Effective date: October 24, 2018
Last updated: April 5, 2023
This Privacy Policy describes how National Endowment for Financial Education (“NEFE”, “we”, or “us”) collects, uses, protects, and discloses information when you visit or use our websites, https://www.nefe.org (“NEFE.org”) and https://toolkit.nefe.org (“Toolkit”) (collectively, our “Websites”). This Privacy Policy applies only to natural persons and is not applicable to any entities (whether business, non-profit, or governmental). By using our Websites, you are consenting to NEFE’s Privacy Policy. Please review it carefully.
1. COLLECTION OF PERSONAL INFORMATION
Whenever you visit our Websites, we will collect some information from you automatically simply by you visiting and navigating through the Website. We also collect information from you voluntarily when you submit information using a form, such as the “Contact NEFE” page or use any of the other interactive portions of our Websites, including our email lists and newsletters. Through our Websites, we will collect information that may identify you and/or your activity. NEFE does not, however, collect any sensitive Personal Information (also known as personally identifiable information), such as social security numbers, driver’s license numbers, financial account numbers, or medical information via its websites.
2. TYPES OF INFORMATION COLLECTED
Listed below are details about the categories of Personal Information we collect from our Websites:
- Internet Activity, including but not limited to, the date and time of your visit to our Websites; webpages visited; links clicked on the website; IP address and domain server from which the Website was accessed; type of computer or device, including device ID; type of Web browser and Web browser ID; your operating system; cookies; or other information related to usage of our Websites, e.g., HTTP requests and other information about your visit to, use of and navigation of the site.
- Personal Identifiers & Contact Information, including your name, e-mail address, and any other personal information that you provide to us through forms on the Website, including but not limited to the “Contact Us” form on our Websites, e.g., mailing address, phone number, and any other personal data you voluntarily disclose to us.
- Other Information, Some sites may require the input of information or data in order to use the features or functions of the site. We may collect and retain the information and data you provide in connection with the use of the site. Details about particular sites are set forth below. Some services offered on a site may require that you agree to additional terms and conditions, and we may collect and retain information relating to this to enable and control the access to and use of these services
3. SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION
- You, the consumer, when you visit our Websites and voluntarily submit information through forms on the website or through social media, when you participate in interactive learning systems contained in our Websites, and when you inquire about any of the products and/or services NEFE offers to the public.
- From our employees and contractors, whenever you interact with them in connection with the Websites or the product and/or services offered by NEFE.
- Other customers and visitors, to the extent you interact with them or when they observe you as part of the interactive learning systems contained in our Websites.
- We utilize cookies to automatically collect information about visitors to our Websites.
- Social media platforms, to the extent that you voluntarily submit information to us through these methods.
- When you submit information through surveys, quizzes, and other materials created by instructors in connection with services offered by our Toolkit as further described below.
4. PARTIES TO WHOM WE MAY DISCLOSE YOUR PERSONAL INFORMATION
- Marketing support vendors, as well as vendors that support the hosting, managing, and maintenance of our Websites.
- Data analytics vendors.
- Security and risk management vendors.
- Federal, state, local, or other regulatory authorities when served with a valid subpoena or lawful court order.
5. WE MAY COLLECT YOUR PERSONAL INFORMATION FOR THE FOLLOWING PURPOSES
We may use the Personal Information that you choose to submit through our Websites, and the information that we collect about you through cookies for the following purposes:
- To fulfill or meet the purpose for which you provided the information.
- To respond to your inquiries about the products and/or services provided by NEFE.
- To improve user experience on our Websites.
- To understand the demographics of our Website visitors.
- To detect security incidents.
- To debug, identify, and repair errors that impair existing intended functionality of our Websites.
- To protect against malicious or illegal activity and prosecute those responsible.
- To prevent identity theft.
- To debug, identify, and repair errors that impair use of the features and functions of the Website;
- To detect security incidents;
- For research, development, and analysis in connection with the maintenance, protection and improvement of our services, materials, and information we provide as part of NEFE’s mission; and
- To provide, maintain, and improve our Website, including to monitor the usage of our Websites, enable third parties or agents to help us maintain and operate the Websites, analyze how users use the Websites, improve the Websites’ experience for visitors, and understand the demographics of our Website’s visitors.
We may share information with third party service providers in the United States and outside of the United States for these purposes, but we do not authorize such providers to use Personal Information for any other purpose or to share Personal Information with others. Third party service providers may have access to Personal Information in the course of providing services, but we do not authorize such providers to use Personal Information for any other purpose or to share Personal Information with others. Any third party with whom we share Personal Information must enter into a contractual agreement with us that strictly limits the third party’s use and disclosure of Personal Information to the business purpose for providing it and prohibits any other use or disclosure. SMS consent or phone numbers for the purpose of SMS is excluded from information sharing with third parties.
6. USE OF COOKIES AND OTHER TECHNOLOGIES
Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent (until deleted) basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons:
- Provide you with services available through the website and to enable you to use some of its features
- Authenticate users and prevent fraudulent use of user accounts
- Identify if users have accepted the use of cookies on the website
- Compile data about website traffic and how users use the website to offer a better website experience
- Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website
- Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website
You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the Website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our Website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:
Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. However, there is currently no universal standard for sending and receiving DNT signals. Due to this lack of universal standard, it would be impossible for us to promise that we comply with all known and unknown DNT standards.
Therefore, we do not respond to DNT signals or other mechanisms that provide a choice regarding the collection of Personal Information about activities over time and across different Web sites or online services. If a universal standard for DNT becomes available, we may revisit our DNT Policy.
7. RETENTION OF YOUR PERSONAL INFORMATION
We will retain and use your information for as long as we need it to provide you Services, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. USER CHOICE REGARDING COLLECTION, USE AND DISTRIBUTION OF PERSONAL INFORMATION
You may choose not to provide us with any Personal Information or request that we delete your Personal Information in our possession. If so, you may be able to access and use some of the site; however, you may not be able to access and use portions of the site or features or functions that require your Personal Information. You may contact [email protected] to request deletion of your Personal Information, including (but not limited to) information you provide in connection with the services provided through our Toolkit. If you have signed up for an email newsletter, texts or other periodic communications from us and wish to no longer receive such communications, contact [email protected].
9. DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not share your Personal Information with any third party, unless required to do so by law or government agency, for the purpose of defending or prosecuting legal claims, to protect our rights or property, or with service providers/vendors that process, collect or store this information for our benefit and that are restricted from using or disclosing the information outside the scope of the services they provide to us.
We do NOT sell your Personal Information, including the data of any minors. We do not sell or otherwise trade Personal Information we collect from our Websites’ visitors at any point or under any circumstances.
10. PROTECTION OF YOUR PERSONAL INFORMATION
We use reasonable and appropriate measures to safeguard the information you submit to us through the Website, or that we have received about you through the Website. You Agree by using this Website that you understand that no transmission of information over the Internet can be guaranteed to be totally secure. If you do not want to transmit information to us because we cannot and do not guarantee it will be 100% secure during its transmission, you agree that you will not submit any personally identifiable information through the website.
11. CALIFORNIA CONSUMERS' RIGHTS
Pursuant to the California Consumer Privacy Act (1798.100), California residents have certain consumer rights of their Personal Information, refer to https://www.caprivacy.org and https://oag.ca.gov/privacy/ccpa for further information.
12. CHILDREN UNDER 13 YEARS OLD
Our Websites are not intended for children under 13 years of age. No one under age 13 may provide any Personal Information on our Websites. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any Personal Information on our website. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact [email protected].
13. EXTERNAL LINKS
Our website contain links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website. We may also make forums, message boards, social media and news groups available to you or otherwise allow you to provide or post information or content. Please understand that any information or content disclosed in these areas may become public information. We have no control over its use, and you should exercise caution when deciding to disclose your Personal Information.
14. CONSUMERS WITH DISABILITIES
We undertake reasonable efforts to ensure that this policy and these Websites are accessible to consumers with disabilities. If you experience any difficulties accessing this policy or our Websites, please contact [email protected].
15. SITE-SPECIFIC DETAILS
TOOLKIT.NEFE.ORG
Our Toolkit provides educational resources such as assessments and surveys that may be adapted and customized by individual users. The adapted and customized resources and any information and data collected or generated by the user may be stored in a database and accessed by that user. We may use this information for our internal analysis, operation of the site and other purposes set forth in this policy.
We do not seek any Sensitive Personal Information through services we provide through our Toolkit. By use of the services provided by our Toolkit, you agree to not provide any Sensitive Personal Information, as defined by the California Consumer Privacy Act of 2018, as amended by the Consumer Privacy Rights Act of 2020 and implementing regulations, such as medical information, social security number, racial or ethnic origin, religious or philosophical beliefs, or union membership, etc. Although we discourage course instructors from requesting any Sensitive Personal Information from you through surveys, quizzes, or tests and other materials in connection with our Toolkit, you agree to notify us (at [email protected]) if you are aware of any materials that ask you to supply any Sensitive Personal Information.
16. UPDATES AND CHANGES TO PRIVACY POLICY
We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such addition, change, update, or modification on this site. Any such addition, change, update, or modification will be effective immediately upon posting on the site. This Privacy Policy was last updated on April 5, 2023.
17. CONTACT
If you have any questions or concerns regarding this Privacy Policy or our treatment of Personal Information, please feel free to contact us at National Endowment for Financial Education, Attn: Privacy Policy Matters, 1550 Market St., Suite 475, Denver, Colorado 80202 or [email protected].