Website Privacy Policy

Last Updated April 15, 2024

Network For Teaching Entrepreneurship (“NFTE,” “we,” or “us”) understands that privacy is tremendously important to our online visitors to our website and to users who donate to, or volunteer with, our organization (“Donors” and “Volunteers”, respectively). This privacy policy (the “Privacy Policy”) applies to our website, www.nfte.com and associated webpages (collectively, the “Site”) and will help you understand how we collect, use and safeguard the personal information provided to us on or in connection with the Site.

This Privacy Policy is part of our Website Terms of Service [https://nfte.com/privacy-policy/] applicable to the Site (the “Terms”).  By using the Site or submitting any content, materials, or other information via the Site (“Submissions”), you acknowledge that you have read and agree to this Privacy Policy.  If you do not agree with this Privacy Policy, you may not use the Site or make any Submissions. 

A Special Note for International Visitors to our Site:   Our computer systems are currently based in the United States, so your personally identifiable information will be processed by us in the United States, where data protection and privacy regulations may be different than other parts of the world, such as the European Union.  If you visit the Site as a visitor from outside the United States, you are agreeing to the terms of this Privacy Policy and our Terms, and you will have consented to the transfer and processing of all such information in the United States, which may not offer an equivalent level of protection of that in the European Union or certain other countries. 

This Privacy Policy provides the following information:

  1. How We Collect and Use Information
  2. How We Share Information
  3. How We Protect Your Information
  4. Choices About Your Information
  5. Children’s Privacy
  6. Links to Other Websites and Services
  7. Additional State Privacy Rights
  8. How to Contact Us
  9. Changes to This Privacy Policy

Transparency. We will always be transparent with the methods we use to collect data and describe exactly how we will use it to the benefit and strict direction of our users and their users.

We collect the following types of information:

Information about Users: We ask for certain information when a user asks for more information regarding our products or services, makes a donation or registers as a volunteer, or otherwise corresponds with us online, which may include a name, email address, phone number, message content and/or payment information. We may also collect information provided by a user if the user sends us a message, posts content to the Site, or responds to emails or surveys. We also collect and retain data regarding your use of the Site (e.g. the duration of a page visit, information downloaded, etc.) automatically when you use the Site. Once a user becomes a Donor or Volunteer, we will keep records of such activities. We use this information for the following purposes:

  • To provide and maintain our Site, including to monitor the usage of our Site.
  • To manage your relationship with NFTE as a Donor or Volunteer. The personal data you provide will enable us to provide you with information regarding your donation or volunteer activities and to facilitate the same. 
  • For the performance of a contract for the products, items or services you have purchased or of any other contract with us through the Site.
  • To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other products and services we offer or that we believe may be of interest to you, unless you have opted not to receive such information. You always have the option to opt out of our internal marketing communications by contacting us at [email protected] or by following the opt-out procedure outlined in such communications.  Please note that opting out of receiving these communications will not remove your personal information from our files and we will still contact you as necessary to provide and support products and services you have ordered or purchased from us at your request. 
  • To manage your requests to us.
  • To evaluate or conduct a business transfer, which may be structured as a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our Site users is among the assets transferred.
  • For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience.

Information Collected through Technology: We automatically collect certain types of usage information when visitors view the Site. We may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Site (e.g., the pages you view, the links you click and other actions you take on the Site), and allows us to track your usage of the Site over time. We may collect log file information from your browser or mobile device each time you access the Site. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, number of clicks and how you interact with links on the Site, pages viewed, features used, and other such information. We may employ clear gifs (also known as web beacons), which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Site. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site. We do not allow third party advertising networks to collect information about the users of our Site.

We use or may use the data collected through cookies, log files, device identifiers, clear gifs information and other similar data (collectively, “Cookies”) to: (i) remember information so that a user will not have to re-enter it during subsequent visits; (ii) provide custom, personalized content and information; (iii) to provide and monitor the functionality and effectiveness of our Site; (iv) monitor aggregate metrics such as total number of visitors, traffic, and usage on our Site; (v) diagnose or fix technology problems; and (vi) help users efficiently access information after signing in.  We may also disclose such data and information to our third party partners whose services or applications interact or interface with our Site, but only as described in this Privacy Policy.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide you with services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.

  • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Site.

  • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time You use the Site.

Publicly Available Information: Please be advised that some information you provide may be publicly accessible, such as information posted in forums, fundraiser descriptions, donation posts, or comment sections (“Publicly Available Information”). Content, including such posted information, comments, feedback, and notes that you choose to post through features of our Site available to the public becomes public information for both us and other users to use and share as “Submissions” under our Terms. Please do not disclose Personal Information unless you intend for that data to become public. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Site, and to remove postings or content that may be viewed as inappropriate or offensive to others. You further agree that we are under no obligation of confidentiality, express or implied, with respect to the Publicly Available Information and may use this information as described in this Privacy Policy.

NFTE only shares personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes.

  • With third-party providers whose software or services interface with or otherwise may receive information from, or provide information to, the Site or our other systems, but only as directed or approved by our users or as necessary for us to fulfill requests submitted by our customers.
  • With third-party providers that provide us with technology or other support services (e.g. web hosting and analytics services), but strictly for the purpose of carrying out their work for us. We will use reasonable efforts to identify these providers in this Policy, but reserve the right to change these providers from time to time with or without notice to you.
  • With third party partners that host, provide services to or otherwise support Donor or Volunteer activities or events, but strictly for the purpose of providing or carrying out such event
  • With our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any companies that control, are controlled by or are under common control with NFTE.
  • With other users with whom you share information or otherwise interact with via interactive features of our Site; any information shared in such forums may be viewed by all users with appropriate access permissions and may be publicly distributed outside.
  • With Your consent, we may use or disclose your personal information for any other purpose. For Donors, unless you specify that a gift be “anonymous” or otherwise request that your name not be listed, we may include your name in lists of donors that appear in our brochures, on the Site, and in benefit programs to recognize the generosity of those who have given to our cause. We do not sell our donor lists to anyone, nor do we include donor lists in direct mail solicitations. You are deemed to have consented to such disclosure unless you specify that a gift be “anonymous” or opt-out of such disclosure by submitting such a request to [email protected].
  • With law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Terms, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users or our company, or otherwise to protect against a legal liability or to comply with a legal obligation.
  • In the event of a change of control (e.g., if we sell, divest or transfer the business or a portion of our business), we may transfer information to the new owner of the business.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We currently use the following tools to provide services to our users. User data may be shared with these providers and will be governed by the privacy policy of such providers. You may be able to opt-out of the use of these tools by visiting the applicable provider’s website and utilizing their information management tools:

Instructure, Inc

We store our data in the United States, and we take reasonable measures to keep data safe and secure.

Storage and Processing: Any information collected through our Site is stored and processed in the United States. If you access or use our Site outside of the United States, you consent to have your data transferred to the United States.

Keeping Your Information Safe: NFTE maintains industry standard administrative, technical and physical procedures to protect information stored in the servers we utilize, which are located in the United States. While no service provider can guarantee absolute security when communicating over the internet or wireless networks, we are committed to taking steps to help secure any personal information that may be in our possession.  Access to information is limited (through user/password credentials and optional two factor authentication) to those employees and agents who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard personal information submitted via the Site, and payment information provided online is submitted and stored through a PCI-compliant third-party provider (currently Stripe, Inc., whose privacy policy can be found here, [https://stripe.com/privacy]). Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our files.  Regardless, you should always be mindful and responsible whenever disclosing information online that the information is potentially accessible to the public, and consequently, could be collected and used by others without your consent.

4.   CHOICES ABOUT YOUR INFORMATION

User Information: Users and other website visitors can opt-out of receiving promotional email from us by clicking on the “unsubscribe” feature at the bottom of each email. Users and other website visitors. You cannot unsubscribe from messages related to your donations or volunteer activities.

If you have any questions about reviewing or modifying user information maintained in our files, contact us directly at [email protected] or [email protected].

Deleting or Disabling Cookies:  Certain parts of our Site require Cookies on your browser to work.  If you disable cookies, such features of the Site may not work properly. You can instruct your browser to refuse all browser Cookies or to indicate when a browser Cookie is being sent. For more information on how you can delete flash Cookies (i.e., local stored objects), please search the “Help” index of your browser or read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

How Long We Keep User Content: NFTE may retain user personal information for a commercially reasonable time for backup, archival, or legal compliance and audit purposes. We may maintain anonymized or aggregated data, including usage data, for analytics purposes.  Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

If you have any questions about data retention or deletion, please contact [email protected]  or [email protected].

NFTE does not knowingly collect any information from children under the age of 13. FURTHER, BY USING THE SITE, YOU ARE ATTESTING THAT YOU ARE 18 YEARS OF AGE OR OLDER.  Please contact us at [email protected] if you believe we have inadvertently collected personal information from a child under 13 without proper parental consents so that we may delete such data as soon as possible. We do not knowingly collect any names or other identifying details regarding children.

6.   LINKS TO OTHER WEB SITES AND APPLICATIONS

Please remember that this Privacy Policy applies to our Site only and not other websites or third-party websites or software applications that may be linked via our Site (“Linked Sites”, under the Terms), which may have their own privacy policies. You should carefully read the privacy practices of each Linked Site before agreeing to engage with the Linked Site through the Site. We assume no responsibility or liability for the privacy practices of any vendor or operator of Linked Sites.

7.   ADDITIONAL STATE PRIVACY RIGHTS

Certain states, such as California, Nevada, Connecticut, Colorado, Virginia and Utah, have consumer privacy laws that may provide their residents with additional rights regarding our use of their personal information.  This section is applicable to residents of such states (sometimes called “consumers”), as applicable, who live in the applicable state on a permanent basis. This section uses certain terms that have the meaning given to them in each state’s privacy law, as applicable, including “Personal Information”, which shall be used interchangeably with privacy laws that similarly define “Personal Data”.

I. Shine The Light

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the CONTACT US section below with a reference to California Disclosure Information.

II. California Consumer Privacy Act Of 2018, As Revised And Updated By The California Privacy Rights Act (Collectively, “CCPA”)

A.   Collection, Disclosure, and Retention of Personal Information

The Personal Information we collect and the sources from which we collect is described above in HOW WE COLLECT AND USE INFORMATION. The Personal Information we disclose for business or commercial purposes is described above in HOW WE SHARE INFORMATION. The length of time that we retain your Personal Information is described above in CHOICES ABOUT YOUR INFORMATION.

B.   Selling and Sharing Personal Information

We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please reference the above HOW WE SHARE YOUR INFORMATION regarding opting out of the use of these tools.

C.   CCPA Consumer Rights

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

  • Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
  • The categories of Personal Information that we collected about you;
    • The categories of sources from which the Personal Information is collected;
    • The business or commercial purpose for collecting or selling Personal Information;
    • The categories of third parties with whom we share Personal Information;
    • The specific pieces of Personal Information that we have collected about you;
    • The categories of Personal Information that we disclosed about you for a business purpose or sold to third parties; and
    • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
  • Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
  • Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell your Personal Information in exchange for monetary consideration. We may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please see the above HOW WE SHARE YOUR INFORMATION section for more information regarding opting out of the use of these tools.
  • Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16 without proper consent of a parent or guardian.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for certain reasons outside of providing the Site. However, we do not collect or process Sensitive Personal Information for any of these reasons.
  • Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

If you would like to exercise any of the rights provided, please refer to the CONSUMER REQUESTS AND VERIFICATION section below.

III. Virginia, Colorado, Connecticut, Utah Privacy Rights

This section applies only to Virginia, Colorado, Connecticut residents to the extent their Personal Information is subject to the Virginia Consumer Data Protection Act (VCDPA), or the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA) or any amendments or acts thereto upon their effective dates.

A.   Collection, Disclosure, and Retention of Personal Information

The Personal Information we collect and the sources from which we collect is described above in HOW WE COLLECT AND USE INFORMATION. The Personal Information we disclose for business or commercial purposes is described above in HOW WE SHARE INFORMATION. The length of time that we retain your Personal Information is described above in CHOICES ABOUT YOUR INFORMATION.

B.   Consumer Rights

Virginia, Colorado, Connecticut, and Utah privacy law provides residents with specific rights regarding Personal Information, including:

  • Right to Access. You have the right to confirm whether or not we are processing your Personal Information and to access such information.
  • Right to Correction. You have the right to correct inaccuracies in your Personal Information which we have collected, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
  • Right to Deletion. You have the right to request deletion of Personal Information provided by or obtained about you, subject to legal exemptions.
  • Right to Data Portability. You have the right to obtain a copy of your Personal Information.
  • Right to Opt-Out. You have the right to opt out of the processing of Personal Information for purposes of (1) targeted advertising; (2) the sale of Personal Information; or, if you are in Virginia or Colorado (3) profiling in furtherance of decisions that produce legal or similarly significant effects.

If you would like to exercise any of the rights provided, please refer to the CONSUMER REQUESTS AND VERIFICATION section below.

IV.      NEVADA PRIVACY RIGHTS

We comply with the requirements of the Nevada Privacy law, which in some instances provides residents with choices regarding how we share information. Nevada Covered Personal Information (“Nevada PI”) includes personally identifiable information about a Nevada consumer collected online, such as an identifier that allows the specific individual to be contacted. Nevada PI also includes any other information about a Nevada consumer collected online that can be combined with an identifier to identify the specific individual. We may collect the following categories of covered information about you through our Site:

  • First and Last Name
  • Physical Address
  • Email Address
  • Telephone Number

We may share such covered information with categories of third parties including marketing. Third parties may collect covered information about your online activities over time and across different Internet websites or online services when you use our Site.

You have the right to request that we not sell your Personal Information. Although we do not currently sell Personal Information, you may submit a request directing us not to sell Personal Information if our practices change in the future.

If you would like to exercise any of the rights provided, please refer to the CONSUMER REQUESTS AND VERIFICATION section below.

V. CONSUMER REQUESTS AND VERIFICATION

A.   Right to Non-Discrimination

We may not discriminate against you because you exercise any of your privacy rights contained in this Privacy Policy including, but not limited to:

  • Denying goods or services to you;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing a different level or quality of goods or services to you; or
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

B.   Verifying Requests

You may request to exercise your rights of access, deletion, or correction by contacting us as described in the CONTACT US section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:

  • As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
  • We will confirm that you want your information accessed, corrected, and/or deleted.
  • We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
  • We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  • In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing products or services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

C.   Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the CONTACT US section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

  • The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
  • You to verify your identity directly with us; or
  • You to directly confirm with us that you provided the authorized agent permission to submit the request.

D.   Virginia and Connecticut Appeal Process

If you have made a request to access, correct, or delete your Personal Information under VCDPA and CTDPA, and we have declined to take action, you may appeal our decision within 45 days of the denial. When you make such an appeal, you can expect the following:

  • We will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
  • We will review your appeal and respond in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision, within 45 days upon receipt of your appeal. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  • In certain cases, an appeal may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing products or services or completing an order. If we deny your appeal, we will explain why we denied it and provide you with a method to contact your state’s Attorney General to submit a complaint.

8.   HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Site, please contact us at [email protected] or [email protected].

We reserve the right to change this Privacy Policy at any time by posting revised Privacy Policy on the Site, and we may also (but are not required to) notify registered users (e.g. Donors and Volunteers) of such posting via the most recent user email address on file with us.  We encourage you to review this web page periodically. The changes will be effective immediately upon notice or posting, and we will update the effective date of this Privacy Policy upon such posting. Your use or continued use of the Site following the posting or email notification (as applicable) of any changes to the Privacy Policy will be deemed to be your acceptance of the changed Privacy Policy.