Types of User Information IFE Obtains
Visitors to the IFE website. Certain sections of the IFE website use “cookies” in order to enhance your experience. A cookie is a small string of text that a web site can send to your browser.
A cookie cannot retrieve any other data from your hard drive, pass on computer viruses, or capture your e-mail address. You do not have to accept cookies to continue browsing the IFE website. If you do not wish to have the IFE website place a cookie on your computer, you can set your browser preferences to refuse all cookies before accessing the IFE website.
Registered IFE Users. In order to access the full range of features on the IFE website, a visitor must register as a IFE user (“Registered IFE User”). In order to register, we may obtain the following information from visitors, which may include information that can itself be used to identify and/or contact you (“Personally Identifiable Information”):
- School and Class Information (e.g. school district, school name and location, department and job title (if applicable), class type, grade)
- Email Address
- User Name
- Phone Number
- Credit card and billing information
Content Uploaded by Registered IFE Users. Registered IFE Users can upload content containing Personally Identifiable Information, such as videos or photographs. IFE makes use of third party service providers for the resource and storage intensive requirements of video transcoding, hosting, and streaming. Videos uploaded to the IFE website are not publicly searchable outside the IFE website.
Research Information. The IFE website may be used as part of a school curriculum. As part of this use, IFE may obtain voluntary survey information from Registered IFE Users (“Survey Data”). Survey Data does not include personally identifiable information, but rather is linked to an anonymous ID number. Survey Data is used to evaluate the effectiveness of the IFE website, such as through measuring the impact the IFE website has had on a Registered IFE User’s personal food choices or eating behaviors.
Cookies. Cookies help us understand which parts of the IFE website are the most popular, where our visitors are going, how long they spend there, and the types of mobile devices and browsers visitors are using to access the IFE website. We analyze this data for trends and statistics to improve the IFE website.
Cookies also help remember your preferences, such as a username, so that you do not have to enter it again the next time.
How We Use This Information
We may use the non-personally identifiable information of our users for any legally permissible purpose, but we use Personally Identifiable Information only in the ways listed here.
Registered IFE User Information. We will use Personally Identifiable Information provided by registered IFE users in order to manage and improve the services available on the IFE website. For example, we may use Personally Identifiable Information:
- to register user accounts, respond to user inquiries, and fulfill user requests, such as to send you newsletters or retrieve a user’s password;
- to complete and fulfill your purchases and process your payments;
- to communicate with users;
- for our administrative or internal business purposes, such as to improve our content, research, evaluate and improve the IFE website’s educational efficacy, or enable promotional campaigns (these campaigns will not reveal any Personally Identifiable Information to third parties);
- to allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities – some of these activities have rules that could contain additional information about how we use and disclose your Personally Identifiable Information;
- in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
- as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We will not sell or share any Personally Identifiable Information to anyone outside IFE or the research team associated with IFE (“Nutrition Research Team”), other than in the ways identified below.
We may share your information, including Personally Identifiable Information, with third parties who perform certain services for us relating to the IFE website, such as to process credit cards, conduct communication/marketing outreach, administer sweepstakes, or conduct or evaluate research, including on the educational impact of the IFE website. We may also share your information, including Personally Identifiable Information with your school and district administrators, law enforcement agencies in response to a subpoena, to governmental agencies conducting an investigation, or if otherwise needed to protect the personal safety or property rights of any individual, any of our affiliates, or us. We may share and transfer your Personally Identifiable Information to a subsequent owner, co-owner or operator of the IFE website or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
We also may provide your Personally Identifiable Information to third party licensors (e.g. school districts, state and local education agencies) pursuant to contractual agreements. The privacy practices of such third party licensors may differ substantially from ours, and may permit sharing of your information to additional third parties beyond those contemplated here.
Content Uploaded by Registered IFE Users. Content uploaded by Registered IFE Users will be shared only with some other users and teachers from the same school as the Registered IFE User. This subset of all Registered IFE Users (“Class Roster”) will be determined by teachers and administrators at the school using the IFE website. Content uploaded by the Registered IFE User will not be shared beyond the Class Roster without permission from the Registered IFE User or a parent or legal guardian of the Registered IFE User.
Research Information. The Nutrition Research Team may use Survey Data to evaluate and improve the effectiveness of the IFE website as a nutrition teaching tool. We will not sell or share any of this information to anyone outside IFE, nor will we use it for purposes unrelated to childhood nutrition research. Any published results or findings will present user data only in an anonymized form.
Data Management, Security, and Retention
Security. We seek to use reasonable safeguards to help protect and secure your Personally Identifiable Information within our organization. Please be aware that no data transmission or storage system can be guaranteed to be 100% secure. We cannot warrant the security of information you transmit to us, and you use IFE website and provide us with your information at your own risk. If you have reason to believe that your interaction with us is not secure, please contact us as set forth below.
Data Management and Retention. At any time, Registered IFE Users and parents or legal guardians of Registered IFE Users under the age of 13 may review any information we keep about them or their children, and can request that we stop using and delete such information. This is done by emailing firstname.lastname@example.org.
We will retain Registered IFE User information for as long as the account is active or as needed to provide services. After the account is deactivated, the information is archived (“Archived Information”) and will be accessible only by IFE, Web Developers, or the Nutrition Research Team. IFE retains the right to delete any Archived Information.
Every user account has at least one designated account administrator. For accounts created by an individual above the age of 13 or by a parent on behalf of a child under the age of 13 for individual use (“Family Accounts”), a parent must always be the account administrator when children under the age of 13 are allowed to use the account. For accounts created by students in school at the direction of a teacher or other school administrator, (“Classroom Accounts”), a teacher (and optionally, a school administrator) must always be the account administrator. All accounts have management tools, accessible via the ‘My Account’ link on the IFE website, that permit an account administrator to access, change, or delete Personal Information provided to the IFE website through an Account. For Classroom Accounts, the school administrator who is the Account Administrator may add and remove individual teachers and the teacher who is the Account Administrator may add and remove individual students, although school administrators and teachers should not provide any Personally Identifiable Information aside from First Name, Last Name and Gender, for students. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. When you edit or ask to have your account information deleted, the changed or deleted information may nonetheless persist internally in our databases, for our administrative and recordkeeping purposes. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. If a parent believes that Personally Identifiable Information of his or her child is on the IFE website in a manner that the parent has not authorized, the parent may contact us as set forth below.
Children’s Privacy Notice
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age.
IFE does not use or disclose Registered IFE User information for its own commercial purposes beyond providing education services to a school. When a school contracts with IFE to use the IFE website for the benefit of its students or the entire school system, IFE is not obligated to obtain direct parental consent before collecting Personally Identifiable Information from children under 13 years of age.
For individuals using the IFE website by purchasing an individual subscription, independent of any school contract, we require the consent of Parents in order for children under 13 years of age (“Children” or “Child”) to use the IFE website in any manner that could result in a Child submitting Personally Identifiable Information. Such consent, if received, authorizes us to collect, use, and store a Child’s Personally Identifiable Information for the purposes delineated above in “How We Use This Information.” Additionally, we may link certain information collected through a variety of technologies that automatically collect certain information whenever a Child interacts with the IFE website.
Do Not Track Requests
The IFE website does not respond to Do-Not-Track requests.
Links to Other Sites
In the separately password-protected sections of the IFE website, we may include links to other websites or apps. Linked websites and apps are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of those linked websites and apps.
How to Contact Us
You may also opt out of further communications from IFE. Requests to opt out of receiving marketing emails from IFE will be honored within 10 business days of our receipt of your request. Requests to remove Personally Identifiable Information collected from you or your child via the IFE website which are properly submitted as indicated above will be honored within 10 business days our receipt of your request, unless doing so would conflict with IFE’s legal obligations or unless IFE can otherwise anonymize or render invisible the information to prevent individual identification of the user. Note that removal may not ensure complete or comprehensive removal of the information from the IFE website or IFE’s records.