Project Paradigm (“Project Paradigm” or “Us” or “We,” whether capitalized or not) respects privacy rights and we are committed to protecting the personally identifiable information of youth who participate in The Paradigm Challenge (“The Challenge”), the Mini Contests, the Public Voting Contest, the Ambassador Program, or otherwise use this and other websites operated by Project Paradigm (“Websites”). This Privacy Policy (or “Policy”) details certain policies implemented on the Website for the specific protection of youth and their parents and guardians. Use of the Websites constitutes acknowledgment and acceptable by you of this Policy, as well as the Terms of the Websites.
Project Paradigm is a private foundation under the laws of California and the United States. Although we are a non-profit organization that is not subject to some laws and regulations regarding the handling of the personally identifiable information of youth, we strive to follow the practices as set forth herein.
PRIVACY OFFICER AND SITE OPERATOR
Collection of youth information through the Websites is operated by the Project Paradigm Privacy Officer. Our Privacy Officer may be reached at privacyofficer@projectparadigm.org or 11301 West Olympic Boulevard, Suite 306, Los Angeles, CA 90064.
INFORMATION WE COLLECT AND HOW WE COLLECT IT
In order for youth to participate in The Challenge, the Mini Contests, the Public Voting Contest, and/or the Ambassador Program, and otherwise engage with some portions of the Websites, we need to collect certain information from youth, including first name, last initial, email address, Website profile password, and month and year of birth. If a participant is under 13, we request a parent or guardian’s email address instead. We collect this information by enabling youth to submit information directly to us through the Websites or other websites operated by Project Paradigm or members of The Challenge coalition.
Initially, at the time of registration, we do not collect a person’s last name, day of birth, address, telephone number, facsimile number, social security number, or image. In the event that a participant is selected as a potential recipient of a prize in The Challenge, a Mini Contest, Public Voting Contest, or the Ambassador Program, we will need to collect additional information, such as the participant’s last name, mailing address, photograph, and potentially other information (“Identifying Information”) to verify eligibility, distribute any awarded prizes, comply with reporting obligations, and to promote winning entries on the Websites. Before we gather any of this additional Identifying Information from a youth under 13, we will collect parental or guardian consent as described below.
Like most websites, we may collect non-personally identifiable information about you in a number of ways, including but not limited to tracking your activities through computer settings or most-recently visited URL. When you use the Websites, we might insert some instructions on your computer or mobile device. These instructions will be in the form of a “cookie” or similar file. Cookies are small pieces of instruction stored on your hard drive or device, not on our Website. Cookies may help you navigate the Websites as easily as possible. Please visit www.allaboutcookies.org to learn more about how cookies are used. If you do not want to receive cookies, you may set your browser to reject them. However, if you turn cookies off, you may not have access to some of the Websites’ services and features. Unless you have adjusted your browser setting to turn off cookies, the Websites will automatically use cookies when you access them.
One form of cookie we may use is associated with Google Analytics advertising. Our participation in the Google Analytics program will enable Google to collected non- personally identifying information about your usage of the Websites and the Internet. For more about how Google uses that data, and how to opt out of Google Analytics, please see this webpage: https://www.google.com/policies/privacy/partners/ .
We may also use web beacons or flash cookies within emails. A web beacon or flash cookie is an invisible graphic on a web page or email newsletter that is programmed to collect non-personally identifiable information about the use of a given website or newsletter, such as whether or not an email is opened and viewed.
HOW WE USE INFORMATION ABOUT YOUTH
We use information submitted by youth to register them for our Websites, for participation in The Challenge, the Mini Contests, the Public Voting Contest, the Ambassador Program, and as described herein. We do not share this information with third parties unless: (a) the third parties assist us in operating and delivering our Websites, such as technology providers that support the Challenge, the Mini Contests, the Public Voting Contest, and the Ambassador Program; (b) we are required to do so by law; (c) it is necessary to protect the rights, property, or safety of participants, our employees, or third parties; (d) it is necessary to respond to legal claims; or (e) we need to enforce this Policy or our Terms. We strive to take reasonable steps to require that the third parties that assist us in operating and delivering our Websites comply with the terms of this Policy.
If you do not want us to share or disclose your information as stated in this Policy, please do not submit any information.
We will keep your personal information for as long as necessary to further our charitable purpose and activities. We may discard your personal information at any time. If your information has changed, or you believe you are the victim of identity theft, please contact us.
The information submitted by youth will remain subject to the terms of this Policy even if we undergo an organizational change or assets transfer. However, we may transfer your information to a successor entity upon an acquisition or other reorganization. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Policy.
PARENTAL CONSENT POLICY
Other than as discussed herein, upon obtaining actual knowledge that a child under the age of 13 submitted Identifiable Information to Project Paradigm without parent or guardian consent, we will make reasonable efforts to delete such information expeditiously, unless retention is necessary: (i) for protecting the security or integrity of the Websites; (ii) to take precautions against liability; (iii) to respond to judicial process; or (iv) to provide information to law enforcement agencies or for an investigation on a matter related to public safety.
If we need to collect Identifiable Information from a youth under age 13, we will email the youth’s parent or guardian to notify the parent or guardian and to request consent for the collection of the information. We will use the parent or guardian email provided when the youth registered. If we receive a favorable response to the initial email, we will send a follow-up email to confirm consent. We will also request the Identifying Information pursuant to the consent. If we do not receive parent or guardian consent, we will not seek the Identifying Information from the youth and we may in our sole and absolute discretion disqualify the youth and/or his or her team.
Although we do not currently share Identifiable Information with third parties other than as described above, if we do so in the future, we will email a parent or guardian to provide notice and request consent for the sharing of the information.
CORRECTING/UPDATING INFORMATION ABOUT YOUTH
Project Paradigm will provide a parent or guardian with the ability to review, correct, and/or delete any of the Identifiable Information that a youth under the age of 13 has provided to us. If you have questions about this Privacy Policy or wish to review or correct any information provided to us, you may contact our Privacy Officer at privacyofficer@projectparadigm.org. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making changes or modifications. Unfortunately, we cannot always ensure that such changes or modifications will be reflected in all iterations of the information as previously stored.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits California residents to request certain information regarding the disclosure of Identifiable Information to third parties for their direct marketing purposes. However, we are a non-profit organization and we do not share any of your personal information with third parties for direct marketing purposes.
SECURITY AND STORAGE
We primarily store your information in the United States and Canada. Some information may be stored elsewhere. You authorize us to do so. We will take commercially reasonable steps to safeguard and deter unauthorized access to your information. Although we take measures to safeguard against unauthorized disclosures of your information, we cannot assure you that your information will never be disclosed in a manner that is inconsistent with this Policy.
THIRD PARTY WEBSITES
The Websites may contain links to other websites. We are not responsible for the privacy practices or the content of such services. When you directly submit information or data to third parties, their privacy policies, not ours, will govern their use of the information and data. You should review the privacy policies and terms of service of all such third parties. We do not make any representations regarding the policies or practices of such third parties.
PRIVACY POLICY UPDATES
We may revise or enhance this Policy through amendments from time to time in our sole and absolute discretion. We will post a current version on the applicable Website and will communicate material changes to you by, among other things, posting a notice on the Website before the changes take effect. By continuing to use the Website subsequent to us making available an amended version of the Policy, you thereby acknowledge, agree and consent to such amendment. However, we will not deem applicable to you any future changes made that would enable the sharing of “Identifiable Information” about youth under the age of 13 without acquiring verified parental consent.
Effective July 1, 2017