifiable information, if required to do so by applicable rules, regulations and laws, or as otherwise stated in this COPPA Policy, or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on PFG; (2) protect and defend the rights or property of PFG and others, including among other things to enforce our contracts; (3) act under exigent circumstances to protect the personal safety of Children or the public; (4) to correct technical problems and malfunctions in how we provide our Site and PFG App to you and to technically process Children’s personal identifiable information; (5) to take precautions against liability; (6) to respond to claims that the rights or interests of a third party have been violated; or (7) as permitted or required by law to respond to law enforcement agencies. Also, certain technical processing of Children’s personal identifiable information is required for: (1) providing the Site and PFG App; (2) conforming to technical requirements of connecting networks; (3) conforming to the limitations of the Site or the PFG App; or (4) other similar technical connecting requirements.

We may disclose aggregated information about Children and information that does not personally identify any child, without restriction.

Your Rights to Stop, Review, Delete, and Control

Parents may ask us to stop collecting personal identifiable information from their child by emailing us at support@passportforgood.com; however, in such cases the child may not be able to use the Site or the PFG App at all or to its fullest extent. If a parent directs us to stop collecting and using a child’s personal identifiable information, we must disable his or her use of the Site and the PFG App to ensure that no personal identifiable information is collected.

Parents have a right to review the personal identifiable information we have collected about their Children, to delete it, and/or to tell us to stop using it. To exercise these rights, you may contact us at support@passportforgood.com.

As a parent, you will be required to authenticate yourself as the child’s parent to receive personal identifiable information about that child.

If a child is inactive on the Site or the PFG App for at least twelve months (meaning, that the child has not accessed the Site or the PFG App in that time), PFG shall delete the personally-identifiable information associated with the account of that child.

Please note that copies of personal identifiable information may remain in a cached or archived form on PFG’s systems or the systems of PFG’s information technology service providers after you request us to delete it.

Changes to This COPPA Policy

We may change this COPPA Policy from time to time, so please be sure to check the Site and the PFG App periodically and also look for any communications from PFG regarding such. We will post any changes to this COPPA Policy on our Site or the PFG App

If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal identifiable information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on the Site and the PFG App.

General

In the event of any conflict or inconsistency between this COPPA Policy and PPP, in respect to Children, the terms of this COPPA Policy shall control.

 

Rev. 11/2018