This Privacy Policy for Economic Literacy and Growth Center Inc. (“we” “us,” or “our”) applies to all users of our website located at https://www.fingem.io (the “Website”) and our mobile application (the “Application”), as well as the features and functionality thereof (collectively, the “Services”). The Privacy Policy is designed to explain what information we collect and how we use it to provide our Services. This Privacy Policy is part of, and incorporated into, the Terms of Use [PROVIDE HYPERLINK].
By accessing and using the Services, you, the user (the “User,” “you,” or “your”), acknowledge our collection, storage, use, and disclosure of your personal information and other information as described in this Privacy Policy.
1. Information We Collect & Use
Some of the information we collect is provided by Users and some is collected automatically from devices.
Information You Provide
When you use the Services, you provide information to us. We collect data from students who have registered with and use the Services (“Students”) and from schools, administrators, and teachers that have acquired access to and use the Services (collectively, “Educators”). Examples of the information Students and Educators may provide are:
- Names
- Email addresses
- Physical addresses
- Phone numbers
- Grade levels of Students
- Payment methods and/or financial account information
- Comments on forums or other messaging functions on the Services
We do not collect any data defined as “educational records” under the Family Educational Rights and Privacy Act (“FERPA”). We do collect data about Students defined as “directory information” under FERPA, including Students’ names, grade levels, email addresses, and dates of attendance. At any time, parents or guardians of Students under the age of 18, and Students over the age of 18, have the right to contact us or those Students’ Educators in order to restrict our collection of those Students’ directory information. Parents or guardians may contact us at: [___________].
Information We Automatically Collect
When you use the Services, we and/or our third-party services providers may automatically collect information about how you use the Services and the devices you use to access the Services. Examples of the information collected automatically include Users’ IP address, access URL, time of access, browser type, and usage data about how you interact with the Services. We also collect Students’ performance data as they use the tools on the Services.
Cookies
The Services use cookies, which are text files containing small amounts of information that are downloaded on your device to store or collect information. We use cookies for authentication, security, and server-monitoring purposes. Cookies can help us learn about your online activity, including on other sites or the Services. Our service providers may also use cookies. You may be able to opt-out of certain cookies activity by adjusting the settings on your browser.
Third-Party Content, Links, or Plug-Ins:
The Services may have links to third-party websites or apps, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
2. How We Use Information & Lawful Bases
In general, we collect, use, and store your information to provide the Services, to fix and improve the Services, and to market the Services. Some specific examples of how we use information are to:
- Operate, maintain, enhance, and provide all of the features of our Services
- Register and administer accounts
- Analyze Students’ use of the Services’ tools and collect performance data about usage
- Provide Students’ data about usage of the Services to those Students’ Educators
- Communicate with Users about their accounts or activities
- Test changes in the Services and develop new features
- Analyze use of the Services and personalize content
- Prevent, detect, investigate and respond to fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior
- Comply with any procedures, laws, and regulations that apply to us
3. Retention
We keep your information for the period required to complete the purposes for which it is processed and to satisfy legal retention requirements. The length of time for which we retain information depends on the purposes for which we collected and use it and the requirements of applicable laws.
4. Information Sharing
We do not rent, sell, or share information except as described in this Privacy Policy.
Educators
A Student’s performance data from his or her usage of the Services may be shared with Educators from the school that Student attends.
Services Providers
We employ other companies and people to perform tasks on our behalf and need to share information with them so they can perform tasks, including hosting, cloud services, email delivery, business administration, and payment processing.
Public Information
Any information Users may disclose on public areas of the Services, including through comments or other messaging functions, becomes public information accessible to other Users.
Business Transfers
We may choose to buy or sell assets and may share or transfer user information (including personal information) in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, user information could be one of the assets transferred to or acquired by a third party.
Legal Requirements, Protection of and Others
We reserve the right to access, read, preserve, and disclose any information that we in good faith believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety our employees, Users, or others.
Consent
We may share your information in other ways if you have asked us to do so or have given your consent to do so.
6. Security
Accounts are protected by a password for your privacy and security. We recommend that you choose an appropriate password, safeguard your password, and limit access to the devices on which you access your account.
We use reasonable organizational and technical measures intended to protect the privacy of your account and personal information we use or store, but the internet and our Website are not 100% secure. We cannot guarantee complete privacy or security for the information that you provide or that we collect.
6. Choices & Rights
Access, Review, Correct
Through your account settings, you are able to access, edit, or delete information you have provided to us, including your name and password, email address, physical address, and phone number.
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have about you, please contact us at [___________].
Marketing and Email Communications
We may send you emails regarding our products and services. Only we, or the service providers operating on our behalf, will send you these emails. You can choose to not receive these emails by clicking the unsubscribe link in any email. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Services, or technical or security notices.
Deactivate Account
You may request deactivation of your account by clicking on “Deactivate Account” in your “Settings” and following the steps provided.
Rights
To the extent required by law, we provide Users with reasonable access to the personal information that we receive, a copy of the information, and the ability to review, correct, delete, restrict or object to the processing of such information.
Although we make good faith efforts to provide individuals with access to their information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the information is commercially proprietary. If we determines that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
For questions or complaints regarding our data use practices or Privacy Policy, please contact us at: [___________]
7. Children’s Privacy
We do not knowingly collect or solicit “personal information” (as defined by the U.S. Children’s Online Privacy Protection Act) from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information. If you believe that a child under 13 may have provided us personal information, please contact us at [___________].
Please review our Terms of Use [PROVIDE HYPERLINK] regarding age eligibility for use of the Services. If you are a parent or guardian of a Student, and you have questions about reviewing, modifying, or deleting that Student’s personal information, please contact that Student’s Educators or you may contact us at [___________].
8. Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and Services that you do not want your online activities tracked over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
9. Changes to Our Privacy Policy
We reserve the right to change, add, or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. Your continued use of the Services after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.
10. Contact Information
If you have any questions or concerns regarding this Privacy Policy or our use of your data, please send a message to [___________].