Because Wings is a public institution, some information collected from the Site, including information from our server logs, e-mail delivered to our website, and information collected from Web-based forms, may be subject to the Ohio Public Records Act. This means that while we do not actively share information, in some cases we may be compelled by law to release information gathered from our Web servers.
Information We Collect About You and How We Collect It
- Information You Provide To Us
- Information We Collect Automatically
We and our third-party service providers (including any third-party content, advertising, and analytics providers) may use a variety of technologies that automatically or passively collect certain information about your use of the Site whenever you visit or interact with the Site. This information (“Usage Information”) may include:
- Information about your use of the Site, including your Internet Protocol (“IP”) address, web request, access times, pages viewed, web browser, media access control address (MAC address), links clicked and the page you visited before navigating to the Site;
- Information about the mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, mobile network information, browser type, and information about your use of our mobile applications; and
- Information collected by cookies and other tracking technologies: We and our service providers may use various technologies to collect information, including cookies and web beacons. This information is not linked to any Personal Information while on our Site. Cookies are small data files stored on your hard drive or in device memory that may help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. Web beacons are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. You can find more information about cookies and how they work at AllAboutCookies.org. A Flash cookie is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you onto your device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. Flash cookies are not managed by the same browser settings as are used for browser cookies. For more information about Flash and the privacy choices Adobe offers, visit the Adobe’s Flash Player Settings Manager page. Use the options in your Internet browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. If you disable all cookies or adjust your Flash privacy settings on your device, some features of the Site may not function properly, and you may not be able to take advantage of all the features of the Site.
We may use Usage Information for a variety of purposes, including enhancing or otherwise improving the Site and our services, and to target content or offers to users. The Usage Information we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.
- Information Third Parties Provide About You
Advertising and Analytics Services Provided by Others
For example, we may use Google services, such as Google Analytics, to collect data about traffic across our Site, to deliver advertisements when you visit other websites, and to share data about traffic to our website with Google and other Google Analytics program participants. For more information about how Google Analytics collects and processes data, visit How Google uses data when you use our partner’s sites or apps. To opt out of: (i) Google Analytics install the Google Analytics opt-out browser add-on and (ii) Google’s ad serving. You may also want to visit The Network Advertising Initiative for Consumer Opt Out (“NAI”) which provides information regarding targeted advertising and the “opt-out” procedures of NAI members, and the Digital Advertising Alliance Consumer Choice Page (“DAA”) which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program.
How We Use Your Information
We may use the information we collect about you or that you provide to us, including Personal Information and Usage Information:
- to enable you to use our Site, and to provide related services and care, including responding to your questions, complaints or comments;
- to process your donation and, as applicable, create your account or personal profile;
- to provide you with information, opportunities, or services that you have requested or that we otherwise believe will interest you, including opportunities to donate and other special opportunities from us and our third-party partners;
- to personalize your experience by tailoring content, recommendations, and opportunities we display to you, both on the Site and elsewhere online;
- for internal business purposes such as to improve our Site and services;
- to process information you provide via our Site, including verifying that your email address is active and valid;
- to provide and deliver the information, products and services you request, process transactions and send you related information, including confirmations and receipts;
- to process your registration;
- for billing purposes and to fill your orders—we use credit/debit card information solely to collect payment from you and we use a third-party service provider to manage that processing and to use that information for the sole purpose of processing credit/debit information;
- to otherwise support students, parents, legal guardians, and/or staff;
- to monitor and analyze trends, usage and activities in connection with our services;
- to comply with regulatory and legal obligations; and
Data Security and Payment Processing
We may allow donations or purchases (“Payment”) to be made via the Site. Payments may be made or paid by debit card or credit card. You may only use credit or debit cards that belong to you or to people who expressly authorize you to use such payment methods. We employ commercially reasonable security methods and technologies to help secure and protect Payment and Personal Information we collect and store from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Access to the information is restricted to personnel with a legitimate business need to access or modify the information contained therein. However, no system can be guaranteed 100% secure. Although we do our best to protect your Payment and Personal Information, we cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties.
If you authorize us to collect Payment you agree to pay all charges incurred by you or any users of your account and credit card (or other applicable payment mechanism) at the price(s) in effect when such charges are incurred, including any applicable taxes. We retain the absolute right to accept or refuse any Payment made in any form. We cannot guarantee that a particular product will always be available and, to the extent it is not after purchase, the payment will be refunded to you in a commercially-acceptable among of time.
To maximize security Wings does not hold any credit/debit card details. Wings uses PayPal and GoDaddy for payment processing. Since we use a vendor to process Payments made through the Site and to store associated payment data, Wings does not directly collect such Payment information, nor does Wings store or have access to credit card information submitted online. Payment information is stored within PayPal or GoDaddy. For further information on PayPal or GoDaddy please visit their website. Your credit or debit card company may conduct security checks to confirm it is you making the Payment.
Each employee who has any responsibility for the operation or maintenance of the Site, or the use of Personal Information maintained in the system, shall be provided a copy of this policy and shall be trained in how to comply with it.
Third Party Content / Links
From time to time, we may link content from third parties, which may include information to events that may include registration and/or payment links. By posting third-party content or allowing third parties to post content on the Site, we are not responsible for the linked or third-party accessible content or for any liability for any event. Wings has no control over information posted by any third party or of any event marketed on the Site.
- Third Parties Providing Services on Our Behalf
Companies may be engaged by Wings to perform a variety of functions, such as assisting with donation collection, providing technical services for our Site, etc. Such companies may have access to Personal Information if needed to perform certain functions pursuant to the contracts we have in place with those entities. However, these companies may use such Personal Information only for the purpose of performing that function and may not use it for any other purpose.
- Administrative and Legal Reasons
Wings reserves the right to use or disclose any information (including Personal Information) as needed to satisfy any law, regulation or legal request, to protect the integrity of the Site, to fulfill your requests, or to cooperate in any law enforcement investigation or an investigation on a public safety matter, to protect and defend the legal rights or property of Wings, our Site or its users, or any other party, or in an emergency, to protect the health and safety of our users or the general public. Wings also reserves the right to share registration and enrollment information that is collected to school districts or other third parties as may be required by state law, federal law, and/or school operating procedures.
- Social Networking Features
- Business Transfers & Transitions
In the event Wings goes through a transition (such as a merger, acquisition, bankruptcy or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process), your Personal Information will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
Family Educational Rights and Privacy Act (“FERPA”)
Your California Privacy Rights
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your Personal Information to outside parties for use as part of their own marketing without your consent. California Civil Code Section § 1798.83 also permits users of our Site that are California residents to request certain information. To make such a request, please contact us at the phone number or address listed below.
Children Under the Age of 18
Visitors under the age of 18 must obtain permission from their parents or guardians before sending any personal identifying information to any page within the Wings website.
Children Under the Age of 13
We take reasonable efforts to be in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”). Our Site is not intended to solicit information of any kind from children under the age of 13, and we do not and will not knowingly contact or collect Personal Information from children under 13.
The only Personal Information we may receive through this Site about children under the age of 13 is information provided by the parent or legal guardian or information provided by the child as part of that child’s participation in our education program with consent of their parent or legal guardian. For example, Wings may collect personal information from children under the age of 13 when Wings students under the age of 13 use their Wings account to communicate with us. Wings student accounts may allow for students to share work, send files from home to Wings, write to their teachers and turn in class work, among other uses. Wings requires all parents and legal guardians of students under the age of 13 to review and sign our Technology and Internet Acceptable Use Policy, otherwise such student will not receive or will be denied access to her Wings account. If a Wings student chooses to correspond with us through their account or email, we may store, process and/or use the personal information contained therein to communicate with the student and/or her parent or legal guardian, to address technical issues with the student’s account or access to the network, to update our records and perform other administrative functions. We may retain the content of the student’s messages together with their email address and our responses. We may provide the collected information to employees, agents or service providers acting on Wings’s behalf in connection with the activities described above, but we will only provide those employees, agents and service providers the personal information they need to perform their functions for us. By enrolling a child at Wings, a parent is consenting to the collection of that information.
If you are a parent or legal guardian and are concerned about the disclosure of personal information about your child that we may obtain via this Site, you may review your child’s personal information, ask to have it deleted and refuse to allow any further collection or use of the child’s information. You can contact us at the contact information listed below.
Our website, products and services are all directed to people who are at least 13 years old or older. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, once verified, we will promptly obtain parental or guardian consent, and in the absence of such consent, will delete the information.
Accessing and Correcting Your Information
If at any time, you would like to review, correct, erase, object to, and/or dispute the information we have about you or if you would like to change your preferences for contacts from us, you can let us know by contacting us at the address below. Wings will make good faith efforts to implement requested changes in our active databases subject to the applicable laws. Note, however, that we may continue to store information about you as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will endeavor to deal with all requests for access and modifications in a timely manner.
With your consent, we may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Links to Other Sites
We may offer links to sites that are not operated by Wings. If you visit one of these linked sites, you should review their privacy and other policies. We are not responsible for the policies and practices of others.
‘Do Not Track’ Notifications
Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit All About Do Not Track (DNT).
Use Within the United States
The Site is operated in the United States and is for United States users only. Users outside of the United States are prohibited from using the Site. As such, we are not responsible for any potential violations of privacy laws outside the jurisdiction of the United States.
How to Contact Us
Other Policies: Please also see our public records, security, social media and networking, use of electronic equipment, software and copyright, technology and internet use, and personal information systems policies.
[For addition when putting in policy manual: R.C. 1347; 20 U.S.C. 1232g; R.C. 3319.321; R.C. 3301.0716; 15 U.S.C. 6501–6505; Cal. Bus. & Prof. Code §§ 22575-22579 (2004); R.C. 149.43; 15 U.S.C. § 4]
Last date modified 4/2022