PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE FBINAA CA CHAPTER APP, WEBSITE, AND/OR SERVICES, INCLUDING ATTENDING ONE OF OUR CONFERENCES AND BY USING YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.

FBI National Academy Associates, Inc. California Chapter (“FBINAA”) has created this privacy policy as part of its commitment to helping users better understand how FBINAA collects and may use your content and information on its Application, Website and Services. FBINAA encourages you to read this privacy policy, and to use it to make informed decisions.

Your (further referred to herein as “you” or “User”) use of the FBINAA Application, Website, and Services (as each of these terms are defined in this Privacy Policy), including any dispute concerning privacy, is subject to this privacy statement (“Privacy Policy”) and FBI National Academy Associates Terms of Service (located at http://www.fbinaa.org/terms-of-service). By using the FBINAA Application, Website, and Services, you are accepting the guidelines and practices set out in this Privacy Policy and in FBINAA’s Terms of Service.

A. Word from FBINAA
The FBINAA is committed to providing superior service to all of our members and visitors, particularly with respect to their privacy concerns. We understand that you may have questions about how the FBINAA Applications, Website, and the Services collect and use your information; we have prepared this statement to inform you of the governing privacy principles.

This Privacy Policy contains numerous general and technical details describing the steps we take to respect your privacy. We have organized this Privacy Policy by major topic areas so that you can quickly refer to the information that is of most interest to you. Meeting your needs and expectations forms the foundation of everything that we do, including protecting your privacy.

To the extent that anything in this Privacy Policy conflicts with an existing written (including electronic) agreement between you and FBINAA regarding the use of the Applications, the Website, or Services, including specific licenses, terms of use, or privacy disclosures relating to Services (collectively, “Product Agreements”), the terms of the Product Agreements shall govern.

If you have questions regarding this Privacy Policy, or concerns relating to compliance with the policies outlined in this Privacy Policy, please contact a Chapter Board Member.

Changes in the Privacy Policy
FBINAA reserves the right to modify this Privacy Policy at any time by posting such changes on this page without prior notice. Your continued use of any portion of the FBINAA Applications, Website, or Services subsequent to the posting of an updated Privacy Policy will constitute your acceptance of all such changes.

If as the result of any such changes, you wish to alter the ways in which FBINAA is allowed to use your personal information, you may do so by following the steps described in the Choices Available to You section of this Privacy Policy.

Legal Issues
FBINAA may disclose your personally identifiable information without your permission if it has a good-faith belief that disclosure is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable government request; or to investigate or protect against harmful activities to FBINAA’s guests, users, associates, or property (including the Applications and Website), or to others. We may also disclose personally identifiable information when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating this Privacy Policy, the terms of their agreements with the FBINAA (such as the Terms of Service), or to protect the safety of our users and the public. We may also disclose personally identifiable information under confidentiality and licensing agreements with certain third parties who assist us in developing, operating and maintaining the Applications, Website, and Services, including the content therein.

FBINAA may also be required by law enforcement or judicial authorities to provide personally identifiable information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, FBINAA will provide this information upon receipt of appropriate documentation. FBINAA may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.

B. Information We Collect
Information We Collect Through Applications and Information Made Available by Client
The FBINAA Applications may be used by users with User Accounts (“Registered Users”) as well as users without User Accounts (“Unregistered Users”). However, FBINAA Applications’ functionality may be significantly limited or unavailable for Unregistered Users. The Clowder Application will only be available to Registered Users who have provided or made available all of the required Membership Data to the FBINAA.

The Applications collect information from both Registered Users and Unregistered Users. This information includes information that Registered Users and Unregistered Users voluntarily provide to FBINAA, including usernames, passwords, user profile information (the Registered User’s name, picture, phone number), User Content (as defined in this Privacy Policy), as well as communications between Registered Users and FBINAA (for instance, as e-mails sent from users to FBINAA). If a user logs into the FBINAA Application (other than Clowder Application) using an authorized third party social network account, such as a Facebook or Instagram account, FBINAA may collect certain information as to that user’s activities and information in that third party social network. Additionally, the FBINAA Application may collect certain technical information automatically from both Registered and Unregistered Users, including the model, manufacturer and OS version of the mobile device used, MAC (Media Access Control) address, device identifiers, International Mobile Equipment Identity (IMEI), and time-stamped logs of messages sent and received, and network status (WiFi, etc.).

As a Registered User, you may also be permitted to provide your exact location if you choose to enable your mobile device to send us and other Registered Users such information. We may use and store this information to provide certain Services, such as tagging the uploaded User Content with your location and may otherwise use this information to improve your experience with the Services and to provide you with additional functionality.

The Membership Data and/or personally identifiable information described above, may also be provided or made available by FBINAA to Pinxter, which then, in turn is being populated into the accounts of the Registered Users for purposes of creating, operating, and updating the Applications.

Information We Collect Through the Website
The Website does not collect personally identifiable information from your computer when you browse the Website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with your personally identifiable information (such as by sending an e-mail to FBINAA), FBINAA will not know your name, your e-mail address, or any other personally identifiable information when you browse the Website.

When you request a page from the Website, our servers log the information provided in the HTTP request header, JavaScript or similar technical tools, including the IP address, the time of the request, the URL of your request, and other information. We collect this information in order to make the Website function correctly and provide you the Website’s functionality. We also use this information to better understand how visitors use the Website and how we can better adjust the Website, its contents, and functionality to meet the needs of our users. However, this information is not associated with any personally identifiable information of the person browsing the Website.

When you use the Website, FBINAA or trusted third parties authorized by FBINAA may also collect certain technical and routing information about your computer (also known as environmental variables) to facilitate your use of the Website and the Services enabled thereby. When you browse the Internet, your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to FBINAA every time you access content on one of our internet domains. Examples of such information include the URL of the particular Web page you visited, the IP (Internet Protocol) address of the computer you are using, or the browser version that you are using to access the Website. All of this information may be collected by FBINAA and used to help improve our offerings to you.

All information submitted to FBINAA while not logged into secured regions of this Website including electronic mail inquiries, is submitted through the Internet, which is an unsecured, public network. Your confidential use of the Website cannot be guaranteed and you acknowledge that your use of the Website (including information you transmit to the Website) may be subject to access by, or disclosure to, other persons. Without limiting any other disclaimer herein, FBINAA shall not be responsible or liable for any harm that you or any other person may suffer in connection with any such breach of confidentiality or security.

User Content
The Applications and Services allow Registered Users to upload content to share with other users (“User Content”). Because the Applications are social networking, entertainment, and/or membership engagement tools, some of the information you provide to us when uploading User Content may be made public. This includes information provided along with User Content, such as the date and time that the User Content was posted, as well as User Content that you like and dislike or comment on, or other public interactions in the Services. Furthermore, other Registered Users may “follow” your User Account and thereby access all information you have made public.

Providing Information to FBINAA
You never have to provide personally identifiable information to FBINAA. However, should you choose to withhold certain required information, FBINAA may not be able to provide you with some or all of the Services. For instance, a User Account is necessary to enjoy all of the FBINAA Application’s features. Some of the information we ask you to provide may be identified as mandatory or optional. If you do not provide the mandatory information with respect to a particular activity, you may not be able to engage in that activity or make such a purchase. FBINAA will inform you of the mandatory or optional nature of the requested or required information.

When you submit personal information to FBINAA through the Applications or Website, you understand and agree that this information may be transferred across international boundaries and may be stored and processed in any of the countries in which FBINAA and its affiliates and subsidiaries maintain offices or web hosting servers. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of FBINAA. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties.

FBINAA may establish relationships with various partners whose services may become available to you via the Applications, Website or third party websites to the Website or through the Applications (“Providers”). Typically, these Providers will offer services that FBINAA users may find useful, such as those that can be used in conjunction with the Applications, Website, or Services. In order to use these third party services, you may be required to provide personal information to such partners. Unless expressly provided to the contrary, personal information that you provide while you are visiting a partner’s website will be subject to the privacy policy posted on that partner’s website, and personal information that you provide while on the Website in conjunction with a Provider’s service will be subject to this Privacy Policy. For instance, credit card or PayPal® information entered as part of the filling out a purchase form or registration process collected by a third party’s registration and/or merchant services is subject to that third party’s privacy policies. You should be aware that FBINAA’s agreements with these service providers often provide that they will share personal information collected from you, with FBINAA. In such instances, FBINAA may use this information in a manner consistent with this Privacy Policy.

You may be provided an opportunity to subscribe to periodic newsletters and product updates provided by FBINAA’s advertisers and trusted partners. These newsletters and product updates are marketing tools that allow FBINAA’s advertisers to inform you of new services, products, and updates, as well as other news which may be relevant to you. Subscription to such newsletters may require you to provide your first and last name, your email address, and other information. You will be given the opportunity to choose the type of information such advertisers will provide to you and you will be provided with an opportunity to opt-out from receiving such information by either making appropriate choice in your User Account or by writing to info@fbinaa.org.

Third Party Applications
FBINAA may make third party applications or services available to you through the Applications, Website, or Services. The information collected by FBINAA when you enable a third party application or services is processed under this Privacy Policy. Information collected by the third party application or service provider is governed by the provider’s privacy policies.

Information Relating to Children
The Children’s Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children’s privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Website at http://www.ftc.gov/ . The FBINAA Applications, Website, and Services are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, we recognize that children under the age of 13 may access the FBINAA Application, Website, and Services. The collection of information from such users is covered above. Parents and legal Guardians may request us to review, delete, or stop the collection of the personally identifiable information of their child. You may do so by contacting us by letter (using the address information provided at the bottom of this page) or e-mail, at info@fbinaa.org.

Cookies and Web Beacons
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:

• measure usage of various pages on our Website to help us make our information; more pertinent to your needs and easy for you to access;
• identify and categorized the internet webpages from which the visitor came to the Website and observe the browsing patterns; and
• provide functionality such as online orders, FBINAA services and other functionality that we believe would be of interest and value to you.

The types of cookies that we use are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted once you leave the Website. Persistent cookies remain on your computer hard drive until you delete them. We do not use cookies to gather information concerning your visits to other websites, nor ascertain any personally identifiable information about you, apart from what you voluntarily provide us in your dealings with FBINAA. Cookies do not, under ordinary circumstances, corrupt or damage your computer, programs, or computer files.

In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. There are no cookies in the advertisements or e-mails. A cookie is placed on your computer only if and when you click on an advertisement or open the e-mail. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.

You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website. Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. As opposed to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of a web beacons allows the site to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited at a website. FBINAA uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website, and to facilitate those visitors’ interactions with the Website. FBINAA may make the aggregate data obtained from web analytics (including from our third party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.

C. Purpose for Processing/Use of Information
How Your Personal Information Is Processed/Used
FBINAA collects information from you in order to record and support your participation in the activities provided by FBINAA. FBINAA recognizes and appreciates the importance of responsible use of information collected through the Applications, Website, and Services. FBINAA will not communicate any information to you regarding products, services, or special offers available from FBINAA or its affiliates without your consent, although we may find it necessary to communicate with you regarding your use of the Applications or Services. Except in the particular circumstances described in this Privacy Policy, FBINAA will also not provide your name to other companies or organizations without your consent.

• We may use your e-mail address to send a confirmation e-mail when you sign up for a User Account and, if necessary, may use other information you provide to contact you for help to process the purchase or service you have selected. Your personal information also may be used to keep you informed about new services, service upgrades, special offers, and other Services.
• FBINAA may collect information about your use of the Applications, Website, and Service (such as the types of services used and how many users we receive daily.) This information is collected in aggregate form, without identifying any user individually. FBINAA may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

Disclosure of Information to Third Parties
In operating the FBINAA Applications, Website, and Services, FBINAA may engage third parties, such as e-mail service providers, purchase shipping and order processing merchants, and marketing companies that act as independent contractors on behalf of FBINAA. These parties are contractually prohibited from using your personally identifiable information for any purpose other than for the purpose FBINAA specifies.

• We provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of personal information to entities outside of the FBINAA affiliates for their use without your approval.
• We provide non-personally identifiable information on an aggregated basis to our trusted third party partners to enable our partners to provide you with information about services, special offers, and promotions of interest to you.

Disclosure of Information to Other Users
Through the use of the FBINAA Applications, Website, and Services, you may have the option to disclose personally identifiable information about yourself to other users. Certain personally identifiable information you disclose may be available to all users, such as information in your publicly-accessible account profile (“Public Information”). Other personally identifiable information may be intended only for particular users (“Private Information”), such as a private correspondence to such users. Any disclosure of Public Information or Private Information is undertaken willingly by you and you agree that FBINAA is not responsible for the contents or consequences of any such disclosure. FBINAA encourages you to exercise extreme caution when disclosing any information about yourself to other users, especially Private Information. Although FBINAA will not disclose your Private Information, you agree that FBINAA is not responsible for any consequence whatsoever of your willing disclosure of Private Information or Public Information to other users.

The Applications and Services may also allow you to communicate with other users. The rules and guidelines governing such communications are set out in the Terms of Service accompanying this Privacy Policy (www.fbinaa.org). You expressly agree that FBINAA is not responsible for contents or consequences of any such communication or any information you choose to disclose through any such communication. You also acknowledge that FBINAA may access and review any such communications. Please exercise due caution when engaging in any such communication.

Due to the regulatory environment in which FBINAA operates, FBINAA cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting any of the foregoing), FBINAA may be required to disclose information to the government, law enforcement agencies or third parties to prevent fraud and protect the safety of FBINAA users. Under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or members may abuse or misuse your information that they collect from the FBINAA Application or Website. Although FBINAA uses industry standard practices to protect your privacy, FBINAA does not promise, and you should not expect, that your personally identifiable information or private communications will always remain private.

Securing the Transmission and Storage of Information
FBINAA is committed to protecting the security of your personally identifiable information. We use a variety of security technologies and procedures to help protect your personal information. FBINAA operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our users. FBINAA takes steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no data transmission over the Internet can be guaranteed secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us or from our online products or services, and you use these services at your own risk.

We treat the information you provide to us as confidential information; accordingly, it is subject to our company’s security procedures and corporate policies regarding protection and use of confidential information. After personally identifiable information reaches FBINAA, it is stored on a server with physical and electronic security features as are customary in the industry, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access from outside of FBINAA. Because laws applicable to personal information vary by country, our offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this Privacy Policy is processed and stored in the United States. All FBINAA employees are obligated by our privacy and security policies. Your information is only accessible to those employees who perform technical support of the service.

A password is used to help protect your accounts and personal information. It is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving any site or service to protect access to your information from subsequent users.

Effect of Change in Control
In the event that all or substantially all of FBINAA’s assets are transferred or sold to another entity, FBINAA may transfer personally identifiable information to the acquiring entity. If, as a result of such business transition, your personally identifiable information will be used in a materially different manner than as described herein, you will be given a choice consistent with our policy regarding notification of changes.

D. Choices Available to You
Opt-In and Disclosure
You may always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website and having limited access to the Applications and Services. Please note, however, if you should choose to withhold certain requested information, we may not be able to provide you with some or all of the Services dependent upon the collection of this information. You will be given an opportunity to “opt-in” and make your preference choices for any items that are optional and which are not prerequisite for our rendering such services.

Opt-Out Options
You can choose at any time to opt-out of receiving emails from FBINAA by clicking the unsubscribe link at the bottom of any email you receive from FBINAA or by contacting FBINAA directly info@fbinaa.org . If you elect to opt-out, we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.

California Residents
If you are a California resident, you can request a notice disclosing the categories of personal information that we may share with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to info@fbinaa.org. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

Retention Policy
We only retain the personally identifiable information about you for as long as your User Account remains active and in accordance with applicable law related to record retention requirements. We will retain and use information as necessary to comply with our legal obligations, archival purposes, resolve disputes, and enforce our agreements.

E. Privacy Related Inquiries and Complaints
FBINAA takes and addresses its users’ privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your personal information or you have other related inquiries or concerns, you may write or contact FBINAA at info@fbinaa.org.

In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly.

Please note that if you provide FBINAA with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), FBINAA cannot guarantee that your most recent privacy preference will be honored.

The FBI National Academy Associates, Inc. is a private 501 (c)(3) nonprofit organization and is not a part of the Federal Bureau of Investigation or acting on behalf of the FBI.

Disputes
By using the Application, Website or Services, you agree that any disputes arising out of or relating to the Application, Website, or Services or products made available regarding information collected or shared about you, is subject to the applicable provisions in the Terms of Service.

The FBI National Academy Associates, Inc. is a private 501 (c)(3) nonprofit organization and is not a part of the Federal Bureau of Investigation or acting on behalf of the FBI.