ATHLETES FOR FREEDOM FOUNDATION
Last Updated November 24, 2020
AFF has created this privacy statement in order to fully disclose its information gathering and dissemination practices for the AFF Website (“Website”), and the Services offered and provided through the Website (“Services”).
A. BACKGROUND INFORMATION
Description of the types of personally identifiable information (Yours and that of third parties) collected through the Website and Services;
How collected personally identifiable information is used;
With whom the collected personally identifiable information may be shared;
The choices available to You regarding the collection, use, and distribution of such information;
Security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under AFF’s control; and
Instructions on how You can access and correct any inaccuracies in the information collected about You.
A note about the Website and Services: Some of AFF’s Services, data centers, service providers, affiliates or operating partners and servers may be located in other countries. As such, the Website and Services may be subject to the laws of numerous countries and jurisdictions, some of which may require AFF to disclose certain information about its users. AFF is committed to keeping Your information private while using its best efforts to comply with all applicable laws in the jurisdiction(s) in which it operates.
B. A WORD FROM AFF
C. INFORMATION AFF COLLECTS
Information AFF Collects Through the Website
The Website does not collect personally identifiable information from Your computer when You browse the Website and request pages from AFF servers. This means that, unless You voluntarily and knowingly provide AFF with personally identifiable information, AFF will not know Your name, email address, or any other personally identifiable information.
When You use the Website, AFF, or trusted authorized third parties, may also collect certain technical and routing information about Your computer (also known as environmental variables) to facilitate Your use of the Website and the Services enabled thereby. When You browse the Internet, Your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to AFF every time You access content on one of AFF’s internet domains. Examples of such information include the URL of the particular web page You visited, the IP address of the computer You are using, or the browser version that You are using to access the Website. All of this information may be collected by AFF and used to help improve its offerings to You.
Providing Your Information to AFF
You never have to provide personally identifiable information to AFF. However, should You choose to withhold certain required information, AFF may not be able to provide You with some or all of the Services. Some of the information AFF asks You to provide may be identified as mandatory or optional. If You do not provide the mandatory information with respect to a particular activity, You may not be able to engage in that activity or make such a purchase. AFF will inform You of the mandatory or optional nature of the requested or required information.
When You submit personal information to AFF through the Website, You understand and AGREE that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which AFF and its affiliates and subsidiaries maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of Your information may be undertaken by trusted vendors of AFF. AFF may use vendors to aid in the facilitation of technical support services that may potentially receive limited access to Your personal information.
PayPal, Stripe, and any other third-party payment service providers designated by AFF are responsible for payment information You provide through the Website, which will be subject to their respective privacy policies.
Third-Party Websites and Service Providers
The Website may contain links to websites owned and operated by third parties. These links are presented for Your convenience and information. AFF does not control these third-party websites and is not responsible for their privacy practices or content. AFF does not control the information collection and distribution policies on such websites other than those that are under the control of AFF itself. Content on third-party websites may not reflect products, services, and/or information provided by AFF. Third parties may also set their own cookies and/or use web beacons, which may be used to identify some of Your preferences or to recognize You if You have previously had contact with these third parties. AFF does not control the use of such technology by third parties, the information they collect, or how they use such information. You should direct all concerns regarding any third-party website directly or to the site administrator or webmaster.
Information Relating to Children (COPPA)
The Children's Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission (FTC) website. The AFF Website and any Software or Services available thereon are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, AFF recognizes that children under the age of 13 may potentially access the Website and subscribe to the newsletter, purchase Software and Services, or download software programs. Parents and Legal Guardians may request AFF to review, delete or stop the collection of any personally identifiable information of their child(ren). You may do so by contacting AFF by email at firstname.lastname@example.org.
Cookies and Web Beacons
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on AFF’s Website may require the use of a cookie for purposes of keeping information You enter on multiple pages together. Cookies also enable AFF to customize the Website and offerings to Your needs and provide You with a better online experience with AFF. In addition, cookies are used to:
Measure usage of various pages on AFF’s Website to help make AFF’s information more pertinent to Your needs and easier for You to access;
Identify and categorize the internet webpages from which a visitor came to the Website and in order to observe browsing patterns; and
Provide functionality such as online orders, AFF Services, and other functionalities that AFF believes would be of interest and value to You.
In addition, the service providers AFF uses to serve and host its advertisements may use session or persistent cookies to track the number of times the Website is accessed and whether the Website was accessed via an advertisement. There are no automatically-placed cookies within these advertisements, a cookie is placed on Your computer only if and when You click on an advertisement. The cookie generated from the advertisement does not contain any personally identifiable information and will remain on Your hard drive until You delete it. Furthermore, AFF may use email tracking services in order to receive read receipts and related information when sending emails, however, these services are used by AFF for these reasons and not to collect any personal information about You.
You may set your browser to block cookies (consult the instructions for Your particular browser on how to do this), although doing so may adversely affect Your ability to perform certain transactions, use certain functionality, and access certain content on AFF’s Website.
Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1-pixel x 1-pixel) that is placed on a website. As opposed to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of web beacons allows a website to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited on a website. AFF uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website, and to facilitate those visitors' interactions with the Website. AFF may make the aggregate data obtained from web analytics (including from its third-party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.
D. PURPOSE OF PROCESSING & USE AND DISCLOSURE OF INFORMATION
How Your Personal Information is Used
AFF collects information from You in order to record and support Your participation in the activities provided by AFF. AFF may use Your email address to send a confirmation email when You donate and, if necessary, may use other information You provide to contact You for help to process or provide a purchase or Service You have selected. Your personal information also may be used to keep You informed about new services, service upgrades, special offers, and other Services.
Disclosure of Information to Third Parties
AFF may use the services of third parties, such as email service providers, purchase, shipping and order processing merchants and marketing companies that act as independent contractors on behalf of AFF. These parties are prohibited from using personally identifiable information for any purpose other than for the purpose AFF specifies. AFF does provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to AFF. AFF prohibits the sale or transfer of personal information to entities outside of the AFF’s affiliates for their use without Your approval.
Securing the Transmission and Storage of Information
E. DATA CHOICES AVAILABLE TO YOU
Opt-In and Disclosure
You may always choose whether or not to disclose personally identifiable information and that choice will not prevent You from using the Website and having limited access to the Website and Services. Please note, however, if You should choose to withhold certain requested information, AFF may not be able to provide You with some or all of the Services dependent upon the collection of this information. You will be given an opportunity to “opt-in” and select Your preference choices for any items that are optional and which are not prerequisite for AFF rendering of Services.
You can choose at any time to opt-out of receiving emails from AFF by clicking the unsubscribe link at the bottom of any email You receive from AFF or by contacting AFF directly at email@example.com. If You elect to opt-out, AFF will not, as applicable, share Your personal information with third parties or send You emails. However, AFF may continue to use Your personal information for internal purposes, to enhance Your user experience or as necessary to administer the Website or comply with applicable law.
Contact by AFF
AFF reserves the right to send infrequent service alert messages to users to inform them of specific changes that may impact their ability to use a service that they have previously signed up for, purchased, or used, regardless of email contact opt-in status. AFF also reserves the right to contact You if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty, or purchase agreements. AFF is retaining this right because in limited cases AFF feels that it may need to contact You as a matter of law or regarding matters that will be important to You. This does not allow AFF to contact You to market a new or existing service if You have asked AFF not to do so, and issuance of these types of communications are rare.
If You are a California resident, You can request a notice disclosing the categories of personal information that AFF may share with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit Your request to AFF as detailed in Section G. Please allow 30 days for a response. For Your protection and the protection of all of AFF’s users, AFF may ask You to provide proof of identity before it can answer such a request. AFF does not respond to general do not track (DNT) requests.
F. RIGHTS OF EUROPEAN USERS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
AFF complies with the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 “On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”). If You are a natural person of the EU within the meaning of the GDPR (“Qualified Individual”), You are afforded certain additional rights by the GDPR as further described within this Section.
If and when AFF receives Your personal information directly from You via its Website or Services, it performs the functions of a Data Controller, as defined by the GDPR, and has the ability to determine how personal data is collected, for what purposes, and how this data is to be processed. As the data controller, AFF has implemented many technical and operational measures to ensure the most complete protection of personal data processed through its Website, and Services.
Legal Basis for Processing
Article 6(1)(a) of the GDPR serves as the legal basis for processing operations for which AFF obtains consent for a particular purpose. If the processing of personal data is necessary for the performance of a contract to which You are a party, as is the case, for example, when processing operations are necessary to provide a service, the processing is based on Art. 6(1)(b). The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning AFF products or Services. If AFF is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c). If the processing of personal data may be necessary to protect Your vital interests or that of another Qualified Individual, then the processing is based on Art. 6(1)(d). Finally, processing operations could be based on Article 6(1)(f) if processing is necessary for the purposes of the legitimate interests pursued by AFF or by a third party, except where such interests are overridden by Your fundamental rights and freedoms under the GDPR.
Right of Confirmation
You may obtain confirmation of whether or not Your personal data is being processed. If You wish to exercise Your right of confirmation, You may contact AFF using the contact information as provided in Section G, below.
Right of Access
You may obtain from information about Your stored personal data at any time and a copy of this information. If You wish to exercise Your right of access, You may contact AFF using the contact information as provided in Section G, below.
Right to Rectification
You may request the rectification of any inaccurate personal data. Taking into account the purposes of the processing, You have the right to have inaccurate or incomplete personal data completed or deleted, by means of first appropriately identifying Yourself and then providing a supplementary statement. If You wish to exercise Your right of rectification please may contact AFF in accordance with Section G, below.
Right to Erasure (Right to be Forgotten)
You may request the erasure of Your personal information by contacting AFF using the contact information provided in Section G, hereof. Please note that while any changes You make will be reflected in active user databases within a reasonable time, AFF may retain all information You submit for the prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where AFF otherwise reasonably believes that it has a legitimate reason to do so, such as for archiving purposes within the public interest.
Right to Restriction of Processing
As a Qualified Individual, You have the right to restrict processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of the controllers use of such data;
The controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims; or
The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right to Data Portability
You may request to receive Your personal data in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without interference.
Furthermore, You may have the personal data transmitted directly from one controller to another, where technically feasible and where such transmission does not adversely affect the rights and freedoms of others.
Right to Object and Automated Decision Making
You may object to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects You, as long as the decision is not (i) necessary for entering into, or the performance of, a contract between You and AFF; (ii) authorized by European Union or Member State law to which You are subject; or (iii) based on the data subject’s explicit consent.
Right to Object to Processing
You may object to the processing of Your personal data using the contact information provided in Section G below, unless there are legitimate grounds for the processing within the public interest, or for the establishment, exercise, or defense of legal claims.
If AFF processes personal data for direct marketing purposes, You shall have the right to object at any time to the processing of Your personal data for such purposes. This right also applies to profiling to the extent that the processing is related to such direct marketing purposes. If You object to AFF processing Your personal data for direct marketing purposes, then AFF will no longer process the personal data for such purposes.
AFF only retains personally identifiable information about You for as long as it needs to provide You with Services or otherwise fulfill the purposes for which AFF had initially collected such information, unless otherwise required by law. AFF will retain and use information as necessary to comply with its legal obligations, for archival purposes, to assist in the resolve of disputes, and to enforce its agreements.
Cross-Border Data Transfers
If and when sharing of information involves cross-border data transfers, for instance to the United States of America and other jurisdictions, AFF uses EU Standard Contract Clauses or other suitable contracts and safeguards to permit data transfers from the EU to other countries. The Standard Contractual Clauses commit companies transferring and receiving Your personal information to protecting the privacy and security of Your data. Copies of AFF’s current Standard Contractual Clauses are available on request using the contact details listed below.
G. PRIVACY-RELATED INQUIRIES AND COMPLAINTS
Athletes for Freedom Foundation
ATTN: Privacy Matter
Mailing Address: 901 N Pitt Street, STE 325
Alexandria, VA 22314
Please note that if You provide AFF with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact You with marketing offers and indicating on another occasion that they may not), AFF cannot guarantee that Your most recent privacy preference will be immediately honored.
Copyright © 2020 AFF All rights reserved. The Website, Services, and all documentation are the copyrighted property of AFF and/or its licensors and protected by copyright laws and international intellectual property treaties. AFF and related logo, and all related Product and service names, design marks and slogans are the trademarks and/or registered trademarks of AFF and/or its affiliates. All other product and service marks contained herein are the trademarks of their respective owners. Any use of the AFF or third-party trademarks or logos without the prior written consent of AFF or the applicable trademark owner is strictly prohibited.