Privacy Policy2018-10-04T14:31:56+00:00

Our Commitment to Privacy

This Privacy Policy explains how information about users is collected, used and disclosed by Challenger Center. This Privacy Policy applies to information Challenger Center collects when users visit Challenger Center’s  website, and services that link to it (collectively, the “Site”). Prior to the collection of any personal information on the Site, users will be asked for their consent via a positive opt-in action and in accordance with the Children’s Privacy Policy outlined below. By law, consent must be freely-given, specific, informed, and revocable. References to consent throughout this Policy will therefore meet these specifications.

Challenger Center may change this Privacy Policy from time to time. When the Privacy Policy is amended, and it affects the information collected from users, users will be notified, and their opt-in consent will be acquired.

Information Collection and Consent

Challenger Center will not sell, share, or rent information collected on the Site to others in ways different from what is disclosed in this statement. Challenger Center collects information from users at several different points on the Site.

The Site provides ways for users to access Challenger Center services and resources, learn more about Challenger Center and Challenger Learning Centers, contact Challenger Center, and donate. Challenger Center collects information about its online visitors both directly from visitors and indirectly from vendors that provide data to the Center. For example, Challenger Center collects information when users request information, complete a form, send Challenger Center an email, sign up to receive newsletters, make a donation, or otherwise communicate with the Center.  The types of information Challenger Center collects may include username, email address, postal address, phone number, mobile number, payment information, and other information a user chooses to provide. Because this information qualifies under current law as “personal data,” a user’s consent will be obtained prior to collection, in accordance with applicable law and regulations, including the Children’s Privacy Policy below.

Cookies

Pending users’ provision of consent in response to a “pop-up” opt-in inquiry when first visiting the Site, Challenger Center collects information about online visitors using “cookies.” Challenger Center uses this information to ensure that all users are apprised of the Center’s privacy policy and of changes made to that policy. In addition, Challenger Center puts the information it collects from users to several other uses. The Center uses the information collected by vendors to track the popularity and success of specific website features and for the collection and management of payment and other customer information, as described in detail below.

There are also cookies used by Challenger Center’s vendors when users visit the Site. Three third-party services – Google Analytics, AddThis, and DAF Direct – collect this information on the Site.  Before these three vendors collect information via cookies, this is disclosed in the “pop-up” inquiry and the consent process is employed when users first visit the Site.

Analytics: Google Analytics collects data related to a user’s device, location, browser, and activity on the Site, and provides a summary of this information to Challenger Center about activity on the Site. Google’s privacy policy is available here; Google can be reached via this webpage. Google uses the information collected to target advertising to users, to measure performance, to develop new services, to improve products and services, and to improve the safety of its services.

Social Media: AddThis empowers users to share information from the Site to user social media accounts (e.g., Facebook, Twitter). The use of this service is voluntary for users. AddThis uses cookies to support the transfer of information from the Site to user social media accounts. Challenger Center does not receive or use the AddThis data for any other purpose. AddThis’s privacy policy is available here; AddThis can be reached by calling 650-506-7000. AddThis uses the information collected to market products and services, provide personal recommendations, provide linkages and sync information across devices, improve products and services, and provide security.

Donations: DAF Direct connects donors to the website of their Donor Advised Fund, a type of philanthropic vehicle, and automatically prepopulates a donation amount and designation. Its purpose is to make donating via a Donor Advised Fund easier. Challenger Center does not collect or store any information input via this tool, but as addressed in the Donor Privacy Policy below, does share information with two other vendors, Bloomerang and BluePay. DAF Direct’s privacy policy is available here; DAF Direct can be reached at DAFDirect@fmr.com. DAF Direct uses the information collected to support operation of its website and for security purposes.

The “pop-up” inquiry referenced in this section will read as follows: “Challenger Center’s website uses cookies to ensure that all users are apprised of the Center’s privacy policy and of changes made to that policy. Challenger Center’s policy is available here. [Insert link.] There are also cookies used by Challenger Center’s vendors, Google Analytics, AddThis, and DAF Direct. In order to proceed (and thus utilize cookies), you must be 13 years of age or older.  If you are younger than 13, consent from a parent or guardian is necessary for you to proceed to/access this Site. If that is the case, please ensure that your parents or guardians print and sign this form granting parent consent to the use of cookies and agreeing to the Challenge Center privacy policy and fax, mail, or e-scan it back to Challenger Center. If you are 13 years of age or older, and you consent to the use of cookies for the purposes described here and to Challenger Center’s privacy policy, please click ‘I Accept’ below.”

Donor Privacy Policy

If users make a donation to Challenger Center, pending the granting of user consent (both to Challenger Center collecting such information and to the sharing of that information with third parties, and in accordance with the Children’s Privacy Policy below), user information will be shared with two vendors – Bloomerang and BluePay – for the purpose of processing user transactions. Challenger Center will not sell, share, or trade donors’ personally identifiable information with any entity, except the Center’s vendors Bloomerang and BluePay, and only for the purposes described below. These vendors are bound by strict confidentiality rules and are permitted to use donor data only to support Challenger Center operations.

Bloomerang is a customer relationship management system in which Challenger Center stores donor and subscriber contact information, interactions, and contributions. Bloomerang’s privacy policy is available here; the vendor can be reached at 866-332-2999. Bloomerang uses the information gathered to improve its products and may periodically use information gathered to contact users, as discussed in further detail below.

BluePay is a credit and debit card payment processor. Bluepay’s privacy policy is available here; the vendor can be reached at marketing@bluepay.com or by calling 866-739-8324. BluePay uses the information gathered for business purposes including e-mail updates and quality improvement.

Challenger Center is committed to respecting the privacy of its donors. When users make a financial or in-kind donation, users provide their name, contact information, and payment information. This information is used by Bloomerang and BluePay to process the user’s donation transaction. A user’s name and contact information will be retained in Bloomerang and will be used by Challenger Center staff to communicate with users in the future, pending user consent for Challenger Center to do so. For example, Challenger Center may use the contact information to send users newsletters, donation appeals, and event invitations via mail or email. If a user no longer wants to receive communications from us, users can click the ‘Unsubscribe’ link in any email received from Challenger Center or users can request to opt out by emailing Challenger Center at privacy@challenger.org or calling at 202-355-7721. If users ‘Unsubscribe’ or request to opt out, Challenger Center will do so, but retain user contact information and donation and interaction data in Bloomerang for historical records and for reference if the user reengages in the future. However, if requested by the user, Challenger Center will remove all contact information and historical data.

Challenger Center and its vendors Bloomerang and BluePay protect the security of financial transactions as required by Payment Card Industry Data Security Standards. Challenger Center uses several measures such as encryption, access controls, network firewalls, and physical security.

As discussed, Challenger Center will not sell, share, or trade donors’ personally identifiable information with any entity, except the Center’s vendors Bloomerang and BluePay, and only for the purposes described above. These vendors are bound by strict confidentiality rules and are permitted to use donor data only to support Challenger Center operations.

Survey Privacy Policy

Challenger Center loves to hear from users about users’ experience with the Center’s programs. Current students, alumni, and educators are all encouraged to complete a survey on the Site designed for their cohort—either a student survey, alumni survey, or educator survey. The information provided to Challenger Center via each survey will be retained in the Center’s electronic file systems and may be used for marketing purposes, pending the granting of consent to do so both by the user or by a parent/guardian, in accordance with the Children’s Privacy Policy, if the user is a minor under the age of 13. For example, Challenger Center may quote survey responses in a newsletter, donation appeal, or blog posts. Users who complete any of the surveys and grant consent for marketing use must also sign a media release form in case Challenger Center chooses to use the user’s information and responses publicly; if users are minors under the age of 13, parents’/guardian’s consent is required according to the procedures outlined in the Children’s Privacy Policy. Anytime any personal information, such as a user’s name or contact information, is gathered in connection with the completing of a survey, Challenger Center will gain consent from the user prior to the collection of such information; in the case of a minor under the age of 13, the parent/guardian consent procedures outlined in the Children’s Privacy Policy will be followed.

The Student Survey is a part of the website offering intended for current students who have experienced a Challenger Center program and therefore could be completed by minors under the age of 13. Individuals who complete the Student Survey are not asked to provide any personally identifiable information. If such information is provided, Challenger Center will only collect and retain the personal information if Challenger Center receives explicit consent from the individual—or in the case of a minor under the age of 13, from a parent (according to the consent procedures outlined in the Children’s Privacy Policy)—to do so.

The Alumni Survey is intended for individuals who are no longer active students in grades K-12, but who experienced a Challenger Center program during their primary and secondary education. These individuals must confirm they are 13 years of age or older prior to completing the survey. If the individual is a minor under the age of 13, Challenger Center will only collect and retain the survey data if Challenger Center receives consent from a parent to do so, according to the consent procedures outlined in the Children’s Privacy Policy. Individuals who complete the survey are asked to provide their name and contact information, after granting Challenger Center consent to collect such information.

The Educator Survey is intended for educators who have supported children in experiencing a Challenger Center program. These individuals are presumed to be legal adults. Individuals who complete the survey are asked to provide their name and contact information, after granting Challenger Center consent to collect such information.

Challenger Center will not use user data provided via surveys for any other purpose other than the purposes for which users have granted their consent.

Links

This website contains links to other sites. Please be aware that Challenger Center is not responsible for the privacy practices of such other sites. Challenger Center encourages its users to be aware when they leave the Site and to read the privacy statements of each and every website that collects personally identifiable information.

How Challenger Center Secures Data

Challenger Center uses a variety of security measures to protect user data. Challenger Center maintains physical and electronic safeguards to help prevent unauthorized access to identifiable data.

Access to and Control Over Data

At any time, users have a right to access their personal data in a machine-readable format, have that data deleted or amended, or transmit that data to another entity. This data could include contact information, donation records, and/or interactions such as emails. Users also have a right to object at any time to the processing and storage of their personal data. These requests can be made by e-mailing privacy@challenger.org.

Opt-Out

If users no longer want to receive communications from Challenger Center, users can click the ‘Unsubscribe’ link in any email received from Challenger Center or users can request to opt out by emailing Challenger Center at privacy@challenger.org or calling Challenger Center at 202-827-1580.

If users ‘Unsubscribe’ or request to opt out, Challenger Center will delete all the user’s personal information. However, Challenger Center notes that the deletion of all personal data will result in a more cumbersome user experience in the future if the same user reengages with the Site. For this reason, Challenger Center suggests that user contact information and donation and interaction data in Bloomerang only be retained when a user chooses to “Unsubscribe.” If you agree to have this information retained, please click “I accept.”

Children’s Privacy Policy

In addition to Challenger Center’s general privacy policy, the Center’s Children’s Privacy Policy provides further information and privacy protections for users who are under the age of 13.

The Site is not intended for children under 13 years of age.  No one under 13 may provide any personal information to or on the Site.  We do not knowingly collect personal information from children under 13.  If you are under 13 years of age, do not provide any information about yourself on the Site.

Challenger Center Programs and Products

Challenger Center programs and products (excluding the Augmented Reality Apps via Google Play and Apple App stores) are marketed to teachers and school administrators and delivered to students. The Augmented Reality Apps are only accessible via Google Play and Apple App stores and are subject to the privacy policy within each of those stores.

Children under the age of 13 should not submit personally identifiable information on the Site.

In general

  1. If someone under age 13 attempts to submit personal information to Challenger Center via a form and Challenger Center is made aware, Challenger Center will obtain parental consent from a parent or guardian. In the case of consent to cookies, this consent is gained via a “pop-up” when users first visit the Site that reads, in part, as follows: “In order to proceed (and thus utilize cookies), you must be 13 years of age or older. If you are younger than 13, consent from a parent or guardian is necessary for you to proceed to/access this Site. If that is the case, please ensure that your parents or guardians print and sign this form granting parental consent and fax, mail, or e-scan it back to Challenger Center.” When users—no matter their age—attempt to submit personal information to Challenger Center, in order to proceed, they must opt-in to an agreement that reads as follows (or substantially similar to what follows): “In order to submit this information, you must be 13 years of age or older. By checking this box, you certify that you are 13 years of age or older and consent to the collection of this information. If you are younger than 13, consent from a parent or guardian is necessary for you to proceed. If that is the case, please ensure that your parents or guardians print and sign this form granting parental consent and fax, mail, or e-scan it back to Challenger Center.”On the form discussed in the previous paragraph, the Center will inform parents that the Center is seeking the personal information of their child and what information specifically is being sought. Parents will be informed that their consent is required in order for such collection to occur, and the necessary steps for consent to be granted (the signing and faxing, mailing, or e-scanning of the form back to Challenger Center) will be detailed. A link to the Center’s Privacy Policy will be included. As discussed, in order for consent to be granted, the Center will require parents to sign a form and fax, mail, or e-scan the form back to Challenger Center. At any point following the granting of consent, parents have the right to revoke such consent.
  2. Under the Children’s Online Privacy Protection Act, no website operator can require, as a condition of participation, that a child under the age of 13 disclose more information than is reasonably necessary. Challenger Center abides by this requirement. In addition, the Center will dispose of information concerning children once it no longer has a legitimate need for it; in this context, “dispose” means the elimination of all records, both electronic and hard copy.
  3. At any point, parents have the right to review the personal information of their child. To do so, parents should email privacy@challenger.org. Parents can direct the Center to delete such information and further direct the Center not to collect or use such information in the future. In addition, parents have the right to direct the Center not to share child data with third parties.

Information sharing and disclosure

Challenger Center will not contact children under 13 about special offers or for marketing purposes without parental consent.

Users can modify any personal information provided to Challenger Center by emailing privacy@challenger.org.

Contact Challenger Center 

If users have any questions about this Privacy Policy, please email privacy@challenger.org.