Introduction

Welcome to findthwhy.org (the “Website”), which is owned and operated by Symphony Workforce, LLC (“Company” or “we” or “us”). We are committed to protecting your privacy. We have established this privacy policy (this “Privacy Policy”), and are providing it to you so that you can understand the manner in which we collect, use, maintain, and disclose your information and the efforts we use to protect it. This Privacy Policy applies to information we collect: (a) on this Website; or (b) in email, text, and other electronic messages between you and this Website. Please note that this Privacy Policy is for the findthewhy.org website and does not apply to third-party websites linked from our Website. Please check the privacy policies on those web sites for more information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

The General Data Protection Regulation, which became effective on May 25, 2018, creates consistent data protection rules across Europe. It applies to all companies that process data about individuals in the European Union. The GDPR imposes responsibilities on “data controllers” and “data processors.” A company is a “data controller” when it has the responsibility of determining why and how personal data is processed. A company is a “data processor” when it processes personal data on behalf of a data controller. The Company operates as a data controller.

This Privacy Policy is designed to address only the Company’s data practices with respect to activities conducted by the Company on its own behalf. For those activities, the Company acts as a data controller and may appoint third parties to act as data processors on its behalf. The Company is committed to ensuring that it has appropriate terms in place with such partners so that both the Company and the partners comply with their respective requirements under the GDPR.

Data controllers must have a legal basis to process your personal information. Our legal basis to process your information arises from our need to use your information to provide you with the services described on the Website and customer support and to advance the Company’s other legitimate interests, as discussed more fully in this Privacy Policy. The Company also relies on your consent in some circumstances as the basis for the processing your personal information.

Age of Users

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have inadvertently and without authorization obtained any information from a child under 13, please contact us.

Individuals who are age 13 or older but under the age of 18 (individually, a “Permitted Minor”, and collectively, “Permitted Minors”) are only allowed to use the Website with the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy. If we learn we have collected or received personal information from a Permitted Minor without the supervision or consent of a parent or legal guardian, we will delete that information. If you believe we might have inadvertently obtained any information from a Permitted Minor without parental consent, please contact us.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” below for more information.

Personal Information Collected

We recognize the need for consumers to control the use and management of personal information. By personal information we mean information that can be used to identify or contact an individual. This may include, but is not limited to, a first and last name, a physical address, an email address, a date of birth, or a phone number. We may, from time to time, collect information from parents about their minor children (for example, we may ask about your child’s date of birth), for purposes of marketing, and providing products and services. If you are a parent providing personal information about your minor child, your provision of such information constitutes your consent to our collection of such information and your consent to our use of the information for the purposes set forth in this Privacy Policy. If you are visiting our Website to browse or find information about our products or services, you do not need to provide any personal information about yourself or about any other person. If you decide to register, however, we may collect this information so that we can provide you with the service you requested.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or participating in our services and programming. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us, such as when you request support, contact us with questions or feedback, complete our surveys, engage with us on social media or otherwise interact with us.
• Your submission of stories to us about your experience with Find the Why!

Automatic Information Collected

Like most website operators and social media, we collect certain information automatically, without your input, of the sort that web browsers and servers and social media typically make available, such as your internet connection, operating system, browser type, language preference, referring site or source, location data, and other usage details. Our purpose in collecting this automatic information is to better understand how our visitors use the Website and social media. This information, and information about internet IP and social media, as well as the date and time web pages are visited, are stored in various security and traffic logs. Unless we are tracking down a technical problem or we suspect either fraudulent behavior or illegal conduct, we do not trace specific user sessions.  We may also track precise geolocation data, such as location-based information, when you allow our Website to access your location.

Supplemental Technologies

Our Website may use browser cookies, session identifiers, and browser detection technology to provide consumers with a more pleasant, personalized online experience. Many browsers provide consumers with the ability to disable some or all of these technologies. Disabling them may prevent you from viewing some webpages. Cookies we use do not place any personally identifiable information on your computer.

Information Collected from Other Sources

We may receive personal information about you from companies that help provide our services.  We may also receive personal information from data providers, such as information services and data licensors, and marketing partners, such as companies that have entered into joint marketing relationships or joint ventures with us.  We may combine personal information about you that we receive from third parties with information we have already collected about you and use that combined information pursuant to this Privacy Policy.

Information Collected from Third Party Platforms

If you communicate with us or mention us via social media (such as Facebook, Twitter, Google, Instagram) or other third party online platforms, we may collect information about you, such as the communications, your name, your user ID and/or username, and any information or content you have permitted the platform to share with us.  The platform provider’s privacy policy will apply to your interactions and its collection, use and sharing of your personal information, including when you interact with pages that we maintain on social media platforms.  You or the platforms may provide us with information about you, and we will treat such information in accordance with this Privacy Policy.  You should check your privacy settings in your social media accounts to understand and change the information sent to us through these services.

Third-Party Use of Supplemental Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Personal Information Use

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To service your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To respond to your requests, resolve disputes, and/or troubleshoot problems.
• To deliver information related to any Find the Why! challenge to you.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may periodically send you emails or social media notifications concerning products or services and newsletters. Any such notification will include instructions for opting out of future mailings.

Disclosure of Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or that you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To third parties to make their products or services available to you if you purchase such third-party products or services.
• With your consent.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our users, or others.

We take reasonable steps to ensure that third parties to whom we disclose information provided by you are obligated to protect your information on our behalf. However, we are not responsible for the privacy practices of third-party advertisers or for any other web sites reached through links from our Website.

We will not sell or trade your information to unrelated third parties without your consent.

You are responsible for ensuring the accuracy of personal information you provide to us when registering for Find the Why!. We use the information you provide when registering for Find the Why! to service your participation in competitions and send you promotional emails and for no other purposes. After registering, you are responsible for updating your contact information as needed.

Confidentiality and Security

We take reasonable steps to ensure that your information is protected. Our Website is hosted in a data center which makes use of multiple levels of redundant firewalls and database encryption to protect information. Internally, we limit access to your information to those employees or agents whom we believe have reasonable need to use the information to provide products or services to you, or to perform their jobs. In addition, any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Notifications

This Website may send you e-newsletters and notifications via email or on social media in order to communicate with you. These communications are considered part of our service and may not be disabled. We will send the email, but we cannot guarantee delivery. You are responsible for providing a valid email address and for updating it when your address changes.

History

This Privacy Policy was last updated on the date written above. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website homepage. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Your Rights: Contact

If you do not want to have your contact information used by us to promote third parties’ products or services, you can opt-out by contacting us below. If you no do not want us to retain information about your minor child beyond a certain date or if you do not want us to use information of your minor child for hiring or any other purposes, please so advise us by contacting us at the address indicated below. You may also contact us at the address indicated below to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” for more information.

Please direct all privacy-related questions and concerns to the following address:

Symphony Workforce

Attn: Customer Care

800 N. Front St. #1000

Waterloo, NE 68069

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://app.findthewhy.org/CaliforniaPrivacy

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the address indicated above.