For the purposes of this policy, FLDC defines the term “User” as an entity with which FLDC has an established relationship, the term “Respondent” as any individual who responds to surveys powered by FLDC or who is included as a contact in a User’s account and the term “Visitor” as an individual that visits our front-end website (for example www.FaithAndLiberty.org) or mobile application.
Any information stored on FLDC’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. FLDC implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
2. COLLECTION AND USE
The following sections cover the specifics of each of the three groups from which data is collected: website Visitors, Respondents and Users.
As a general rule, FLDC does not collect PII about you when you visit our website, unless you choose to provide such information to us. Submitting PII through our website is voluntary. By doing so, you are giving FLDC your permission to use the information for the stated purpose. However, not providing certain information may result in FLDC’s inability to provide you with the service you desire.
If you choose to provide us with PII on an FLDC website, through such methods as completing a web form or sending us an email, we will use that information to help us provide you the information or service you have requested or to respond to your message. The information we may receive from you varies based on what you do when visiting our site.
Generally, the information requested by FLDC will be used to respond to your inquiry or to provide you with the service you request. When this information is requested, the reasons for collecting it, a description of FLDC’s intended use of the information, how to grant consent to use mandatorily provided information, and how to grant consent for other than statutorily mandated uses will be fully described in a separate customized “Privacy Notice.” This customized Privacy Notice will either appear on the web page collecting the information or be accessible through a hyperlink (link) prominently displayed immediately above or below the information request.
Many of our programs and websites allow you to send us an email. We will use the information you provide to respond to your inquiry. We will only send you general information via email. You should be reminded that email may not necessarily be secure against interception. Therefore, we suggest that you do not send sensitive personal data (such as your Social Security number) to us via email. If your intended email communication is very sensitive, or includes information such as your bank account, credit card, or Social Security number, you should instead send it by U.S. mail. Another alternative may be submission of data through a secure web page, if available.
Electronic mail messages that meet the definition of records in the Federal Records Act (44 U.S.C. 3101 et seq.) are covered under the same disposition schedule as all other Federal records. This means that emails you send us will be preserved and maintained for varying periods of time if those emails meet the definition of Federal records. Electronic messages that are not records are deleted when no longer needed.
2.2. WEBSITE and APplication VISITORS
If you are a Visitor to our website or application only, and not a Respondent to a survey or otherwise submitting information to us, then this section is relevant for you.
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website or application. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in FLDC products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between FLDC and yourself.
FLDC gathers data about visits to our websites and applications, including numbers of visits, Geo-location data, length of time spent on the site, pages clicked on or referring pages.
FLDC uses social media websites and other kinds of third-party websites. FLDC also uses web measurement and customization technologies to measure the number of visitors to our websites and their various actions and to help make our websites more useful to visitors. In such cases, the third-party application may request an email address, username, password, and geographic location (e.g., State, region, or ZIP code) for account registration purposes. FLDC does not use third-party websites to solicit and collect PII from individuals. Any PII passively collected (i.e., not solicited) by the third-party website will not be transmitted or stored; no PII will be disclosed, sold or transferred to any other entity unless required for law enforcement purposes or by statute.
FLDC retains the data from survey results as long as needed to support the mission of FLDC.
FLDC uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website and applications by analyzing how Visitors navigate.
Session: Session cookies last only as long as your web browser is open. Once you close your browser, the cookie is deleted. Websites may use session cookies for technical purposes such as to enable better navigation through the site, or to allow you to customize your preferences for interacting with the site.
Persistent: Persistent cookies are saved on a user’s hard drive in order to determine which users are new to the site or are returning
Respondents should be aware that in responding to surveys or survey invitations, they could be disclosing information that could make them personally identifiable to FLDC. The security and privacy protection implemented on FLDC’s platform does not cover this type of transfer or disclosure of personal information. Respondents responding to surveys or survey invitations should be aware that they alone are responsible for the content of their responses. For more detailed information concerning the protection of privacy when responding to surveys or survey invitations, Respondents may contact the entity conducting the survey. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. FLDC will not process Personal Data of Respondents for other purposes or by other means than instructed by its Users.
FLDC takes the security of all PII very seriously. We take precautions to maintain the security, confidentiality, and integrity of the information we collect at this site. Such measures include access controls designed to limit access to the information to the extent necessary to accomplish our mission. We also employ various security technologies to protect the information stored on our systems. We routinely test our security measures to ensure that they remain operational and effective.
We take the following steps to secure the information we collect:
- Employ internal access controls to ensure that only personnel who have access to your information are those with a need to do so to perform their official duties.
- Train appropriate personnel on our privacy and security policies and compliance requirements.
- Secure the areas where we retain paper copies of the information we collect online.
- Perform regular backups of the information we collect online to ensure against loss.
- Use technical controls to secure the information we collect online including, but not limited to:
- Secure Socket Layer (SSL)
- Password protections
- Periodically test our security procedures to ensure personnel and technical compliance.
- Employ external access safeguards to identify and prevent unauthorized access by outsiders that attempt to “hack” into, or cause harm to, the information contained in our systems.
We hold our contractors and other third-party providers to the same high standards that we use to ensure the security, confidentiality, and integrity of personal information they may have access to in the course of their work completed on behalf of FLDC.
Interaction with Children Online
FLDC is committed to the protection of children’s online privacy. The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information from a child under age 13. If a website intends to collect information about children under 13 years old, COPPA-required information and instructions will be provided by the specific web page that collects information about the child. The web page will specify exactly what the information will be used for, who will see it, and how long it will be kept.
In order to provide services to its Users, FLDC collects certain types of data from them. Furthermore, FLDC’s Users collect information from Respondents when they produce and distribute surveys. This section will describe how these two types of data are collected and used by FLDC as well as geographical differences that effect this policy. Data entered or transferred into FLDC by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by FLDC without express consent from the User.
During a User’s registration and interacgtions with the website or application, , they provide information such as name, company name, email, address, telephone, credit-card number and other relevant data. This information is used by FLDC to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.
Respondent data includes data from individuals uploaded, transferred or manually entered by a FLDC User into their account for the purpose of providing feedback to the User by responding to surveys. Personal Data may include, personal contact information such as name, home address, home telephone or mobile number, email address, information concerning family, lifestyle and social circumstances including age, date of birth, marital status, number of children, employment details, education/qualification, business contact details, gender, religion, race, health detail and other sensitive Personal Data. Answers to questions by Respondents, may also include Personal Data.
FLDC has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU/GDPR safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the web site visitor/User’s data in FLDC’s possession. FLDC will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.
All data collected by FLDC Users through web visits or surveys will be stored exclusively in secure hosting facilities. FLDC’s contract with its hosting providers ensures that all hosting is performed in accordance with the highest security regulations. FLDC’s policy is to protect and safeguard any personal information obtained by FLDC in accordance with International, United States state or federal laws governing the protection of personal information and data. Accordingly, FLDC adheres to practices and policies that aim to safeguard the data.
FLDC will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Respondent data, FLDC’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Respondent data, Users with an active account will therefore have the responsibility to delete data when required. When a user’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
4. ACCEPTANCE OF THESE CONDITIONS
5. OUR LEGAL OBLIGATION TO DISCLOSE PERSONAL INFORMATION
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to FLDC or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.