Revised and Adopted: July 22, 2016.
- Why We Collect Your Information
We collect information from you in order to:
- Enforce our terms and conditions, and perform any other functions otherwise described to you at the time you provide your information;
- Provide a confirmation phone call, and/or email or text message;
- Provide a reminder phone call, and/or email or text message;
- Post Workshop follow up to discuss your Federal benefits;
- Post Workshop follow up in the event you do not attend inviting you to an additional Workshops, and/or to discuss any Federal Benefit related questions you may have;
- Deliver the information, programs, products or services you have requested from us;
- Provide you with customer support;
- Communicate with you by email, postal mail, telephone, and/or mobile devices about information, programs, products or services that may be of interest to you either from us or Service Providers, Licensed Providers or Corporate Affiliates;
- Evaluate the effectiveness of FFEBA benefits and offerings;
- Display advertising tailored to your interests or background; and
- Perform data and statistical analysis
- Information We Collect From You
When you log onto this Website, or submit a benefit analysis request to FFEBA, we collect basic information such as your name, contact information, preferences and date of birth. We collect information about your participation in FFEBA activities.
FFEBA also collects information on our Website. We collect both information that identifies you as a particular individual (“personally identifiable information”) and anonymous information that is not associated with a specific individual (“nonpersonally identifiable information”). When you visit our Website, some information may be collected automatically as part of the site’s operation. We also collect information we receive from you during online registration and when you complete other forms. In the following sections, we explain in more detail the types of information we collect online.
- Your browser type and language, and operating system;
- Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- The times that you visit our website;
- Information about areas of our website you visited;
- The sites you visited immediately before and after visiting our website;
- Web pages and advertisements you view and links you click on within our website;
- Unique identifiers when using a mobile device, including mobile device identification numbers.
- Information that can identify the physical location of your mobile device in accordance with applicable law and industry guidelines and best practices. We will seek your permission before we identify the physical location of your device and before we engage in any continuous tracking of your device’s location;
- Information collected through cookies, Web beacons and other technologies. A “cookie” is a piece of information a website sends to your computer while you are viewing the website that allows the site to recognize your computer each time you visit. You have the choice to set your browser to accept all cookies, reject all cookies or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) It is up to you whether to allow us to send you cookies. However, if you do not accept cookies from us, your ability to use some areas of our site will be limited, such as our tools and other online features. Web beacons (sometimes called transparent GIFs, clear GIFs or Web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a Web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the Web beacon is placed;
- Information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded;
- Upon request for assistance, your bandwidth speed and information about the software programs installed on your computer; and
- Standard server log information.
Information you provide directly to FFEBA through our Website. You are not required to provide information about yourself when you visit our Website. However, in order to help us better serve you, we may ask you for information when you register for certain services, access various content or features, or directly contact us through our website, including:
- Contact information, such as name, email address, postal address, phone number, fax number and mobile number;
- Payment information;
- User name, password, and password-reminder questions and answers;
- Age and date of birth;
- Other demographic information, such as gender, employment information and ZIP code;
- Information for a public profile, such as your interests, your profile photo, personal updates and descriptive information that you provide, and the address of your Facebook page, LinkedIn profile, Twitter, Pinterest or your website;
- Communications preferences, such as which emails and newsletters you would like to receive;
- Search queries;
- Contact information about others when you provide information about others or refer a friend to a particular site or service;
- Correspondence you send to us;
- Information collected about you offline (including via fax, mail and in person);
- Other information that may help us to provide customized content or advertising.
Information we obtain from other sources. We may collect information about you from other sources, including through interactive applications (such as mobile devices and third-party services), from Service Providers, Licensed Providers and from commercially available sources (such as data aggregators and public databases). The following are examples of information we may collect from other sources:
- Name, postal address and telephone number;
- Demographic data, such as age, gender and income level;
- If you access third-party services (such as Facebook Connect) through our website, your username and password for those services and other information available about you on those services;
- Your interests and purchase behavior;
- Publicly observed data, such as activities on blogs, videos and other online postings;
- Other navigation data, such as websites visited and advertisements viewed or clicked on.
- Information Collected by Third Parties
We may allow third-party analytics companies, research companies or ad networks to collect nonpersonally identifiable information on our website. These companies may use tracking technologies, including cookies and Web beacons, to collect information about users of our site in order to analyze, report on or customize advertising on our site or on other sites.
If you stay logged in to your social media accounts, log-in to our website using your social media account, use a “like” button or use other social media features while visiting our website those social media companies may collect information about you. Your interactions with social media companies and the use of their features are governed by the privacy policies of the social media companies who provide those features.
- With Whom Your Information May be Shared
Your information may be shared with:
- Social Media Advertising Networks. We may share information about you with social media networks to allow for the delivery of customized advertising about products and services that you may be interested in. We provide this information to the social media network so they can deliver the ad to the right social media user. The delivery of customized social media ads, and your ability to opt-out of receiving those ads, is governed by the privacy policies of the social media companies who deliver customized ads to you.
- Licensed Providers.Licensed providers are third parties who make available special FFEBA branded discounts, products or services. Licensed providers are required to keep FFEBA user or member information confidential, and to use the information only to offer the contracted products or services to FFEBA and FFEBA user or members. Some of our licensed providers may also collect data about our members through their interactions with the members. The licensed providers may share some or all of this data with FFEBAP so that we may make available more effective and personalized service to our members. We may share information including personally identifiable information collected with Licensed Providers, even if you are not a user or member of FFEBA.
- Corporate Affiliates.We may share information including your personally identifiable information with wholly or majority owned affiliates or other affiliated organizations, so they can provide you with information about services and programs that might interest you.
- Approved Vendors.We may share your information including your personally identifiable information with companies we hire to provide certain a services such as sending mailings, improving advertising services, providing member benefits and managing databases or other technology.
- Selected Organizations.We may occasionally engage in “list exchanges” with selected organizations in which we may share your information including your personally identifiable information.
- Aggregate Data.We may share aggregate statistics and other nonpersonally identifiable information with the media, government agencies, advertisers and other third parties. These aggregate statistics will not allow anyone to identify your name or other personally identifiable information.
FFEBAS May Share Your Information With Other Third Parties:
- Pursuant to Legal Requirements.FFEBA will disclose your personally identifiable information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement agency or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.
- To Protect Our Website and Users.We will disclose your personally identifiable information when we reasonably believe disclosure is necessary to investigate, prevent or take action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our website users or others; or to enforce our website terms and conditions or other agreements or policies.
- In Connection With Business Transfers.We may share your personally identifiable information as required by law, such as in response to a subpoena or court order or in the unlikely event of a substantial corporate transaction, such as the sale of FFEBA or our affiliates, a merger, consolidation, asset sale or bankruptcy.
- How We Keep Your Information Secure
FFEBA uses commercially reasonable physical, procedural and technological security measures to help prevent unauthorized access to and improper use of the information we collect about you. For example, only authorized employees and authorized third parties are permitted to access personally identifiable information, and they may do so only for lawful purposes. When we share aggregate data with third parties we prohibit them from reengineering nonpersonal data to permit identification of individual users. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information. However, no website or Internet network can be completely secure. Although we take steps to secure your information, we do not guarantee, and you should not expect, that your personal information, searches or other communications will always remain secure. Please refer to the U.S. Federal Trade Commission’s website for information on how to protect yourself from identity theft.
- How You Can Keep More of Your Information Private
You have options for limiting who can see your information:
If you choose to share contact information with us, you will have the opportunity to update or delete that information or to shut down your account by sending an email to: firstname.lastname@example.org.
You may request to stop receiving communications from us by sending an email to: email@example.com.
Please note that if you opt out of receiving communications from us, you may continue to receive material from Service Providers, and/or other parties to whom we provided your information before processing your request to opt-out of communications. You will need to directly contact those third parties in order to opt out of receiving such communications. You also may opt out of receiving such emails by clicking on the “unsubscribe” link within the text of those third party emails.
Even if you opt out of the sharing of information for the purpose of customizing ads to your interests, FFEBA may continue to collect and use such information for other purposes.
THE WEB PAGE CONTENT ON OR AVAILABLE THROUGH THIS WEB SITE ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, FFEBA DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. FFEBA MAKES NO REPRESENTATION OR WARRANTY REGARDING THE WEB PAGE CONTENT OR ITS USE THEREOF. THE WEB PAGE CONTENT ON OR AVAILABLE THROUGH THIS WEB SITE COULD INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS AND COULD BECOME INACCURATE BECAUSE OF DEVELOPMENTS OCCURRING AFTER THEIR RESPECTIVE DATES OF PREPARATION OR PUBLICATION. FFEBA HAS NO OBLIGATION TO MAINTAIN THE CURRENCY OR ACCURACY OF ANY WEB PAGE CONTENT ON OR AVAILABLE THROUGH THIS WEB SITE. YOU ACKNOWLEDGE AND AGREE THAT FFEBA IS NOT, AND SHALL NOT BE, RESPONSIBLE FOR THE RESULTS OF ANY DEFECTS THAT MAY EXIST IN THIS WEB SITE OR ITS OPERATION. AS TO THE OPERATION OF THIS WEB SITE, FFEBA EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. FFEBA MAKES NO REPRESENTATION OR WARRANTY THAT (A) THE OPERATION OF THIS WEB SITE WILL MEET YOUR OR ANY OTHER USER’S REQUIREMENTS; (B) ACCESS TO THE WEB SITE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR FREE OF ERRORS, VIRUSES OR OTHER HARMFUL COMPONENTS; OR ANY DEFECTS IN THIS WEB SITE WILL BE CORRECTED. YOU AGREE THAT YOU, AND NOT FFEBA, WILL BEAR THE ENTIRE COST OF ALL SERVICING, REPAIR, CORRECTION OR RESTORATION THAT MAY BE NECESSARY FOR YOUR DATA, SOFTWARE.
- Limitation of Liability
YOU AGREE THAT UNDER NO CIRCUMSTANCES WILL FFEBA BE LIABLE TO YOU OR ANY OTHER PERSON OR ENTITY FOR ANY DAMAGES OR INJURY, INCLUDING ANY DIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES OR ANY DAMAGES OR INJURY CAUSED BY ERROR, INACCURACY, OMISSION, INTERRUPTION, DEFECT, FAILURE OF PERFORMANCE, DELAY IN OPERATION OR TRANSMISSION, TELECOMMUNICATIONS FAILURE OR COMPUTER VIRUS OR OTHER PROBLEM, THAT MAY RESULT FROM THE USE OF, OR THE INABILITY TO USE, THIS WEB SITE OR THE WEB PAGE CONTENT ON OR AVAILABLE THROUGH THIS WEB SITE, WHETHER IN AN ACTION ALLEGING BREACH OF CONTRACT, NEGLIGENCE OR ANY OTHER CAUSE OF ACTION, OR ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF ANY WEB PAGE CONTENT ON OR AVAILABLE THROUGH THIS WEB SITE. YOU AGREE THAT FFEBA SHALL NOT BE LIABLE EVEN IF WE OR OUR AUTHORIZED REPRESENTATIVES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. APPLICABLE LAW MAY NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU. HOWEVER, IN NO EVENT SHALL FFEBA’S TOTAL LIABILITY TO YOU FOR DAMAGES, LOSSES, AND CAUSES OF ACTION (WHETHER IN CONTRACT, TORT OR OTHERWISE) EXCEED THE AMOUNT PAID BY YOU, IF ANY, IN ACCESSING OR USING THIS WEB SITE OF WEB PAGE CONTENT THEREON.
- Financial Advice
Any recommendations or analysis performed or provided on the Web site is not intended to represent financial advice or guarantee future results. Prior to making any investment or financing decisions, please consult a qualified attorney or financial advisor.
- OTHER IMPORTANT DISCLOSURES
Your California Privacy Rights: A Notice to California Users (California Civil Code Section 1798.83). Under the California “Shine The Light” law, California residents may opt-out of LLS’s disclosure of personal information to third parties for their direct marketing purposes. Any California resident may choose to opt-out of the sharing of such personal information with third parties for marketing purposes at any time by sending an email to: firstname.lastname@example.org. For the avoidance of doubt, it is important to understand that this opt-out shall not prohibit any disclosures made for non-marketing purposes.
- LAW, DISPUTES, VENUE, JURISDICTION, CHILDREN AND NON-U.S. USERS
The site is directed to a general audience and not directed to those under the age of 18. FFEBA asks that minors not submit any personal information. FFEBA does not knowingly collect personal information from individuals under 18 years of age and if we obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that user’s personal information from our systems.
The Online Services is operated in the United States and is intended for users located in the United States. If you are located anywhere outside of the United States, please be aware that information we collect, including personal information, will be transferred to, processed and stored in the United States.
The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.
By using the Online Services or providing us with any information, you consent to the transfer, processing and storage of your information in the United States. You are also consenting to the application of United States federal and Florida state law in all matters concerning the Online Services and this Policy.
The laws of the State of Florida shall govern any dispute, including those disputes arising from FFEBA’s use of personal information or otherwise relating to privacy. This Policy does not create rights enforceable by third parties.