Last revised: April 13, 2017
We place the highest importance on respecting and protecting the privacy of our customers and users of our products and services. We want you to feel comfortable and confident when using the FFG Site and with entrusting your personal information to us.
We protect the confidentiality and security of your personal information by taking reasonable security measures, including physical, technological and organization procedures, designed to protect the integrity and security of that information.
- The information we collect and how we collect it.
- How we use the information we collect.
- When we share the information we collect with others.
- Measures we take to protect the integrity and security of the information we collect.
- How you can update or correct your personal information.
Personal Information We Collect and How We Collect It
We Collect Information that You Provide to Us
In order to use the FFG Site, we will ask you to register with us. As part of the registration process, we require that you provide to us certain information, including personal information such as your name and email address.
During the process of creating your Challenge plan, you will also have the option of providing some demographic and other information, including your gender, work and relationship status, education level, etc. You also have the option of answering general, descriptive questions about your financial situation.
You may submit comments, help requests, suggestions, problems or other feedback to use through feedback functionality on the FFG Site or otherwise. If you choose to provide us with this sort of information, we may collect your email address and other information that you provide us in order to follow up with you and otherwise address or communicate with you with respect to your comments, requests, suggestions, or problems feedback.
Information We Collect Through Your Use of the FFG Site
We collect information about your interaction with and your use of the FFG Site, such as your IP address, your device, browser and operating system type and version, event information such as device crashes, which pages you view, which page linked you to the FFG Site, and which link you select when you leave the FFG Site.
As most websites do, PI uses various technologies to collect information through your interaction with and use of the FFG Site. These technologies include cookies (small files that are sent to your browser or device when you visit a website which allow the website to recognize you when you visit again and permit storage of information such as user preferences) and may also include web beacons, clear GIFs, pixels and other pixel tags (small blocks of code that can be used to read and place cookies and transmit information), HTML5 and other local storage and caching (technology that allows an application or website to store and retrieve data on a user’s device) and similar technologies. For some of these technologies, your device or browser may offer settings which may enable you to disable the usage of such technologies. However, some services or features may not function properly or as well as a result, and the settings offered by your device or browser may only apply to that device or browser.
We Do Not Intend to Collect Information from Children Under Age 13.
We do not market the FFG Site to children under the age of 13, nor do we knowingly collect information from children under the age of 13.
How We Use the Information that We Collect.
We may use the information we collect in the following ways:
- Tailor and Personalize the FFG Site. We use the information that you provide us, as well as information gathered through your interaction with and use of the FFG Site to tailor the content displayed on the FFG Site and personalize your experience to fit your needs. For example, by answering demographic questions or questions about your financial situation, the FFG Site may provide you with recommended goals and content that would be relevant to your situation. The FFG Site may also provide links to third-party sites and offerings, tailored to the information we collect from your interaction with and use of the FFG Site.
- Provide Additional Information and Alerts. We may use your contact information to provide you with additional information, alerts, and updates regarding your account, the FFG Site and your use of the FFG Site. For example, when you satisfactorily complete a course, we will use your contact information to provide you with a certificate of completion for that course and a report on how your financial knowledge, attitudes and behaviors have changed. We may also use your contact information to provide you with information about our products and services and the programs and events of and other communications from or relating to the Subscriber through which you are using the FFG Site.
- Create Aggregated and Other De-Identified Information. We may use the data we collect to create, publish, disclose and use information from which we have removed personally identifiable information, for example by summarizing, aggregating or removing certain data elements. We may use such non-identifiable information for any business purpose.
- Understand the FFG Site Usage and Improve Our Offerings. We use the data we collect from your interaction with and use of the FFG Site and aggregated and other non-identifiable data we create to perform analytics, assess performance and otherwise better understand the FFG Site activity. This allows us to better troubleshoot and resolve issues, to provide technical support assistance, and to improve the FFG Site offerings.
When We Share the Information that We Collect with Others.
Information Shared with Subscribers. We may share aggregate and other non-identifiable information about our users with our Subscribers and other third parties in our discretion, however we will not share your individual responses to assessment and survey questions or your exam scores. We may share your contact information with the Subscriber through which you are using the FFG Site and certain information, such as that you passed the courses or completed the Challenge, for their internal use in administering the FFG Site offering and related programs and benefits. For example, a Subscriber may offer an incentive for employees that complete the Challenge, and we will provide that Subscriber with information as to employees that have completed the Challenge and their contact information in order for the Subscriber to provide that incentive to those employees. We may further share your contact information with the Subscriber through which you are using the FFG Site for their use in providing you with information regarding their products and services or for other marketing or promotional purposes.
Other Information Sharing. We also may share information that we collect with third parties in the following circumstances:
- Service Providers.We may share information with third parties who provide services to us, such as fraud detection services, services relating to data collection, processing, hosting and reporting, and analytics, for the purpose of providing such services to us.
- For Legal Reasons. PI may release information it collects when PI believes that such release is appropriate to comply with the law (for example, pursuant to a subpoena, warrant, or court order), to protect against fraudulent, abusive or unlawful use of the FFG Site, to protect the rights or property of PI or others, to enforce any contract between you and PI and to investigate possible violations, or to prevent or address a situation involving danger of death or injury to any person.
- Sale or Merger of PI. PI may merge with another entity or be sold or it might sell all or a portion of its business or assets relating to the FFG Site. In such event, the information we collect from you may be transferred to or otherwise shared with another entity. We may also disclose information on a confidential basis in connection with or during negotiation of a merger, financing, acquisition, bankruptcy, dissolution, or similar transaction or proceeding.
- With Your Consent. We may share personal information with third parties when you authorize us to do so. We will not disclose your personal information to affiliates or third parties for their direct marketing purpose without first obtaining your “opt-in" consent.
- Non-Identifiable Information. We may share aggregated, de-identified or other non-personally identifiable information with third parties in our discretion
Measures We Take to Protect the Integrity and Security of the Information We Collect.
We take reasonable security measures, including physical, technological and organization procedures, designed to protect the integrity and security of personally identifiable information that we collect. For certain sensitive data, we use industry standard encryption technology to protect such data during storage and transmission through our services. We also use industry standard security technology such as firewalls designed to protect our network and systems from external attack. Our contracts with our employees and with third parties that receive your personal information include standard provisions requiring them to maintain its security and confidentiality.
You play an important role in keeping your information secure. Your account information is protected by a password that you select for your privacy and security. We encourage you to use “strong" passwords (that use a combination of upper and lower case letters, number and symbols). Please also make sure to protect your account information and log off when you are done using the services, especially if other users have access to the device you are using to access the services. You should not share your user name, password, or other security information for your account with anyone. If we receive instructions using your user name and password, we will consider that you have authorized the instructions.
Please be aware that no protection measures are perfect or impenetrable. Although we believe the measures we take are reasonable, we cannot guarantee the absolute integrity and security of your personal information or that unauthorized third parties will never be able to defeat the security measures taken by us or others. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
How You Can Update or Correct Your Personal Information.
If your personally identifiable information changes (such as your name or email address), we provide a way to correct or update personal data. This can be done at the Settings page on the FFG Site.
Your California Privacy Rights. Residents of the State of California, under the California Civil Code, have the right to request from certain companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes and a disclosure of the shared information. To make such a request, please send an e-mail or write to us at the addresses provided under “Contacting Us with Questions" above.