PRIVACY POLICY OF THE

CLUBFOOT RESEARCH FOUNDATION (501c3) WEBSITE

 

NOTICE: On May 15, 2018, CRF adopted an amended Privacy Policy, providing as follows:

CRF and each Member that provides courses through the CRF Site care about the confidentiality and security of your information. This Privacy Policy applies to information that ClubfootResearch.ORG collects through the ClubfootResearch.ORG Site when you interact with ClubfootResearch.ORG, with Members, with other users, and generally with the ClubfootResearch.ORG Site.

Your information is received and controlled by ClubfootResearch.ORG according to this Privacy Policy when you sign up for an ClubfootResearch.ORG account or otherwise use the ClubfootResearch.ORG Site.

ClubfootResearch.ORG is solely and independently responsible for its own privacy practices. No Member is responsible for ClubfootResearch.ORG’s privacy practices.

If you enroll in a course offered by a Member through the ClubfootResearch.ORG Site, information about you and your activity in the course is received and controlled also by that Member as described in this Privacy Policy.

Each Member is solely and independently responsible for its own privacy practices. No Member is responsible for another Member’s privacy practices. Also, ClubfootResearch.ORG is not responsible for any Member’s privacy practices.

If you do not accept the terms of this Privacy Policy, then please do not access, browse, or register for the ClubfootResearch.ORG Site or enroll in any courses. If you choose not to provide certain information required to provide you with various products and services offered on the ClubfootResearch.ORG Site, then you may not be able to establish a user account or obtain those products or services.

Any version of this Privacy Policy in a language other than English is provided for convenience and you understand and agree that the English language version will control if there is any conflict.

This Privacy Policy is organized as follows:

  1. Information that ClubfootResearch.ORG collects from you (including Personal Information)

  2. Cookies and Tracking Technologies on the ClubfootResearch.ORG Site

  3. How your information is used

  4. How your information is shared

 

How to manage your Personal Information

  • Storage & Security

  • Privacy Policy updates

  • Contact information

  • Glossary

 

INFORMATION THAT CRF.ORG COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)

 

CRF.ORG directly collects information when you:

  • Sign up for an ClubfootResearch.ORG user account and create an ClubfootResearch.ORG user profile.

  • enroll and participate in online courses.

  • purchase a product or service (for example, course certificates).

  • send email messages to ClubfootResearch.ORG (including messages to learner support at info@clubfootresearch.org).

  • participate in user surveys; and

  • participate in public forums, webinars, and other interactive experiences on the ClubfootResearch.ORG Site.

 

ClubfootResearch.ORG also indirectly collects usage information about your visit to the ClubfootResearch.ORG Site, as explained in the section below titled Cookies and Tracking Technologies.

 

ClubfootResearch.ORG does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the ClubfootResearch.ORG Site, for example a Verified Certificate, you will be directed to ClubfootResearch.ORG’s third-party payment processor and ClubfootResearch.ORG’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the ClubfootResearch.ORG Site.

 

ClubfootResearch.ORG requires your Personal Information limited circumstances when you:

  • sign up for an ClubfootResearch.ORG user account (name, username, email address);

  • purchase a training certificate (so that ClubfootResearch.ORG’s third-party vendor can authenticate your identity) or other product or service (so that ClubfootResearch.ORG’s third-party vendor can process payment);

  • participate in remote proctoring or other course facilitation processes (so that ClubfootResearch.ORG’s third-party vendor can monitor and assess the integrity of your course activity); or

  • earn a verified Certificate (the certificate will have your name on it).

  • To the extent that ClubfootResearch.ORG associates the information that ClubfootResearch.ORG collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.

 

You may voluntarily choose to share additional Personal Information on the ClubfootResearch.ORG Site, for example:

  • in your ClubfootResearch.ORG account profile (and you may display a limited or full profile to other ClubfootResearch.ORG Site users).

  • in applying for financial assistance, or grant funds, sponsorships or similar

  • when participating in a course, forum, webinar, or other interactive experience on the ClubfootResearch.ORG Site (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the ClubfootResearch.ORG Site or a course).

 

ClubfootResearch.ORG encourages you to use discretion before voluntarily sharing additional Personal Information on the ClubfootResearch.ORG Site. (If you later choose to delete your ClubfootResearch.ORG account, deletion of your Personal Information will be subject to the process and limits outlined below.)

Members do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Member that offers the course will receive Personal Information from your ClubfootResearch.ORG account profile plus the information that ClubfootResearch.ORG collects about your activity and performance in the course in which you enrolled.

 

Cookies And Tracking Technologies on the ClubfootResearch.ORG Site

Like many companies, ClubfootResearch.ORG uses Cookies and other common Tracking Technologies on the ClubfootResearch.ORG Site and in email communications to help ClubfootResearch.ORG better understand your use and needs of the ClubfootResearch.ORG Site, current and future ClubfootResearch.ORG-related products and services, and how ClubfootResearch.ORG and Members can improve. For example: Tools issued by WIX or other website technologies that provides statistics and data for website management based on your cookie settings, ClubfootResearch.ORG tracks information indicating, among other things, which pages of the ClubfootResearch.ORG Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used.

 

ClubfootResearch.ORG may log the IP address, operating system, and browser software (including mobile use and device type when you use ClubfootResearch.ORG native mobile apps) you used when accessing the ClubfootResearch.ORG Site, and ClubfootResearch.ORG may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and

 

ClubfootResearch.ORG may track and collect information from emails that ClubfootResearch.ORG sends to you, for example whether you opened the email or clicked on any links from the email.

 

ClubfootResearch.ORG also partners with third parties to help us track and understand your activity on the ClubfootResearch.ORG Site, how you interact with ClubfootResearch.ORG’s social media, and how you find or may be referred to the ClubfootResearch.ORG Site. Individual Members may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the ClubfootResearch.ORG Site.

 

ClubfootResearch.ORG and Members use Cookies and other Tracking Technologies for the following purposes:

 

when necessary for system administration, security, and integrity to ensure the ClubfootResearch.ORG Site works properly for you. Without these technologies, the ClubfootResearch.ORG Site may not function correctly.

 

to enable analytics, performance and functionality, to help ClubfootResearch.ORG and Members gather information about how visitors use the ClubfootResearch.ORG Site and monitor ClubfootResearch.ORG Site performance, and to enhance your experience by recognizing and remembering whether you have visited the ClubfootResearch.ORG Site before and may have any personal preferences; and

 

to support marketing by enabling ClubfootResearch.ORG and Members to deliver content relevant to your interests on the ClubfootResearch.ORG Site and third-party sites based on how you interact with ClubfootResearch.ORG or Member advertisements or content. ClubfootResearch.ORG and Members use “first-party” cookies, which means cookies served by ClubfootResearch.ORG or an individual Member, and “third-party” cookies, which means cookies served by third parties that help ClubfootResearch.ORG and Members track this information.

 

You have some options for managing Cookies and other Tracking Technologies. These include:

 

Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject ClubfootResearch.ORG’s Cookies, many functions and conveniences of the ClubfootResearch.ORG Site may not work properly.

 

Opting-out of certain third-party tracking and advertising: Some of the third parties used by ClubfootResearch.ORG or a Member for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available at the ClubfootResearch.ORG learner Help Center and includes, for some, links to applicable opt-out processes. Neither ClubfootResearch.ORG nor any Member is responsible for the effectiveness of any third-party opt-out options.

 

HOW YOUR INFORMATION IS USED

ClubfootResearch.ORG and Members use information, including Personal Information, to carry out the following purposes:

 

Operate and improve the ClubfootResearch.ORG Site – This includes creating and improving features that support the ClubfootResearch.ORG community and enable ClubfootResearch.ORG Site usage at scale. This also includes personalizing the ClubfootResearch.ORG Site, so your learning experience is tailored to your interests and needs.

 

Create, administer, provide, and teach courses – This includes creating and improving the delivery of massive open online courses and programs on ClubfootResearch.ORG. This also includes personalizing courses, so your learning experience is tailored to your interests and needs and assessing your performance and awarding certificates.

 

Offer and improve products and services – This includes enabling you to navigate the ClubfootResearch.ORG Site, to enroll and participate in courses and programs on the ClubfootResearch.ORG Site, to learn effectively in such courses and programs, and to purchase or obtain products and services on the ClubfootResearch.ORG Site such as Verified Certificates.

 

Develop and maintain the security and performance of the ClubfootResearch.ORG Site – This includes tracking ClubfootResearch.ORG Site outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the ClubfootResearch.ORG Site.

 

Communicate with you – This includes answering your course and platform questions, notifying you of course and ClubfootResearch.ORG Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of ClubfootResearch.ORG or ClubfootResearch.ORG affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.

 

Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners’ access and master course materials online, with the goal of improving course outcomes.

 

Track ClubfootResearch.ORG Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.

 

Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or acting regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of ClubfootResearch.ORG, Members, or others, and as otherwise required by applicable law.

 

ClubfootResearch.ORG or a Member may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

HOW YOUR INFORMATION IS SHARED

ClubfootResearch.ORG and Members share information, including Personal Information, with third parties for the following purposes:

 

With service providers, contractors, and other third parties that help carry out the uses described above – ClubfootResearch.ORG requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the ClubfootResearch.ORG Site and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.

 

With other learners in courses that you take and with other visitors to the ClubfootResearch.ORG Site, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the ClubfootResearch.ORG Site designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, ClubfootResearch.ORG and each Member that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you but will only provide others your username (for clarity, no disclosure of your real name or email address).

 

With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, ClubfootResearch.ORG will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.

 

With affiliates of ClubfootResearch.ORG or a Member, or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

 

ClubfootResearch.ORG or a Member may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, ClubfootResearch.ORG or a Member may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.

 

HOW TO MANAGE YOUR PERSONAL INFORMATION

 

You can manage your Personal Information through contacting the ClubfootResearch.ORG at info@clubfootresearch.org or when you sign up with your email to provide specific information you wish to limit. If your request involves information controlled by a Member, ClubfootResearch.ORG learner support will notify and coordinate with the appropriate Member to address your request. ClubfootResearch.ORG will provide support to the extent required by applicable law (for example, learners in the UK/European Union) and more broadly, when possible, as a courtesy in our sole discretion. ClubfootResearch.ORG will notify you if ClubfootResearch.ORG is unable to meet a request that is not legally required. Similarly, Members will only be obligated to comply with requests to the extent legally required but may choose to comply with other requests in their sole discretion.

 

Access and correct your Personal Information

 

Much of your Personal Information is available in your ClubfootResearch.ORG account. Your name, email address, and other identifiable profile information is editable through the profile settings in your ClubfootResearch.ORG account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Verified Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact ClubfootResearch.ORG learner support to access and update this or other information. If your request involves information controlled by a Member, ClubfootResearch.ORG learner support will notify the appropriate Member of your request.

 

Exceptions:

Usernames cannot ever be changed. This is an ClubfootResearch.ORG system restriction. Because usernames identify you in courses and elsewhere on the ClubfootResearch.ORG Site, ClubfootResearch.ORG encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.

 

ClubfootResearch.ORG does not track or index every time or every place on the ClubfootResearch.ORG Site when or where a learner may volunteer Personal Information, so neither ClubfootResearch.ORG nor Members will be able to help you locate or manage all such instances. ClubfootResearch.ORG encourages you to use discretion before volunteering Personal Information on the ClubfootResearch.ORG Site.

 

Restrict or object to the processing of Personal Information

 

If you want to manage emails and other communications to you, you may update your preferences in your ClubfootResearch.ORG account dashboard, follow the steps described in links at the bottom of email messages, or contact ClubfootResearch.ORG learner support. You may object to, or request that ClubfootResearch.ORG or a Member stop, its use of your Personal Information for other purposes by contacting the ClubfootResearch.ORG learner support team. If your request involves information controlled by a Member, ClubfootResearch.ORG learner support will notify the appropriate Member of your request. Please note that if you choose to restrict ClubfootResearch.ORG’s or a Member’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the ClubfootResearch.ORG Site, you may not be able to establish an ClubfootResearch.ORG user account or enroll for a course, and ClubfootResearch.ORG or a Member may not be able to provide you with those services or products.

 

Delete account and Personal Information

 

To request deletion of your ClubfootResearch.ORG account and Personal Information, you should click the button labeled “Delete my account” in your ClubfootResearch.ORG account settings. Because deletion on the ClubfootResearch.ORG system is a permanent action and cannot be reversed, ClubfootResearch.ORG may ask you to complete a process that aims to confirm your authority to manage the ClubfootResearch.ORG account affected by your request.

 

With respect to your ClubfootResearch.ORG account, ClubfootResearch.ORG will permanently:

  • deactivate your ClubfootResearch.ORG account,

  • remove the active profile,

  • retire your username, and

  • remove you from ClubfootResearch.ORG email lists.

  • With respect to your Personal Information, ClubfootResearch.ORG will permanently delete your ClubfootResearch.ORG account profile Personal Information from the ClubfootResearch.ORG Site.

 

As noted above, to the extent that ClubfootResearch.ORG associates the information that ClubfootResearch.ORG collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your ClubfootResearch.ORG account profile. By erasing the Personal Information in your ClubfootResearch.ORG account profile, the remaining information about your activity on the ClubfootResearch.ORG Site will no longer be associated with you, except as noted below.

 

These changes will be applied to data stores that are used for operation of the ClubfootResearch.ORG Site including course administration by Members. If you enrolled in any courses on the ClubfootResearch.ORG Site, the ClubfootResearch.ORG learner support team will share your request with the Members that offered those courses.

 

Exceptions:

 

Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally "age-off" the ClubfootResearch.ORG system.

 

ClubfootResearch.ORG does not track or index every time or every place on the ClubfootResearch.ORG Site when or where a learner may volunteer Personal Information, so neither ClubfootResearch.ORG nor Members will be able to help you locate or manage all such instances. ClubfootResearch.ORG encourages you to use discretion before voluntarily sharing your Personal Information on the ClubfootResearch.ORG Site.

 

ClubfootResearch.ORG will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Members, and Personal Information may not be deleted from research data packages retained by Members.

 

ClubfootResearch.ORG and each applicable Member cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the ClubfootResearch.ORG Site must be retained for financial reporting, audit, and compliance reasons.

 

ClubfootResearch.ORG and each Member will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.

 

Data retention

 

ClubfootResearch.ORG will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with ClubfootResearch.ORG’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Member’s course, such Member will also retain your Personal Information for as long as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that ClubfootResearch.ORG deactivate your account and delete your information, ClubfootResearch.ORG will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Members, and each such Member may also keep and use course data for scientific research.

STORAGE & SECURITY

ClubfootResearch.ORG stores information, including Personal Information, on its own servers and also on servers of companies that ClubfootResearch.ORG hires to provide services. Each Member also stores information, including Personal Information, on its own servers and/or on servers of companies that the Member hires to provide services. In each case, information may be stored in the United States and in other countries where ClubfootResearch.ORG or a Member operates, and in countries where ClubfootResearch.ORG and each Member’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that ClubfootResearch.ORG and each Member may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

 

ClubfootResearch.ORG controls its own copy of information collected through the ClubfootResearch.ORG Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. ClubfootResearch.ORG uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, ClubfootResearch.ORG cannot guarantee its absolute security. While ClubfootResearch.ORG works hard to ensure the integrity and security of its network and systems, ClubfootResearch.ORG cannot guarantee that its security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining information.

 

If ClubfootResearch.ORG learns of a security breach involving its copy of your Personal Information, ClubfootResearch.ORG may attempt to notify you electronically so that you may take appropriate protective steps. By using the ClubfootResearch.ORG Site or providing Personal Information to ClubfootResearch.ORG, you agree that ClubfootResearch.ORG can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the ClubfootResearch.ORG Site. If a security systems breach occurs, ClubfootResearch.ORG may post a notice on the ClubfootResearch.ORG homepage (www.ClubfootResearch.ORG) or elsewhere on the ClubfootResearch.ORG Site and may send an email to you at the email address associated with your ClubfootResearch.ORG account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

 

If a Member learns of a security breach involving that Member’s copy of your Personal Information, the Member may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Member’s course on the ClubfootResearch.ORG Site or providing Personal Information to the Member, you agree that the Member can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Member may post a notice on the ClubfootResearch.ORG site and/or send an email to you at the email address associated with your enrollment in the Member’s course on the ClubfootResearch.ORG Site. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

 

Privacy Policy Updates

 

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as "Revised (date)," indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the ClubfootResearch.ORG Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

 

Contact Information

 

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that ClubfootResearch.ORG maintains about you, please contact us at info@clubfootresearch.org. You may also write to us at: ATTN: PRIVACY, Clubfoot Research Foundation Inc., Po Box 213 Frisco, TX 75034 USA. If your request involves a Member, ClubfootResearch.ORG will notify the appropriate Member of your request.

 

Glossary

 

Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the ClubfootResearch.ORG Site or in an email communication back to ClubfootResearch.ORG or the authorized third party that served the cookie. ClubfootResearch.ORG or third parties may also use Flash cookies.

 

ClubfootResearch.ORG Site consists of all content and pages located within the ClubfootResearch.ORG web domain and all ClubfootResearch.ORG mobile applications.

 

Member is each educational institution or other leading global institution or entity that provides courses through the ClubfootResearch.ORG Site or who sells products and other services to our members.

 

Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you. Verified Certificate is a virtual certificate that shows that you have successfully completed your ClubfootResearch.ORG course or program and verified your identity using your webcam and your acceptable form of photo ID.

Effective Date: 6 January 2021