PRIVACY POLICY

Flip Flops Foundation (“Flip Flops Foundation,” “we,” “us”) provides online information regarding, and the opportunity to apply for, scholarships for persons furthering their educational pursuits. We are committed to implementing measures designed to protect the privacy of those using this website and its related subdomains (the “Site”).

Although Flip Flops Foundation respects the privacy of all those who visit the Site, we do collect information from our visitors and applicants. This Privacy Policy governs your interaction with the Site, including applications for scholarships. Except as set forth within this Privacy Policy and our Terms of Use and other published guidelines, we do not release personally identifiable information about our visitors or applicants without their permission.

Please note that Flip Flops Foundation reviews its privacy practices from time to time and that those practices are, therefore, subject to change. Any changes to this Privacy Policy will be posted here, and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of our Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of information collected in the past without the consent of affected Site visitors. To contact Flip Flops Foundation about privacy issues, to report a violation of our Privacy Policy or to raise any other issue, please e-mail us at [email protected].

THE INFORMATION WE GATHER.

Flip Flops Foundation gathers two types of information:

(1) Non-personally identifiable information: When visitors come to the Site, we collect and aggregate information indicating, among other things, which pages of the Site were visited, the order in which they were visited and which hyperlinks were “clicked” (“Aggregate Information”). Collecting such information involves the logging of the IP addresses, operating system and browser software used by each visitor to the Site. Although such information is not personally identifiable, we can determine from an IP address a visitor’s Internet Service Provider and the geographic location of their point of connectivity.

We also use “cookies” – that is, small text files placed on a user’s computer hard drive – to help us determine the type of content and sites to which a visitor to the Site links, the length of time each visitor spends at any particular area of the Site and the Site content visitors choose to see. Essentially, cookies are a visitor’s identification card for the Flip Flops Foundation computers or servers that placed them there. Cookies are only read by the server that placed them and are unable to execute any code or virus. Cookies allow Flip Flops Foundation to serve you better and more efficiently, and to personalize your experience at the Site. Nevertheless, you should be able to control how and whether cookies will be accepted by your web browser. For more information on how to do so, please refer to the documentation accompanying your browser.

Some of our business partners (e.g., IT service providers and analytical tracking software providers) use cookies and tracking technologies on the Site. We have no access to or control over these cookies or tracking technologies. In addition, we use a tool called Google Analytics™ to collect information about use of the Site. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other identifying information. Google Analytics collects geolocation data while you visit the Site, but that data is not matched with your IP address. We use the information we get from Google Analytics only to improve the Site, but do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics terms of use and privacy policy. This Policy covers the use of cookies on the Site and by us only and does not cover the use of cookies or tracking technologies by any such business partner.

(2) Personally identifiable information: In certain areas of the Site we require that you provide us with personally identifiable information:

Scholarship Applicants — If you are a potential Flip Flops Foundation applicant, personally identifiable information about you will be collected during the application process, including your name, address, email address, phone number (collectively “Applicant Information”).

Applicant Nominators/Recommenders and References — If you want to recommend or nominate a potential Flip Flops Foundation scholarship applicant, or reply to a reference request you received from a scholarship applicant, you will be required to provide your name, organization, title, email address, phone number and information regarding how you know the applicant (collectively, “Registration Information”).

Donations — We do not sell, share, or lease donor information to third parties. However, if you wish to make a financial donation by credit card, we will require you to agree to our use of a third-party payment process to process your donation. We use Handbid to process donations to Flip Flops Foundation made via credit card. To make this possible we ask financial donors for express permission to share their name, credit card number, expiration date and security code and billing address with Handbid. This information is shared via secure (encrypted) means directly between financial donors and Handbid for the sole purpose of completing your donation. With your permission, Handbid shares such information with us for the sole purpose of allowing us to contact you regarding past donations and future donation opportunities. Handbid will not send you mailings on behalf of other organizations unless you have given Handbid express permission to do so. Please also note that your credit card information (number, expiration date, security code) is provided directly to Handbid and is stored by Handbid (or, with your permission, a third-party credit card processor retained by Handbid) and not Flip Flops Foundation, and as such, it is important to review the privacy policy of Handbid prior to providing this information. Handbid’s privacy policy will apply to the information you provide on Handbid’s web site. Please see our Donor Privacy Policy for more information on how we collect and use donor information.

You hereby acknowledge and agree that Handbid is not an agent, employee, affiliate or representative of Flip Flops Foundation and that Flip Flops Foundation has no responsibility or liability for the services provided by Handbid or any third-party credit card processor retained by Handbid or for Handbid’s or the third-party credit card processor’s acts or omissions.

Applicant Information and Registration Information is collectively referred to as “Personally Identifiable Information”.

(3) Children’s information and privacy: The Site and the services provided by Flip Flops Foundation are not directed to persons under the age of 16. We do not knowingly collect or solicit personally identifiable information from children under the age of 16 without obtaining parental consent. If you become aware that your child has provided us with personal information without your consent, please contact us via email at [email protected]. If we become aware that a child under 16 has provided us with personal information without his or her parent’s or guardian’s consent, we take steps to remove that information.

HOW WE USE (AND DO NOT USE) THE INFORMATION WE GATHER.

Please take some time to familiarize yourself with the different ways Flip Flops Foundation uses the information that it gathers. Keep in mind that we cannot and do not assume any responsibility for any actions or omissions of third parties who do not receive information directly from Flip Flops Foundation, including the manner in which they use information received independently. Nevertheless, in the event that you encounter any third party associated with, or who claims association with, Flip Flops Foundation who you feel is improperly collecting or using information about you, please contact us at [email protected].

(1) Non-personally identifiable information: Flip Flops Foundation uses Aggregate Information to build higher quality, more useful online services by performing statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas of the Site. We are not limited in our use of Aggregate Information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of applications we receive, the geographic distribution of our applicants or total scholarship funds distributed).

The Site contains links to other Internet web sites which may or may not be owned or operated by Flip Flops Foundation. Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such web sites, including such sites’ use of any information (such as IP number, browser type or operating system) collected when visitors to the Site click through links to those sites. Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those sites.

(2) Personally Identifiable Information: By submitting an application, you consent to Flip Flops Foundation’ uses of Personally Identifiable Information as set forth here. Flip Flops Foundation uses Personally Identifiable Information for the purpose of determining whether to grant a scholarship to that applicant. We may contact the applicant or any recommender or nominator for that purpose. We share Personally Identifiable Information with the following Foundation parties:

Selection Committee — as a necessary and integral part of providing our services and granting scholarships. The committee has access to non-redacted scholarship applications through our Site’s portal. Each committee member has entered into a non-disclosure agreement that requires that they protect the confidential nature of information accessed, and not use such information except for purposes of evaluating the merits of such applications.

Donors — certain Flip Flops Foundation donors may receive access to scholarship applications for purposes of final selection of applicants to receive scholarship funds donated by that donor.

Third Party Service Providers — we utilize certain third party service providers, such as software developers, who help us operate and manage the Site. These third party service providers have access to information, including Personally Identifiable Information, that is provided through the Site, but each third party service provider is subject to a written agreement obligating that third party service provider to protect the confidential nature of information provided through the Site and not use such information except to help Flip Flops Foundation operate and manage the Site.

Colleges, Universities and the National Student Clearinghouse (NSC) — we provide Personally Identifiable Information to colleges, universities and the NSC for purposes of verifying enrollment, scholarship disbursement, and graduation information. Most colleges will only receive information, including an applicant’s name, date of birth and completed scholarship application if that applicant has applied to that institution. In certain cases, institutions are provided direct access to information provided by users through our portal. In those cases, the institution has entered into a non-disclosure agreement that requires the institution to protect the confidential nature of user information. If you receive a scholarship award, we provide your college or university with your name, your student ID number, the amount of your scholarship and the name of your scholarship award of donor. The NSC is an organization that works with colleges and universities to verify enrollment information. We provide the NSC with your name, date of birth and the year in which your scholarship was awarded. NSC’s use and disclosure of such information is governed by its Terms of Use and Privacy Policy.

We reserve the right to release information contained within our access logs concerning any visitor, applicant or registrant when there is a violation of our Terms of Use or other published guidelines, or in connection with any illegal activity, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law or as necessary to protect our rights. We cooperate with law enforcement agencies in identifying those who may be using our servers or services for illegal activities. We also reserve the right to report any suspected illegal activity to law enforcement individuals or entities for investigation or prosecution. If a subpoena seeks information about you, we’ll make reasonable business efforts, if permitted by law, to contact you before providing information to the party that requests it, but we cannot guarantee that we will be able to do so. We may disclose Personally Identifiable Information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

PROTECTING PERSONALLY IDENTIFIABLE INFORMATION

Flip Flops Foundation uses PGP encryption technology to protect your Personally Identifiable Information and this information is always kept strictly confidential. Personally Identifiable Information is stored on a secure server via SSL and is protected by firewalls. Only a limited number of the Flip Flops Foundation staff has access to secure Personally Identifiable Information. Although we try to provide a safe and secure service, due to the vulnerable nature of information provided online, we cannot guarantee that information you provide, including Personally Identifiable Information, will remain secure under all circumstances.

CHANGING OR DELETING PERSONAL INFORMATION

If you would like to have your Personally Identifiable Information removed from Flip Flops Foundation’s database, please contact us at [email protected], and we will use reasonable efforts to comply with your request. Keep in mind, however, that there will be residual information that will remain within Flip Flops Foundation databases, access logs and other records, which may or may not contain such information.

GOVERNING LAW NOTICE TO RESIDENTS

This Privacy Policy is governed by the laws of the State of Colorado without giving effect to any principles of conflict of law. Please note that our Site and services are designed for compliance with United States data privacy and security regulations. The United States and other countries have not harmonized their privacy regulations. We have written this Privacy Policy to satisfy United States regulations and the users of the Site agree to that level of privacy protection.

Donor Privacy Policy

Flip Flops Foundation (“Flip Flops Foundation,” “we,” “us”) is committed to respecting the privacy of its financial and in-kind donors, whether the donation is made online, by mail, or any other method. When you make a financial or in-kind donation, you provide name and contact information. Financial donors provide standard payment information including, in many circumstances, credit or debit card information.

SHARING DONOR INFORMATION

Other than as detailed below or with a donor’s consent, we will not sell, share or trade our donors’ personal information with any other entity. In addition, we will not send mailings to our donors on behalf of other organizations, unless a donor has given us specific permission to do so.

DONATIONS BY CREDIT CARD

If you wish to make a financial donation by credit card, we will require you to agree to our use of a third-party payment process to process your donation. We use Handbid to process donations to Flip Flops Foundation made via credit card. To make this possible we ask financial donors for express permission to share their name, credit card number, expiration date and security code and billing address with Handbid. This information is shared via secure (encrypted) means directly between financial donors and Handbid for the sole purpose of completing your donation. With your permission, Handbid shares such information with us for the sole purpose of allowing us to contact you regarding past donations and future donation opportunities. Handbid will not send you mailings on behalf of other organizations unless you have given Handbid express permission to do so.

Please also note that your credit card information (number, expiration date, security code) is provided directly to Handbid and is stored by Handbid (or, with your permission, a third-party credit card processor retained by Handbid) and not Flip Flops Foundation, and as such, it is important to review the privacy policy of Handbid prior to providing this information. Handbid’s privacy policy will apply to the information you provide on Handbid’s web site.

THIRD PARTY SUPPORT

We utilize certain third party service providers, such as software developers, who help us operate and manage the Site and otherwise support our operations. These third party service providers have access to donor information, including Personally Identifiable Information, but each third party service provider is subject to a written agreement obligating that third party service provider to protect the confidential nature of information provided and not use such information except to help Flip Flops Foundation operate and manage our website and our operations. These third parties will not send you mailings on behalf of other organizations.

DONOR INFORMATION SECURITY

Flip Flops Foundation uses PGP encryption technology to protect donor Personally Identifiable Information and this information is always kept strictly confidential. Donor Personally Identifiable Information is stored on a secure server via SSL and is protected by firewalls. Only a limited number of the Flip Flops Foundation staff has access to secure Donor Personally Identifiable Information. Although we try to provide a safe and secure service, due to the vulnerable nature of information provided online, we cannot guarantee that information you provide, including Personally Identifiable Information, will remain secure under all circumstances.

Flip Flops Foundation COMMITMENT TO PRIVACY

Questions regarding this Privacy Policy should be directed to Flip Flops Foundation at [email protected]