FIRST Privacy Policy

Last Review and Update: May 18, 2022

FIRST takes your privacy seriously. As a nonprofit and a mission-driven youth-serving organization, we are compelled to understand who we are serving, how our programs are performing, and make improvements so that we can achieve our goals of making FIRST accessible to any youth who wants to be part of the fun, exciting and life-changing experience. Thus, we need to collect certain personal data from you to ensure we are meeting our goals and responsibilities as a youth-serving nonprofit organization. This FIRST Privacy Policy describes how FIRST ("FIRST," "our," "we," "us,") collects and processes personal data that users (“user,” “your,” or “you”) provide to us at any of our web sites where this Policy is posted (the “Sites”). This Privacy Policy also applies to personal data which FIRST obtains by other means, as described below.

Treatment of Data for Minor Youth

Our storage and processing of youth data meets the requirements set forth by the United States of America’s Children’s Online Privacy Protection Act (“COPPA”) (16 CFR Part 312), the Family Educational Rights and Privacy Act (“FERPA”) (20 U.S.C. § 1232g; 34 CFR Part 99), the European Union’s General Data Protection Regulation (GDPR), the United Kingdom’s General Data Protection Regulation (UK-GDPR) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

It is our policy to gain consent from parents/legal guardians when collecting personal data on anyone under the age of 18. Youth under the age of 13 are not permitted to create accounts or provide personal data on our Sites.

If we learn that we have personal data obtained directly from a child under 13 we will delete that data as soon as possible. If you believe we have collected data on a minor under age 13, notify us per section 19 of this policy and we will delete that data as soon as possible.

1. Agreement to the Policy

By accessing, using or creating an account on any of our Sites, or by completing a FIRST Consent and Release form, you agree to be bound by all of the Sites’ terms and conditions including this Privacy Policy. If you do not agree to any of the Sites’ terms and conditions or this Privacy Policy, please do not access or use any of our Sites.  In the event you believe data was collected without your consent please see section 19 for instructions on how to contact us.

2. What personal data does FIRST Collect:

In the instances and for the reasons outlined in sections 4 and 5 of this document, FIRST collects the following personal data categories:

Name, mailing address, email address, phone number, date of birth, gender, race, ethnicity, employer, your affiliations with FIRST Strategic Alliances, FIRST Alumni status, FIRST program history, secondary or emergency contacts, credit card or banking information, passport and national identification information, images (photos and video) and your Internet Protocol (“IP”) address.  For youth participants, we also collect data on free or reduced lunch eligibility, grade in school, graduation date, school name, and for certain awards, grade point average. We may also collect medical information (if filing a medical incident report). (FIRST does not collect race or ethnicity data from residents of the European Union.)

3. How does FIRST collect the data:

We collect data when you provide it to us directly or indirectly through a third party and by “cookies” (as described in section 9, below). You may provide certain data to us when you: (a) register for in person or virtual participation in any FIRST program or event; (b) apply for, or be nominated for, awards; (c) subscribe to our newsletter; (d) send e-mail messages; (e) submit forms; (f) transmit information by telephone or letter; (g) order products; (h) submit your credit card or other payment information; (i) access certain forms or request information on our Sites; (j) visit other points on the Sites that state that such information is being collected; (k) attend a FIRST event or a FIRST Program Delivery Organization activity; (l) apply for a grant through a third party vendor; (m) register for badging and housing for a FIRST official event or through a third party vendor; (n) complete a FIRST Consent and Release form; (o) complete a survey or evaluation; (p) make a donation to FIRST, or (q) complete forms relating to medical or non-medical incidents.

When you engage in certain activities on any of our Sites, we may ask you to provide data by filling out and submitting an online form. Depending upon the activity, some of the data may be mandatory and some may be voluntary.  If you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity.

4. How does FIRST use the data:

By entering personal data into FIRST Sites or providing it to FIRST (directly or indirectly through third parties), you agree to allow FIRST to collect and use the data for the following purposes:

a. To improve our programs, products and services: FIRST uses data to evaluate and improve our programs, understand whom we are serving, assess program impact, report aggregate/de-identified data, monitor growth, improve the delivery of FIRST programs, improve our product and service-offerings, customize and improve our Sites’ content, layout, and services, diagnose problems with our servers and software, and administer our Sites, often with the assistance of our vendors. FIRST sometimes uses third parties to help implement, manage, and evaluate programs and efforts, and may share personal data with those third parties only for the purposes outlined in this Policy.

b. To improve quality and facilitate use of our Sites. FIRST may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies, to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of our Sites (for example, to facilitate navigation and the login process, enhance security, and preserve order information between sessions).

c. To assist with travel to FIRST events: We may provide assistance with travel arrangements to events, including to FIRST Championship.  Personal data including your name, gender, date of birth and passport number may be required to process visas and manage your travel arrangements to events.

5. How do FIRST and its authorized Program Delivery Organizations use the data:

By entering personal data into FIRST Sites or providing it to FIRST (directly or indirectly through third parties), you agree to allow FIRST and its authorized Program Delivery Organizations to collect and use the data for the following purposes:

a. To register you as a FIRST program participant or volunteer.

b. To manage events: We use personal data to identify your region for program participation, event registration, badging, volunteer management and general event management. FIRST Volunteer Coordinators and Event Managers may use personal data to manage events.

c. To process and administer Program awards: We may use your personal data to process and manage awards associated with the programs and events.  Award applications may require personal information such as name and contact information and may be submitted by an individual or on behalf of an individual in the case of nominated awards (e.g., Woodie Flowers Award, Dean’s List Award, Volunteer of the Year Award).

d. To communicate with you: We use personal data to communicate with you about FIRST information and related opportunities.

e. To conduct marketing, promotional activities, and outreach to support the FIRST mission.

f. To process transactions: We use personal data to engage in interactions with you including to communicate with you about your registration status, payment of team registration, processing of sponsorship information, event information and to process orders, mail program related materials and items, and to collect registration fees or donations.

g. To provide support or other services: We use personal data to provide you with support or other services that you have requested. We may use your data to respond directly to your requests for information including registering for newsletters, registering a FIRST team, registering for trainings, professional development or webinars and any other specific requests you make directly of FIRST or our authorized Program Delivery Organizations. We may pass your data along to the appropriate Program Delivery Organization to respond to your request.

h. To solicit donations for FIRST or FIRST Partner Delivery Organizations. We may use your personal data, including name, email and mailing address to solicit donations to support the FIRST mission.

i. To comply with the FIRST Youth Protection Requirements: FIRST contracts with certified background screening agencies to conduct background screening on volunteers and staff. We will share your personal data for the purpose of conducting background screening, and as required by law to address or investigate Youth Protection concerns.

 j. For insurance purposes: In certain cases, FIRST or FIRST Program Delivery Organizations are required to collect and share information including name, address, phone number, guardian/ parent name, date of birth, and details about the nature of the injurious event and care provided if you are injured while participating in one of our Programs. FIRST or FIRST Program Delivery Organizations may be required to share this information with insurance companies responsible for covering FIRST Program events, the organization hosting the event, or the facility in which the event is hosted.

6. How long does FIRST retain data:

FIRST will retain your data for as long as needed to fulfill the purposes and uses described in this Policy. When we no longer need your data, and there is no need to keep it to comply with our legal obligations or protect our legal rights, we will either delete it from our systems or depersonalize it so we can’t identify you.

If you wish to understand how to request your personal data be deleted, please refer to section 13 for more information.

7. How does FIRST share data:

FIRST does not rent or sell data to others. We share personal data with FIRST Program Delivery Organizations, FIRST Key Donors and Sponsors, vendors, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate our Sites, handle communications, implement, manage or evaluate FIRST programs and events, promote FIRST and its Programs, or complete transactions you request.

Except as otherwise provided in this Privacy Policy, FIRST will keep your personal data private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with the law or legal process served on us; (b) provide you the products, services and/or information that you may have requested; (c) protect our rights or property; (d) enforce our rights; (e) protect the interests of users of the Site or any other person; (f) operate or conduct maintenance and repair of our equipment; (g) detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law; and/or (h) otherwise comply with applicable laws.

8. How does FIRST protect information:

FIRST uses technical and organizational measures to protect data including, but not limited to: conducting third-party security audits, firewalls, maintaining security patches on external systems, a log auditing system to identify breaches, and ensuring that all web connections are over HTTPS.  Access to personal data is available through your user identification and password selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone and no one at FIRST or who represents FIRST will ever ask for your password. In addition, your personal data resides on a secure server to which only select FIRST personnel and Service Providers have secure access.

9. Cookies:

When you use any of our Sites, we may store cookies on your computer in order to facilitate and customize the experience. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us.

Our cookies store randomly assigned user identification numbers, the country where you are located, and your log-in name to welcome you back to a Site. Our cookies: (a) make your use of our Sites easier; (b) make our Sites run more smoothly; (c) track authenticated users visiting our Sites; and (d) help us to maintain secure Sites. You may decline our cookies, but some parts of our Sites may not work properly as a result. You can at any time use your browser setting to delete our cookies from your system. We may use a third party to display information on our Sites. As part of the third-party service, they may place a separate cookie on your computer.

10. Privacy Policies of Third-Party Sites:

We may maintain links to other websites on our Sites. Links to alliances and sponsoring organizations are examples of these links. This Privacy Policy only applies to FIRST.  Other sites accessible through our Site have their own privacy policies and data collection use and disclosure practices.  Please consult each site’s privacy policy.

11. How you can rectify incorrect information:

You have the ability to access and edit the personal data you provide to us. Data may be changed by logging into your FIRST user’s account, or by requesting a change in writing.  Requests in writing should be sent to privacy@firstinspires.org.

Please include your name, address, e-mail address, and/or phone number when you contact us regarding an update or correction to data.  We reserve the right to confirm your identity before updating or correcting personal data.  We encourage you to promptly update your personal data if it ever changes by logging-in to your FIRST accounts.

12. How you can object to certain uses of your data:

If you do not wish to receive email from FIRST, you may “opt-out” of receiving these communications by exercising your right to “opt out” by using the unsubscribe feature in the email or sending us an e-mail at at privacy@firstinspires.org.

13. How you can exercise your right to be forgotten:

You may request that your personal data at FIRST be deleted, by emailing privacy@firstinspires.org. You will need to complete a request form and provide information to confirm your identity at the time of your request.  We reserve the right to confirm your identity before taking any action to delete your data.  FIRST will assess each request to be forgotten on a case-by-case basis to determine the extent to which data can be deleted.  FIRST will comply with all requests to be forgotten except where FIRST has a legal obligation to retain your data.

14. How you can exercise your right to data portability:

You have the right to receive a copy of the personal data you have provided to FIRST by emailing privacy@firstinspires.org.

15. Transfer of data to other countries:

FIRST and its programs operate internationally. However, FIRST is a United States based organization with headquarters in Manchester, New Hampshire, United States of America. FIRST stores data in the United States of America and inside the European Union within the member state of Germany. When you transfer data to FIRST it will be primarily transferred to, stored and processed in one of these locations.

FIRST may need to share your personal data with FIRST Program Delivery Organizations in other countries in order to carry out the activities specified in this Policy. By submitting your personal data to FIRST, through FIRST Sites, or in connection with your interactions with FIRST offline, you consent to such transfers and to the processing of this information in any country where FIRST operates.

16. Special Notification for California Residents:

Users who reside in California and have provided their personal data to us may request information about our disclosures of certain categories of personal identifiable information to third parties for direct marketing purposes. Such requests must be submitted to us at privacy@firstinspires.org. Within thirty days of receiving such a request, we will provide a list of the categories of personal identifiable information disclosed to third parties for use in direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year.

17. FIRST Donor Privacy Policy:

This section applies to all donor-related information received by FIRST, both online and offline, from any donor.

FIRST collects and stores donor information including name, address, email address, phone number, alumni status, and donation amounts. Unless authorized by the donor, mandated by law or necessary for the processing and analyzing of donations, FIRST will not share donor information with any other entity. If the donor notified us that the donor's employer will match the donation and the donor requests that we reach out to obtain the matching gift, we may disclose the donor's contact information (name, postal address, email address and telephone number) and donation information (donation amount and supported projects) to the employer. We are not responsible for the privacy practices of donors' employers. For more information regarding the handling of information by an employer, please refer to the employer's privacy policies.

18. Changes to this Privacy Policy:

We reserve the right to change this Privacy Policy at any time.  Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, posting the revised Privacy Policy at any of our Sites. You acknowledge and agree that it is your responsibility to review the Site you are using and this Policy periodically, and to be aware of any modifications. Your continued use of a Site after any such modifications will constitute your; (a) acknowledgment of any modified Policy; and (b) agreement to abide and be bound by any modified Policy. To the extent that any modifications to this Policy materially alters how FIRST will use information collected under prior version of the Policy, FIRST will provide you notice by email using your email on file, and where required by law, will obtain your consent.

19. How to contact us and how to lodge a complaint:

FIRST has a Data Governance Team who represents FIRST and will lead investigative action, complaint handling and data breach notification. If you have any questions about this Privacy Policy, the practices of any of our Sites, or your dealings with any of our Sites, contact us via email privacy@firstinspires.org or by sending a letter to:

FIRST
200 Bedford Street
Manchester, NH, United States, 03101

Or you may call us at (800) 871-8326 or (603) 666-3906.