FirstString Privacy Statement
This Privacy Statement was last updated on October 20, 2021
Summary Statement
We are committed to supporting the objectives of graduating college athletes, and we want to give you the comfort and confidence you need to fully participate in our services.
Notice with respect to information practices.
To maximize the value of our services, we may request information from you when you visit our Web site or use our services. When we collect information from you, we’ll tell you what is being collected, how it is collected, by whom it is being collected, why it is being collected and to whom it may be disclosed. We identify the information that is necessary to fulfill your request. Whenever we ask for additional or optional information, we identify those fields appropriately so that you know what is required to provide the requested service.
When you register/activate your participation, we request certain personally identifiable information, including your name, address, phone number, Fax number, URL, e-mail address and company name. We use this information to send you our newsletter and communicate with you about other matters that we believe you will find useful in growing or running a business.
We may also use this information to communicate with you with respect to special offers available to you. In addition, under certain circumstances we may share limited contact information with selected third parties such as selected online service providers, so that they may provide you with information about offers we believe will of interest to you.
Automatically Collected Data; Cookies: When you interact with FirstString through our web site or by use of our products or services, we receive and store certain information, which is collected using cookies and log data as described below:
In operating the web site, we use “cookies.” A cookie is a piece of information that the computer that hosts our web site gives to your browser when you access the web site. These cookies help provide additional functionality to the web site and help us analyze web site usage more accurately. In particular:
- Our web site may set a cookie on your browser that allows you to access the web site without needing enter a password more than once during a visit to the web site;
- We use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the web site, compiling reports on the web site activity and providing further services to us relating to the web site usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link:
https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631
You can prevent your data from being collected by Google Analytics on our web site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link:
https://tools.google.com/dlpage/gaoptout?hl=en;
When you first visit the web site, you will be asked to consent to the use of cookies on the web site in accordance with this Privacy Policy, and if you accept, we will store cookies on your computer.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
While we recommend that you leave cookies turned on, because they allow you to take advantage of some of the web site’s features, on most web browsers you may refuse the use of cookies by selecting the appropriate settings. Be aware, though, that if you do this you may not be able to use the full functionality of the web site.
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Web Site Usage Data
Our web site keeps track of usage data, such as the source address that a page request is coming from, as well as the IP address or domain name, the date and time of the page request, the referring Web site (if any) and other parameters in the URL. We use this data to better understand Web site usage in the aggregate so that we know what areas of our Web site users prefer. We may also use this information to track purchases of goods and services to a particular referral source for payment of commissions.
This log information is not linked to personally identifiable information gathered elsewhere on the site.
Third-Party Sites
The FirstString web site may provide links to third-party Web sites, such as those of our business partners and online advertisers. On these sites our partners may collect information about you. FirstString is not responsible for the actions of these third parties. We encourage you to review their privacy policies to learn more about what, why and how they collect and use personally identifiable information.
Third-Party Platforms and Services
This Privacy Policy does not apply to the practices of any third-party services such as Facebook or Twitter that you elect to access or to any applications developed by third parties that FirstString does not own or control (“Third-Party Apps”). While we attempt to facilitate access only to those Supported Platforms and Third-Party Apps that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of any Supported Platforms or Third-Party Apps. We encourage you to carefully review the privacy policies of any Supported Platforms or Third-Party Apps you access.
In some circumstances we may provide certain of your personally identifiable information, specifically your name and email address, to third parties who have products or services that we believe may be of benefit to you. We may be compensated by these third parties for this information. If you do not want us to provide this information to them, you may notify us via our “DO NOT SELL MY PERSONAL INFORMATION” link at [email protected].
Required and Optional Information Fields
We identify the information that is necessary to fulfill your request. Whenever we ask for additional or optional information, we identify those fields appropriately so that you know what is required to provide the requested service.
Service Providers
On occasion we will outsource the completion of certain processes to third parties.
It may be necessary to share certain of your personal information to those third parties.
For example, if our newsletter is delivered through a third party e-mail service, it will be necessary to supply that third party with your e-mail address.
All affiliates and service providers are required to conform to our privacy standards and allow us to audit them for compliance. Service providers are strictly prohibited from using your personally identifiable information for purposes other than to act on our behalf.
Data Collection from Children
Because we provide services exclusively to graduating college athletes, their colleges and universities, and potential employers, and we tailor our content specifically for these groups, our services are not designed to appeal to children. Therefore, we do not knowingly attempt to solicit or receive any information from children.
Changes to Our Privacy Policy
If we plan to make significant changes to any of our privacy policies or practices with respect to how we use personally identifiable information, we’ll post those changes to the FirstString Web site 30 days before they take effect.
Legal Disclosures
In some cases we may be required to disclose certain information to comply with a legal process, such as a court order, subpoena or search warrant.
Choices about use of your personally identifiable information
You have the opportunity to tell us you do not want us to use or share the personal information for purposes other than fulfilling your request. We will provide you the opportunity to opt-out of secondary uses of personal information you provide us.
Simply notify us during the information collection process or contact us via email at [email protected].
Update or corrections of personal information
We provide you the opportunity to update or correct your personal information online using the My Account feature or by sending us an e-mail at [email protected].
Protection of personal information from loss, misuse and unauthorized alteration
We employ industry recognized security safeguards to help protect the personal information that you have provided to us from loss, misuse and unauthorized alteration. Whenever we prompt you to transmit sensitive information, such as a credit card number, we support encryption of your data as it is transmitted to us.
We work to protect personally identifiable information stored on the site’s servers from unauthorized access using industry standard computer security products, such as firewalls, as well as carefully developed security procedures and practices. All employees must review and sign a written statement of these practices, which include limiting access to sensitive information to those employees who require such information and enforcing strict password protocols for all employees. We review the adequacy of our security measures on a regular basis.
Method of contact regarding privacy concerns
Questions regarding the FirstString privacy statement, our online privacy policy, our information practices or other aspects of privacy on our Web site should be directed to us at [email protected].
Additional Information for California Residents
This section supplements our privacy statement to provide California residents with the information needed to exercise their rights under the California Consumer Privacy Act (CCPA).
Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal data from consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | ✔ |
| An alias, Social Security number, driver’s license number, passport number, or other similar identifiers. | ✔ | |
| A name, address, and telephone number. Some personal information included in this category may overlap with other categories. | ✔ | |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A signature, Social Security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | ✔ |
| Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | ✔ |
| Commercial Information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | ✔ |
| Records of personal property. | ✔ | |
| Biometric Information | Physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA) that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | ✔ |
| Internet or other similar activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | ✔ |
| Geolocation data | Physical location or movements. | ✔ |
| Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | ✔ |
| Professional or employment-related data | Current or past job history or performance evaluations. | ✔ |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | ✔ |
| Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | ✔ |
Under the CCPA, personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the FCRA, the GLBA or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Sharing your Personal Information
In the preceding 12 months, we have disclosed the following categories of information for the business purposes described above:
- Identifiers
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial Information
- Internet or other similar activity
- Geolocation data
We disclose these categories of personal information for business purposes to the following categories of third parties:
- Our partners
- Our service providers and other third parties that cannot use personal information collected by or on behalf of us for their purposes, including but not limited to advertising networks, business process outsourcing providers, internet service providers, data analytics providers, data processors and storage providers, operating systems and platforms, social networks, and consumer data resellers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you.
Selling your Personal Information
In the preceding 12 months, we have sold the following categories of personal information:
real name, email address
Rights of California Residents
Pursuant to the CCPA, California residents have the right to submit requests for Access, Deletion, and Opt-Out, as set forth below, to FirstString®. To submit these requests, please email [email protected].
FirstString is prohibited from discriminating against in any way in response to your exercise of any of these rights. This means we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Offer a product enhancement or financial incentive that is contingent on you sharing personal information, unless that incentive is reasonably related to the value provided to us by that collection.
To ensure personal information security and prevent fraudulent requests, we may need to collect personal information and other information such as your name, email, or transaction history to verify your identity. Any authorized agents making requests on your behalf need to provide similar information for verification.
Access
You have a right to request FirstString provide you with the following information, covering the 12 months preceding the date your request is submitted.
- The categories and specific pieces of personal information collected about you
- The categories of sources of the personal information collected about you
- The business or commercial purposes for collecting or selling your personal information
- The categories of third parties to whom we sold your personal information
- The categories of third parties to whom we disclosed your personal information for a business purpose
Deletion
You have the right to request FirstString to delete the personal information collected from you, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Opt-Out
You have the right to request that FirstString not sell your personal information. To exercise that right, please email us at [email protected].
Notice to Participants Engaging in Training Programs
If you instruct FirstString not to share your Personal Information with your college or university, your participation in the training programs will not be reported to them.
FirstString Activation
When you register with FirstString, we require you to supply your name, address, phone number, e-mail address and, if you are a college, the college name and if you are a business, the company name.
We use this information to notify you about changes in our web site and to distribute our newsletter and other data that we believe will be of interest to you.
Credit card information is used only to provide payment to the services you have subscribed to. We do not share your credit card information with third parties except as required to provide payment for the services for which you have subscribed.
In addition, under certain circumstances we may share limited contact information with selected third parties such as online service providers, so that they may provide you with information about special offers we believe may be of interest to you. If you do not wish to receive such notifications in the future, you may opt out of contact at the time of registration. You can also update your preferences at any time using the My Account feature on the site.
Newsletters
We provide you the opportunity to subscribe to e-mail newsletters and other e-mail communications. You may unsubscribe by following the instructions provided in each e-mail newsletter or emailing us at [email protected] or using the app.
Contests and Surveys
From time to time, we may conduct surveys or run contests on our site.
Participation in these contests and surveys may include asking you for contact information, preferences, or other information. This information may be used to conduct research, improve our offerings, or award prizes. We may also ask for more specific demographic information such as age or gender to better understand who uses our site and to make the site more useful for you. Our contests may be conducted jointly with certain of our business partners, and certain of the information provided may be shared with those business partners.
The contest rules will identify how the information that you supply will be used in each case.
