Welcome to Families Are Forever, (“FAF”) and its website, provided and maintained by Families Are Forever, Inc., ( “FAF”, or “Company,” or “We,” or “Us,” or “Our”), a not-for-profit international orphan care ministry and adoption organization, that provides a service that prepares families for international adoption through Our Hague compliant, interactive, educational courses, content, tools and training (“Services”) through Our Website located at www.familiesareforever.org (“Website” or “Site”). Our Services help give families what they need to become loving advocates for their adoptive children.
In the event You choose not to agree and accept the current Policy, or any new, modified or amended terms to this Policy, You shall immediately cease use of any of the FAF Services. Nothing in this Policy shall be deemed to confer any third-party rights or benefits. Additional terms may apply to certain Services and/or products, and those additional terms shall become part of Your agreement with Us if You use those Services and/or Products.
Last Update: March 23, 2019
a. Use by FAF
b. Use by Our Users
FAF acknowledges that You have the right to access Your Personal Information upon Your written request. Our Users control and are responsible for correcting, deleting or keeping their information up-to-date and accurate. If You request to remove data, User Information and/or Personal Information, We will respond within a reasonable timeframe. You may do so by contacting Us at http://familiesareforever.org/contact/ or
1400 136th Ave., Suite 201 Vancouver, WA 98684.
FAF collects information under the direction of its Users, and has no direct relationship with the individuals whose Personal Information it processes. We may transfer User Information and Personal Information to companies, third party affiliates, partners, and/or vendors that help Us provide, analyze and improve FAF Services and Our business. We will only provide information necessary to improve and operate Our business.
c. “Personal Information”
This refers to full name, email address, credit or debit card numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, disability information, or other employment, financial or health information.
Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational Information refers to information about Your computer and Your visits to this website such as Your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. We may collect and process payment information, including credit cards numbers and billing information (“Payment Information”), from You when You pay for training or courses on Our Site and additional services, using a secured third party payment gateway, such as Stripe.
d. “User Information”
User information includes, but is not limited to, email, address, password, phone number, location, number of users accessing FAF Services, gender, ethnicity, race, and names of users associated with Your account, and content, text, course answers, information and media uploaded to Your Account through the use of FAF Services. User Information can also include information about any transactions, both free and paid, that You enter into on the Websites, and information about You that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that We acquire from service providers.
a. When You Visit FAF Site
We may use analytics software to allow Us to better understand the functionality of FAF Services on Your devices. These analytics tools may record information such as how often You use the Site, the events that occur within the Services, aggregated usage, performance data, and where the Services were accessed from. In addition to information We collect on Our Sites, We may also collect Your city location, device model and version, device identifier (or “UDID”), OS version, and Your FAF Service credentials.
We may send emails, text notifications, chat and/or postal mailings from time to time in order to update You about events, promotions, offers, changes to Your account, changes to Our Terms of Service and this Policy. If You no longer wish to receive such communications, You may opt-out or unsubscribe to all marketing and email campaigns. However, You cannot unsubscribe from emails regarding Your Account, unless You delete Your Account with FAF.
We may send You an email on behalf of a User who has invited You to register for FAF Services (“Invitation Email”). You may opt out of any Invitation Email at any time by clicking on the “unsubscribe” button located at the bottom of the Invitation Email.
We may link information We store within the analytics software to Personal Information you submit within the Services. We do this solely to improve the FAF Services We offer You, and to improve Our marketing, content, analytics and Site functionality.
b. When You Register for FAF Services
c. When You Use FAF Services
If You choose to use FAF Services after registering on Our Site, You will be required to provide User Information and Personal Information. You will also be required to pay Training Fees and other costs, where We will ask for and collect Payment Information. We will ask for and collect the same information as outlined in Section 2(b) above. The User Information and Personal Information provided for the FAF Services is stored and managed on servers and third party hosting services, such as SAM, InReach Solutions, and Thinkific.
d. When You Use Non-FAF Services Provided on the Site
If You choose to use Non-FAF Services through Our Site, You will be required to provide the same User Information and Personal Information and additional information outlined in Section 2(b) above. The User Information and Personal Information provided for the Non-FAF Services is stored and managed on SAM, InReach Solutions and Thinkific.
e. Log Files
When You use FAF Services We automatically collect information about Your computer hardware and software. This information can include Your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses (“Log Files”). This information is used by Us for the operation of FAF Services, to maintain quality of FAF Services, and to provide general statistics regarding use of FAF Services. For these purposes, We do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
f. Information Received From Third Parties
From time to time, We may receive User Information and/or Personal Information about You from third party sources including partners, affiliates, and agencies, (“Third Parties”) with which We may offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites. We will only use the User Information and/or Personal Information received from Third Parties for business purposes and to enhance the FAF Services.
g. Information About Children
FAF Services are not intended for or targeted at children under the age of eighteen (18) (“Minor”), and We do not knowingly or intentionally collect information about Minors. If You believe that We have collected information about a Minor, please contact Us at http://familiesareforever.org/contact/ or 1400 136th Ave., Suite 201 Vancouver, WA 98684 so that We may delete the information.
a. Online Data Collection Methods
Following are examples of some of the ways We collect online data:
|Training Course Information|
|Information Received from Responses Provided to FAF|
b. Offline Data Collection Method
Following are examples of some of the ways we collect data offline:
|Other Adoption Agencies|
b. Use of Your Information
We use the information We collect in a variety of ways, including using the information to customize features and training that appear on the Site. We also may provide Your User Information and/or Personal Information to third parties, such as service providers, and contractors, in order to operate and manage the FAF Services. The User Information and/or Personal Information We gather and collect enables Us to provide the Site and FAF Services to help You make full use of FAF Services. You hereby agree that We may use Your User Information and/or Personal Information that We collect to:
- Provide FAF Services;
- Contact You for customer service and/or training purposes;
- Contact You to inform You of important changes or additions to Our Site or FAF Services offered;
- Send You material by trusted third parties;
- Send You administrative notices, offers and any other communications that We believe may be of interest to You;
- Any company that acquires ownership or control of FAF or that may purchase some or all of FAF’s assets;
- Analyze the use, design, functionality and user feedback of the Site and FAF Services;
- Amalgamate data and information for analysis and publication;
- Collect and segment data to optimize and improve FAF Services;
- Operate, improve and maintain Our Products and FAF Services, including analyzing user behavior;
- Process payments and refunds;
- Administer promotions, offers, new feature notifications, and to provide features and display relevant content to You;
- Provide other companies with statistical information about Our users — but this information will not be used to identify any individual user;
You hereby agree to be contacted by Us by email, office phone, mobile phone, text, chat boxes and features, social media, postal mail, chat and any future communication methods that You provide to Us through the use of FAF Services. You may, at any time and for any reason, withdraw Your consent to Our use of Your User Information and/or Personal Information by contacting Us using the contact information below.
c. Use of Navigational Information
We use Navigational Information to operate and improve FAF Services. We may also use Navigational Information alone or in combination with Personal Information to provide You with personalized information about FAF and its partners, affiliates and third parties, to which You may unsubscribe from.
d. Use of Credit Card Information
If You give Us credit card information, We use it solely to collect payment from You as necessary to complete certain trainings. We use third-party service providers to manage credit card processing. These third party service providers are not permitted to store, retain, and/or use the financial, banking and/or credit card information that You provide them, except for the sole purpose of credit card processing on Our behalf.
e. Customer Testimonials and Comments
We may post user testimonials and comments on Our Sites upon written notice to You, which may contain Personal Information. You have the right to request removal of such testimonial and/or comment(s) upon receiving Our written notice.
a. Service Providers and Contractors
b. By Law or to Protect Rights
We may disclose part or all User Information and/or Personal Information collected through FAF Services, if (1) required by law; (2) if We believe that disclosure is necessary to comply with the law; (3) to enforce Our intellectual property rights; (4) to protect the rights, property or safety of Us and Our employees or agents; and (5) if necessary to defend against third-party claims. We may also disclose User Information and/or Personal Information collected on the Site when requested to comply with a court order, investigation, subpoena or governmental request. We will notify You of such use, either by a notification on the Site or by email to Our Users.
c. Business Transfers
d. With Your Consent
We may share User Information and/or Personal Information when You provide Us with Your consent to do so. This may occur when You consent affirmatively or it may occur through Your use of FAF Services as provided in this Policy. For instance, when You request information or services from Our affiliates, partners, service providers, or other third parties through Us, or when You post information to Our Site, You provide Your consent for Us to share that information with others in the regular course of business.
e. We Never Sell Personal Information
Please bear in mind that whenever You voluntarily make Your User Information and/or Personal Information available for viewing by third parties online – for example through email or registering on a website- that information can be seen, collected and used by others besides Us. We are not responsible for any unauthorized third-party use of such User Information and/or Personal Information.
We may, from time to time, contact You on behalf of external business partners about a particular offering that may be of interest to You. In those cases, We do not transfer Your User Information and/or Personal Information to the third party unless You provide Us written approval.
Our legal basis for collecting and using the Personal Information described above will depend on the User Information and/or Personal Information concerned and the specific context in which We collect it. However, We will normally collect User Information and/or Personal Information from You only where We have Your consent to do so, where We need the User Information and/or Personal Information to perform a contract with You, or where the processing is in Our legitimate interests is not outweighed by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect and maintain User Information and/or Personal Information from You.
You may opt-out of promotional and marketing e-mails by using the “Unsubscribe” link in Our e-mails and notifications. Under rare circumstances We may need to contact some or all Users to make an important announcement about the Site and/or FAF Services, its use, privacy or service changes. You may not unsubscribe or “opt-in/opt-out” of these announcements because they may contain very important information regarding Your legal rights, User rights, privacy concerns and/or account information. You may unsubscribe from all emails by deleting Your Account.
If We ask You to provide Personal Information to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of Your Personal Information is mandatory or not (as well as of the possible consequences if You do not provide Your Personal Information). Similarly, if We collect and use Your User Information and/or Personal Information in reliance on Our legitimate interests (or those of any third party), We will make clear to You at the relevant time what those legitimate interests are.
Processing shall be lawful only if and to the extent that at least one of the following applies:
a. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
b. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
c. processing is necessary for compliance with a legal obligation to which the controller is subject;
d. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
e. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
FAF works to protect Your User Information and/or Personal Information by using reasonable and appropriate technical, administrative and physical procedures to protect User Information and/or Personal Information from loss, misuse, unauthorized access, disclosure, destruction or alteration. We also take precautions to protect Users’ User Information and/or Personal Information off-line, and We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. However, We cannot fully ensure or guarantee the security of any information You send to Us, and You do so at Your own risk.
All of Our Users’ User Information and/or Personal Information is restricted in Our office(s) and only employees, FAF affiliated service providers, engineers, developers and/or independent contractors who need the information to perform a specific job, are granted access to Your User Information and/or Personal Information. Employees and independent contractors who violate FAF’s customer privacy safeguards are subject to disciplinary action, including termination. We use industry standard measures, including encryption where appropriate. We cannot and do not guarantee that information supplied to Us will not be intercepted while being transmitted over the Internet. Our servers are based in the United States, so Your User Information and/or Personal Information and other data will be hosted and processed by Us.
Our computer systems are hosted in a secure data center environment that uses a firewall, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. The data center is a highly protected environment with several levels of physical access security and twenty-four (24) hour surveillance.
We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if You directly disclose any information through Our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information You have posted on the Sites if You so request, as described in “Opting Out and Unsubscribing” below.
You may unsubscribe from Our marketing, sales, and promotional communications by clicking on the “unsubscribe” link located on the bottom of Our e-mails, updating Your communication preferences, or by sending Us an email at http://familiesareforever.org/contact/ or 1400 136th Ave., Suite 201 Vancouver, WA 98684
Attn: Privacy Update and Request.
However, Users cannot opt-out of receiving transactional emails related to their account with Us or FAF Services, unless they delete their Account.
Our partners are solely responsible for their own marketing emails and other communications directed to You. We cannot unsubscribe You from Our partners’ communications. You may, however, unsubscribe from Our communications regarding Our partners’ by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
When We have no ongoing legitimate business need to process Your Personal information, Navigation Information, and/or User Information, We securely delete the information or anonymize it or, if this is not possible, then We will securely store Your User Information and/or Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if You so request, as described above.
If You provide any information to Our partners as part of their use of FAF Services, Our partners decide how long to retain the Personal Information, Navigation Information, and User Information they collect from You. After termination, We may, unless legally prohibited, delete all Personal information, Navigation Information, and User Information.
If You have elected to receive marketing communications from Us, We retain information about Your marketing preferences for a reasonable period of time from the date You last expressed interest in Our content, Products, or Services, such as when You last opened an email from Us or ceased using Your FAF Account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
If You share User Information and/or Personal Information with Us, You will have the opportunity and right to review, update, change or delete the User Information and/or Personal Information You have provided to Us (and that We continue to store) at any time. If and when You ask Us to delete or modify Your User Information and/or Personal Information, We reserve the right to retain a record of certain User Information and/or Personal Information, and to record changes in order to comply with applicable federal, state or local law(s). If You remove User Information and/or Personal Information that You have made public on the Sites, copies may remain viewable in cached and archived pages of the Sites.
You have the following data protection rights:
i. You can request access, correction, updates or deletion of Your Personal Information and User Information;
ii. You can object to the processing of Your User Information and/or Personal Information, ask Us to restrict processing of Your User Information and/or Personal Information or request portability of Your User Information and/or Personal Information;
iii. If We have collected and processed Your User Information and/or Personal Information with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your User Information and/or Personal Information conducted in reliance on lawful processing grounds other than consent; and
iv. You have the right to complain to a data protection authority about Our collection and use of Your User Information and/or Personal Information.
To exercise any of these rights, You may contact us at http://familiesareforever.org/contact/ or
1400 136th Ave., Suite 201 Vancouver, WA 98684.
We will respond to Your request to change, correct, or delete Your User Information and/or Personal Information within a reasonable timeframe and notify You of the action We have taken, if any.
By using any of FAF Services, You expressly consent to the following:
ii. Our servers are based in the United States., so Your User Information and/or Personal Information will be primarily processed by Us in the United States or Canada. You consent to the transfer and processing of Your User Information and/or Personal Information in the United States or Canada by Us and by Our partners and affiliates;
iii. You consent and agree that We may transfer Your User Information and/or Personal Information to data processors located in countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and You may revoke Your consent by opting out at any time, as described above. Please note that if You opt-out, We may no longer be able to provide You with Our Service;
iv. You consent to Us sharing Your User Information and/or Personal Information with relevant persons working for service providers who assist Us to provide Our Service; and
Families Are Forever
1400 136th Ave., Suite 201 Vancouver, WA 98684.