FIRST® Lego® League Showcase Privacy Policy

See also: Legal Notices

Last Review and Updated: May 27, 2020

FIRST takes your privacy seriously. As a nonprofit and a mission-driven youth-serving organization, we are compelled to understand who we are serving, how our programs are performing, and make improvements so that we can achieve our goals of making FIRST accessible to any youth who wants to be part of the fun, exciting and life-changing experience. Thus, we need to collect certain pieces of data from you to ensure we are meeting our goals and responsibilities as a youth-serving nonprofit organization.

This FIRST Lego League Showcase Privacy Policy (“Privacy Policy”, or “Policy”) describes how FIRST ("FIRST," "our," "we," "us,") collects and processes  personal data that users (“user,” “your,” or “you”) provide to us by using theFIRST Lego League Showcase website (“Showcase”). This Privacy Policy also applies to personal data which FIRST obtains by other means, as described below.


Treatment of Data for Minor Youth

We are a 501(c) (3) nonprofit organization and are exempt from compliance with the United States Children’s Online Privacy Protection Act (COPPA).  Nevertheless, we choose to protect the privacy of children under the age of 13, residing outside of the European Union, within the spirit of COPPA, and those residing in the European Union as provided by the European Union General Data Protection Regulation (GDPR).

Youth under the age of 13 are not permitted to create accounts, create content, or provide personal data on the Showcase.

If we learn that we have personal data obtained directly from a child under 13 we will delete that data as soon as possible.


1. Agreement to the Policy

By uploading content to, or by accessing the Showcase, you agree to be bound by all of the Showcases’ Terms of Use and this Privacy Policy. If you do not agree to any of the Terms of Use or this Privacy Policy, please do not upload content or access or use the Showcase in order to avoid inadvertent data collection.  In the event you believe data was collected without your consent please see article 16 for instructions on how to contact us.

Please note that the Showcase is intended to be a public facing website.  All content uploaded to the website, including but not limited to, videos, images, voice recordings, written content, and messages are intended for public view.  

2. What personal data does FIRST Collect:

In the instances and for the reasons outlined in section 4,FIRST collects the following personal data categories:

Name, email address, date of birth, your affiliations with FIRST Strategic Alliances, FIRST Alumni status, FIRST program history, and your Internet Protocol (“IP”) address.  

 

3. How does FIRST collect the data:

We collect data when you provide it to us directly or indirectly through a third party and by “cookies” (as described in section 8, below). You may provide certain data to us when you: (a) register for the Showcase; (b) apply for, or be nominated for, awards; (c) send e-mail messages; (d) submit content to the Showcase; (e) transmit information by telephone or letter; (f) access certain forms or request information on the Showcase; (g) view content on the Showcase; (h) complete aFIRST Consent and Release form; (i) complete a survey or evaluation.

When you engage in certain activities on the Showcase, we may ask you to provide data by filling out and submitting an online form. Depending upon the activity, some of the data may be mandatory and some may be voluntary.  If you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity.

4. How does FIRST use the data:

By uploading content or entering personal data into the Showcase or providing it to FIRST (directly or indirectly through third parties), you agree to allow FIRST to collect and use the data for the following purposes:

  1. To register you for a Showcase account.
  2. To process and administer awards: FIRST may use your personal data to process and manage awards associated with the Showcase. Award applications may require personal information such as name and contact information and may be submitted by an individual or on behalf of an individual in the case of nominated awards.
  3. To comply with the FIRST Youth Protection PolicyFIRST contracts with certified background screening agencies to conduct background screening on coaches, volunteers, and staff. To conduct background screening, these agencies use your personal data and secure all data collected according to the process outlined on their privacy policy.  FIRST may receive the last 4 digits of your social security number (if provided), name, and screening status and uses this data only to determine eligibility to volunteer in any role at FIRST and may keep this data in a secured file.
  4. To communicate with you as a participant in the ShowcaseFIRST uses personal data to communicate with you about Showcase information and related opportunities.
  5. To improve our programs, products and servicesFIRST uses data to evaluate and improve our programs, understand who we are serving, assess program impact, report aggregate/de-identified data, monitor growth, improve the delivery of FIRST programs, improve our marketing and promotional efforts, improve our product and service-offerings, customize and improve our Sites’ content, layout, and services, diagnose problems with our servers, software, and administer our Sites, often with the assistance of our vendors. FIRST sometimes uses third parties to help implement, manage and evaluate programs and efforts, and may share personal data with those third parties only for the purposes outlined in this Policy.
  6. To improve quality and facilitate use of our Sites.FIRST may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies, to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of our Sites (for example, to facilitate navigation and the login process, enhance security, and preserve order information between sessions).

5. How long does FIRST retain data:

FIRST will retain your data until December 31, 2020, to fulfill the purposes and uses described in this Policy. When we no longer need your data, and there is no need to keep it to comply with our legal obligations or protect our legal rights, we will either delete it from our systems or depersonalize it so we can’t identify you.

If you wish to understand how to request your personal data be deleted, please refer to article 12 for more information.  In certain cases, the Showcase may link to data, videos, images, or written content that are hosted on a third-party site and are beyond the control ofFIRST, its partners, or its affiliates. In these cases,FIRST will remove all links to the third-party content from the Showcase upon request.  After links are removed, content may still be accessible when hosted by a third-party website.  Upon request,FIRST will make reasonable attempts to direct the third-party data owner of your request to remove the data.  First has no direct control over whether or not the third party complies with this request.

6. How does FIRST share data:

FIRST does not rent or sell data to others. We share personal data with local FIRST Program Delivery Partners, vendors, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate the Showcase, handle communications, or complete transactions you request.  

Except as otherwise provided in this Privacy Policy, FIRST will keep your personal data private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with the law or legal process served on us; (b) provide you the products, services and/or information that you may have requested; (c) protect our rights or property; (d) enforce our rights; (e) protect the interests of users of the Site or any other person; (f) operate or conduct maintenance and repair of our equipment; (g) detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law; and/or (h) otherwise comply with applicable laws.

7. How does FIRSTprotect information:

FIRST uses technical and organizational measures to protect data including, but not limited to: conducting third-party security audits, firewalls, maintaining security patches on external systems, a log auditing system to identify breaches, and ensuring that all web connections are over HTTPS.  Access to personal data is available through your user identification and password selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone and no one at FIRST or who represents FIRST will ever ask for your password. In addition, your personal data resides on a secure server to which only select FIRST personnel and Service Providers have secure access.

8. Cookies:

When you use the Showcase, we may store cookies on your computer in order to facilitate and customize the experience. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us.

Our cookies store randomly assigned user identification numbers, the country where you are located, and your log-in name to welcome you back to a Site. Our cookies: (a) make your use of the Showcase easier; (b) make the Showcase run more smoothly; (c) track authenticated users visiting the Showcase; and (d) help us to maintain Showcase security.

You may decline our cookies, but some parts of the Showcase may not work properly as a result. You can at any time use your browser setting to delete our cookies from your system. We may use a third party to display information on the Showcase. As part of the third-party service, they may place a separate cookie on your computer.  

9. Privacy Policies of Third-Party Sites:

We may maintain links to other websites on the Showcase, including third party content hosting sites and social media accounts not owned, managed, or controlled byFIRST, its partners, or its affiliates.  This Privacy Policy only applies to the Showcase.  Other sites accessible through our Site have their own privacy policies and data collection use and disclosure practices.  Please consult each site’s privacy policy.

10. How you can rectify incorrect information:

You have the ability to access and edit the personal data you provide to us. Data may be changed by logging into your FIRST user’s account, or by requesting a change in writing.  Requests in writing should be sent to privacy@firstinspires.org.

Please include your name, address, e-mail address, and/or phone number when you contact us regarding an update or correction to data.  We reserve the right to confirm your identity before updating or correcting personal data.  We encourage you to promptly update your personal data if it ever changes.

11. How you can object to certain uses of your data:

We may, from time to time, use your name or email to send you information regarding our programs, services and related opportunities as outlined in section 4.

If you do not wish to receive email from FIRST you may “opt-out” of receiving these communications by exercising your right to “opt out” by using the unsubscribe feature in the email or sending us an e-mail at privacy@firstinspires.org.

You also have choices with respect to cookies, as described in Section 8. By modifying your browser preferences, you generally have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Sites may not work properly.

12. How you can exercise your right to be forgotten:

You may request that your personal data at FIRST be deleted, by emailing privacy@firstinspires.org.  You will need to complete a request form and provide certain pieces of information so that we can confirm your identity at the time of your request.  We reserve the right to confirm your identity before taking any action to delete your data.  FIRST will assess each request to be forgotten on a case by case basis to determine the extent to which data can be deleted.  FIRST will comply with all requests to be forgotten except whereFIRST has a legal obligation to retain your data.

13. How you can exercise your right to data portability:

You have the right to receive a copy of the personal data you have provided to FIRST in a machine readable format by emailing privacy@firstinspires.org.

14. Transfer of data to other countries:

Because we are a global organization, FIRST may share your personal data with FIRST Program Delivery Partners in other countries in order to carry out the activities specified in this Policy. By submitting your personal data to FIRST, through FIRST Sites, or in connection with your interactions with FIRST offline, you consent to such transfers and to the processing of this information in any country where FIRST operates.

15. Changes to this Privacy Policy:

We reserve the right to change this Privacy Policy at any time.  Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, posting the revised Privacy Policy at any of our Sites. You acknowledge and agree that it is your responsibility to review the Site you are using and this Policy periodically, and to be aware of any modifications.  Your continued use of a Site after any such modifications will constitute your (a) acknowledgment of any modified Policy; and (b) agreement to abide and be bound by any modified Policy. To the extent that any modification to this Policy materially alters how FIRST will use information collected under a prior version of the Policy, FIRST will provide you notice by email using your email on file, and where required by law, will obtain your consent.

16. How to contact us and how to lodge a complaint:

FIRST has a Data Governance Team who represents FIRST and will lead investigative action, complaint handling and data breach notification. If you have any questions about this Privacy Policy, the practices of any of our Sites, or your dealings with any of our Sites, contact us via email privacy@firstinspires.org or by sending a letter to:

FIRST

200 Bedford Street

Manchester, NH  03101

Or you may call us at (800) 871-8326 or (603) 666-3906.