The @FirstSite products, services and website are owned and operated by the International Foundation for Online Responsibility (“IFFOR” or “We” or “we”). We understand how important privacy is to you. This policy explains how we process information that identifies you personally (“Personal Information”) when you visit the @FirstSite website or use, access or purchase any of our products and services (collectively referred to as “@FirstSite Services”).

This Privacy Policy explains:

• What Personal Information we collect and why we collect it
• How we use Personal Information
• Who we share Personal Information with
• How to access, update, and remove Personal Information

This policy applies only to Personal Information that we collect from and about you. It does not apply to information collected on third party sites that you may access via a link from @FirstSite Services.

Collection & Use of Personal Information

Information you Provide to @FIrstSite Services:

We collect Personal Information that you directly provide to @FirstSite Services, for example, when you submit a question or comment or request to receive updates or when you purchase any of our products or services. We may ask for your name, affiliation, job title, email address, country, financial information, etc. It is entirely up to you to decide whether or not to provide Personal Information. If you disagree with this Policy, please do not submit Personal Information on or to the @FirstSite Services.

Information Collected Automatically:

When you visit the @FirstSite website, our servers automatically log certain information including without limitation: the type of browser you are using (e.g., Safari, Chrome, Internet Explorer), the type of operating system you are using (e.g., Windows XP or Mac OS), the way you access the Internet (e.g., connection speed through narrowband or broadband access), IP address, other information about your geographic location, and the domain name of your Internet service provider. Our servers also log header information forwarded by the Internet site you navigated from to reach the @FirstSite website. Our servers may also log information about your activity on the @FirstSite website, including without limitation the time and date of your visits, the pages you view, your responses to offerings and advertisements (if any) presented on the website. Unless you have provided Personal Information directly, for example by registering for updates, we cannot and do not attempt to use log data to identify you personally.

Use of Personal Information Collected via @FirstSite Services:

We use Personal Information collected via @FirstSite Services to operate and improve the website, to fulfill your requests and respond to your inquiries, to provide access to our products and services, to deliver our products and services and to understand how you use our products and service.

Disclosure of Personal Information

We may disclose your Personal Information to fulfill your requests for products and services, to respond to your inquiries, to third parties as necessary to deliver services, and to personalize the content you see.

We do not share your sensitive information or Personal Information, with third parties without your affirmative consent unless it is: (i) necessary to fulfill a transaction or provide information you have requested; (ii) as required by law or necessary to respond to legal process; (iii) in circumstances in which we believe that the @FirstSite Services are being used in the commission of a crime; (iv) when we have a good faith belief that there is an emergency that poses a threat to your safety or the safety of another person; or (v) as necessary to establish, assert, defend, or protect our rights or property.

We may use agents and contractors in order to help operate the website, provide product and service offerings, and to operate our business. You expressly consent to the sharing of your Personal Information with our agents, contractors and service providers under the premise that, if our agents and contractors have access to your Personal Information, they are contractually required to safeguard that information and prohibited from using that information for any other purpose.

Change of Ownership

If IFFOR’s ownership changes as a result of a merger, acquisition or transfer to another company, your Personal Information may be transferred. If that transfer will result in a material change in the use of your Personal Information, IFFOR will notify you and give you the opportunity to decline to permit such a transfer.

Cookies and Web Beacons

We may use cookies, web beacons, or similar technologies in combination with your Personal Information to enhance and personalize your experience on the website, including without limitation to operate and improve offerings through the website, to help authenticate you when you use the website, to remember your preferences and registration information, to present and help measure and research the effectiveness of our offerings, advertisements, and e-mail communications (by determining which e-mails you open and act upon), and to customize the content, products and services provided to you.

Our Commitment to Security

We have implemented reasonable security measures designed to prevent unauthorized access to or misuse of the your Personal Information, but cannot guarantee that this information will never be disclosed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties that violate applicable law).

Processing Grounds

We will only use your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include contractual necessity, our legitimate interests or the legitimate interest of others or consent, as further described below.

Contractual Necessity: We process Personal Information because we need to provide products or services pursuant to our agreement with you. When we process Personal Information due to contractual necessity, failure to provide such Personal Information will result in your inability to use some or all portions of the products or services that require such information. An example of this is the ability to access our educational materials.

Legitimate Interest: We process the Personal Information when we believe doing so furthers the legitimate interest of third parties or us. Examples of these legitimate interests include operation and improvement of our business, products, and services; marketing of our products and services; provision of customer support; protection from fraud or security threats’ compliance with legal obligations; and completion of corporate transactions.

Consent: In some cases, we process Personal Information based on the consent you expressly grant to us at the time we collect such information. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection.

Your Privacy Choices

Opting Out

You can opt-out of certain activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.

Web Browser Controls: You can prevent the use of certain tracking tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:

• Delete existing Tracking Tools
• Disable future Tracking Tools
• Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set

Mobile Opt Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information.

Emails: We will give you the ability to opt-out of marketing-related emails by clicking on a link at the bottom of each such email. You cannot opt-out of receiving certain non-marketing emails regarding the services we provide.

Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, contact us at https://atfirstsite.org/#contact. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service.

Retaining Your Personal Information

We retain Personal Information about you for as long as you have an account with us or as otherwise necessary to provide you with services, and thereafter as set forth in our agreement with you (typically two years after termination of the service, or sooner upon request (except as required by law)). In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Information. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Your Rights and Choices Regarding Your Personal Information

Accessing, Correcting, and Deleting Your Personal Information

You have certain rights with respect to your Personal Information, and we want to help you review and update your information to ensure it is accurate and up-to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Information, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

You can contact us at https://atfirstsite.org/#contact directly if you have any additional requests or questions:

• Access: You can request more information about the Personal Information we hold about you and request a copy of such Personal Information.
• Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such information.
• Erasure: In certain circumstances, you can request that we erase some or all of your Personal Information from our systems. Please note that if you request the deletion of information required to provide a service to you, your account may be deactivated and/or you may lose access to the service.
• Portability: You can ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the information to another controller where technically feasible.

For the following, please contact us at https://atfirstsite.org/#contact

• Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our services.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Information for certain purposes, such as for marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Information.

You also have the right to lodge a complaint about IFFOR’s practices with respect to your Personal Information with the supervisory authority of your country or EU Member State.

EU Personal Information

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Information, as further described below. IFFOR will be the controller of your Personal Information processed in connection with the Service.

Special Note for Parents

The website is intended for adults. We do not knowingly collect information from children under eighteen.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, and will provide appropriate online notice of any significant changes. You may be provided other privacy-related information in connection with your use of specific product or service offerings, special features and services not described in this Policy, or products and services that may be introduced in the future.

Your California Privacy Rights

California privacy law allows California residents to obtain specific disclosures about a business’s privacy practices if it shares information with other companies for direct marketing purposes. To make a request to IFFOR under California’s privacy law, please contact us at https://atfirstsite.org/#contact.