Privacy Policy

Center for Financial Capability Inc. DB Next Gen Personal Finance (“CFCI” or “we”) is a U.S. non-profit organization dedicated to free educational content. CFCI operates a website at www.creditoparausted.com. The purpose of this Privacy Policy is to inform you regarding:

  • what information we may collect from or about you, and how we collect such information;
  • how we use such information; and
  • what rights and choices you have regarding such information.

PLEASE READ OUR ENTIRE PRIVACY POLICY CAREFULLY BEFORE USING THE CFCI website. This Privacy Policy constitutes an integral part of the Terms of Use for the CFCI website (as defined in the Terms of Use). Capitalized terms not otherwise defined herein are as defined in the Terms of Use.

By using the CFCI website, you acknowledge that you have read and understand our Privacy Policy in its entirety, and accept our processing as described herein. If you do not agree to any of the terms contained in our Privacy Policy, please refrain from using the CFCI website or disclosing personal information on the CFCI website.

1.  CHILDREN’S PRIVACY

We recognize the need to provide additional privacy protection for children on the CFCI website. To register for CFCI, you must be a verified teacher or financial professional. CFCI verifies a teacher identity through several methods including visiting a school’s online teacher directory and/or contacting a teacher’s supervisor. 

If under 13 years of age, please get consent from your parent, guardian, or teacher. 

We do not collect any personal information on children under 13 years of age. Younger visitors should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

For information about how we protect the privacy of children in the European Economic Area (“EEA”), please see Section 9 (“Notices to Individuals in the European Economic Area”).

If you know anyone who is in violation of our age requirements, please email [email protected].

2.  CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify our Privacy Policy from time to time in our sole discretion. For example, we may amend our Privacy Policy in order to address new developments the law, or to conform to changing industry practices. If we make changes to our Privacy Policy, we will announce and post such changes on the CFCI website for the general public. If you are a Member, we may also notify you of the changes via email and may ask you to acknowledge or affirmatively consent to the changes at the time of your next account login on the CFCI website. By continuing to use the CFCI website after such notice and consent, you are bound by our Privacy Policy as modified.

3.  INFORMATION WE MAY COLLECT ABOUT YOU

Personal Information: This refers to information that can be used when Teachers set up an Account on our website. This includes first and last name, email address, school name, school city and state and account login information (i.e., username and password). It also includes information that may be uniquely linked to a User as a result of his/her visit to the CFCI website, such as server log file data and session information (which is explained in more detail below). You may need to provide your username and password) in order to access certain areas and features on the CFCI website.

Non-Personal Information: This refers to any information that does not identify a User personally. For example, we may gather demographic and/or other aggregate data about our Users as a group. Also, we may use online survey and feedback forms to gather opinions, comments, suggestions, etc. about the CFCI website on an anonymous basis from our Users; occasionally, we report quoted feedback from Users, but we do not attribute feedback to individual Users unless we have permission from a User to use his or her name along with the feedback. We collect and use non-personal information to administer and monitor the CFCI website, to analyze CFCI website traffic and usage patterns and trends, to improve the functionality of the CFCI website, and to enable us to personalize and better Users’ experience on the CFCI website. When we report information about the Site to our partners and investors, we report non-personal information only.

4.  HOW WE USE INFORMATION ABOUT YOU

We will use your information only for the purposes for which it was collected. Those purposes include:

  • Member Registration (website registration): Certain areas and features on the CFCI website are accessible only to registered Members, such as Assessments. To register as a Member, you will be asked to provide your first and last name, email address, school name, school city and state, and set up a Username and Password. If you register as a Member, we will use your personal information for all purposes related to your membership (pursuant to our agreement with you as a member) and your use of the CFCI website as a Member, including, without limitation: providing administrative, maintenance and support services to Member accounts and responding to Member inquiries, requests and complaints. Only individuals who are verified Teachers or Financial Professionals are able to set up Accounts on the CFCI website.
  • Electronic Mailing Lists: We will use your personal information to send you communications about the CFCI website, this Privacy Policy or our Terms of Use, notices of security incidents, and other important administrative announcements. We may also use your personal information to send you news, updates, announcements, newsletters, and other CFCI marketing communications via email. Certain of these communications will be pursuant to our legitimate interests to keep you informed, while other communications may be pursuant to your consent (if we are required by law to obtain your consent). You may opt out of our marketing mailing lists at any time. Once you opt out, we will not reuse your email address unless you rejoin our marketing lists or otherwise opt in to receive electronic communications from us. (See Section 6 below for further information on opt-out.)
  • Survey and Feedback Forms: We may use online survey and feedback forms to gather opinions, comments, suggestions, etc. about the CFCI website from our Users. Survey and feedback forms may be completed and submitted by Users anonymously without disclosing any personal information. However, should you choose to voluntarily disclose personal information to us, we will collect and use such information pursuant to our legitimate interests to understand your comments, communicate with you regarding your feedback, and make changes to our services accordingly. We may post your feedback on the CFCI website or in our marketing communications. If we want to include any identifiable personal information with your feedback, we will first obtain your permission.
  • CFCI Stories: You have the option to share your CFCI stories with us. When you share your personal information in online forums, that information will be posted publicly so that anyone who uses the online forum can see your information. When you submit a CFCI story, we may publish that story with your permission.
  • Log Files and Cookies: Our web servers may automatically generate log files that contain data linked to individual Users, such as IP address, browser type, operating system, ISP domain name, referring/exit page, date/time stamp, clickstream data, etc. Also, the CFCI website may use cookies to collect session information about individual Users’ visits to the CFCI website. (See Section 7 below for more information about cookies.) We use log file data and cookie session information internally and to further our interests in operating the CFCI website and generating/analyzing aggregate data about our Users as a group. When we report information about the CFCI website to our partners and investors, we only report aggregate data and do not knowingly report log file data or cookie session information that is linked to individual Users.

5.  WHEN WE SHARE INFORMATION ABOUT YOU

We do not knowingly share or sell your personal information with third parties for their direct marketing use. We will only share your personal information with third parties with your consent, at your direction, or in the following circumstances:

  • To contractors, service providers, and other third parties we use to support our business activities and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • When Required by Law: We may disclose your personal information to third parties if doing so is required by law or, in our good faith belief, is reasonably necessary to:
  • Comply with legal process;
  • Enforce this Privacy Policy and/or the Terms of Use;
  • Respond to claims that any User Postings violate the rights of third parties;
  • Respond to an emergency; or
  • Protect the rights, property or safety of CFCI, its Users, and/or the public.
  • Corporate Transaction: Lastly, if CFCI is acquired by or merged with or into another entity, or if all or substantially all of our assets are transferred to another entity, your personal information may be transferred to such entity as part of the transaction. If that entity has not committed to comply with this Privacy Policy, then we will give you the option to opt out of the transfer of your personal information to the successor entity.

6.  USER CHOICES AND OPT-OUT

We offer you choices and opportunities to opt out of certain uses of your personal information. In addition, you have certain rights with regard to the personal information we collect about you.

  • Membership Cancellation. You may at any time request to cancel and have your membership account removed from the CFCI website, provided that your request to cancel is in writing and sent to CFCI via email [email protected].
  • Electronic Mailings. You may at any time opt out of receiving marketing electronic mailings from CFCI by using the “opt out” or “unsubscribe” means provided in the electronic mailings you received. You may also email us at [email protected]. Notwithstanding the foregoing, by registering as a Member or otherwise providing us with your email address, you expressly agree that CFCI may still send you important administrative messages, such as security breach notices required by law or notices regarding material changes in our Privacy Policy or Terms of Use, to you via email, and you specifically consent to continuing to receive such notices via email from CFCI even after your opt-out, unless you choose to cancel your membership.
  • Access and Modification of Your Personal Information. As a Member, you may log into your account at any time to modify, update and correct your account information. However, you understand and acknowledge that certain personal information (e.g., your name and email address) cannot be deleted without CFCI having to cancel your membership account. You may email us [email protected] or use the contact information in Section 12 below if you have any questions about modifying, updating or correcting your personal information. If you are located in the EEA, you may have additional rights. Please see Section 9 (“Notices to Individuals in the European Economic Area”) for an explanation of these additional rights.

7.  COOKIES

Cookies are small data files that websites and online services send to and store on your computer or mobile device through your web browser. Cookies enable websites and online services to recognize your browser and record certain information about your visits. While the cookies we use may change from time to time as we improve and update the CFCI website, they generally fall into the below categories of use:

  • Authentication: We use cookies to verify your account and determine when you’re logged in so we can make it easier for you to access the CFCI website and show you the appropriate content and features. For example, we use cookies to keep you logged in as you navigate between our webpages. Cookies also help us remember your browser so you do not have to keep logging into CFCI.
  • Features and Services: We use cookies to enable the functionality that helps us provide the CFCI website. For example, cookies help us store preferences, know when you’ve seen or interacted with CFCI website’s content, and provide you with customized content and experiences. Cookies allow us to make suggestions to you and others, and to customize content on third-party sites that integrate our social plugins.
  • Performance: We use cookies to provide you with the best experience possible. For example, cookies help us route traffic between servers and understand how quickly the CFCI website loads for different people. Cookies also help us record the ratio and dimensions of your screen and windows and know whether you’ve enabled high contrast mode, so that we can render our website and apps correctly.
  • Analytics and Research: We use cookies to better understand how people use the CFCI website so that we can improve them. For example, we use Google Analytics to collect and analyze information about our users’ demographics and interests in order to measure and improve the CFCI website. For more information about Google Analytics, please visit https://support.google.com/analytics.

Most web browsers are initially set to accept cookies, but you can change your browser settings to notify you when you are sent a cookie, giving you the ability to accept or reject it, or you can choose to routinely and manually delete cookies stored on your computer or mobile device. Each time you revisit the CFCI website, your ability to restrict our use of cookies on that service is subject to your browser settings and limitations at the time. Please note that if you choose to disable or reject cookies from us, the CFCI website or portions thereof may become inaccessible or may not function properly. For more information on how to manage cookies, visit http://www.aboutcookies.org/. To manage Adobe Local Shared Objects (also known as LSOs or Flash cookies), please visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_mana ger07.html.

We may also use web beacons (also known as clear GIFs or pixel tags) – which are small bits of code embedded in web pages or in emails – to deliver or communicate with cookies, to count users who have visited a web page, and to understand usage patterns. We may include web beacons in emails to help us recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.

8.  LINKS TO THIRD PARTY WEBSITES

The CFCI website may contain links to certain third-party websites. CFCI does not own, control or operate such linked sites, and is not responsible for the privacy policies or practices of such linked sites. Privacy policies and practices for such linked sites may differ from our Privacy Policy and practices. You access and use such linked sites entirely and solely at your own risk. We urge you to read the privacy policies of such linked sites before disclosing your personal information on such sites.

9.  NOTICES TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA

EEA Children’s Privacy: We take appropriate steps to obtain parental or guardian consent prior to collecting personal information from children under 13 or 16 years old (depending on where you are located in the EEA). Younger visitors should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

Member Registration (website registration): Only Verified teachers and Finance Professionals are able to register on the CFCI website. Children are not able to register for the CFCI website.

Marketing Communications: We will obtain your consent to receive marketing communications prior to sending you such communications. You can opt-out at any time by using the “opt out” or “unsubscribe” means provided in the marketing mailings you received. You may also email us at [email protected].

Individual Rights related to Personal Information: You may email [email protected] or use the contact information in Section 12 below to request that we:

  • Delete your Personal Information: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide the CFCI website to you).
  • Change or Correct your Personal Information: You can also ask us to change, update or fix your personal information in certain cases, particularly if it’s inaccurate. As a Member, you may log into your account at any time to modify, update and correct your account information.
  • Object to, or Limit or Restrict, Use of your Personal Information: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal information is inaccurate or unlawfully held). You also have the right to withdrawal your consent at any time.
  • Right to Access and/or Take Your Personal Information: You can ask us for a copy of your personal information and can ask for a copy of personal information to be provided in machine readable form.

10.  DATA TRANSFERS TO THE UNITED STATES

The CFCI website is operated from and hosted on servers in the United States. If you are outside of the United States and access the CFCI website or submit your personal information to us, please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. If you visit our Services or contact us from outside of the United States, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

11.  SECURITY AND DATA RETENTION

We understand the importance of protecting the security and integrity of personal information that our Users have shared with us. We maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. For example, we encrypt the transmission of your information using secure socket layer (SSL) or similar technologies. We also have in place internal policies and procedures that govern our use and disclosure of your personal information. 

Despite the steps we take to protect your personal information, we do not warrant or guarantee the security of any information you transmit to, from or on the CFCI website. Therefore, we urge you to keep your account login information in a safe place and not to divulge it to anyone. Also, remember to sign off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or an Internet cafe.

We will maintain your personal information for as long as you have an account or as necessary to deliver the CFCI website to you or to your school. We may anonymize your personal information after you have deactivated or deleted your account so that we can use this anonymized information for our internal business purposes. 

12.  CONTACT US

If you have any questions regarding our Privacy Policy, please contact us at: CFCI dba Next Gen Personal Finance

Email: [email protected]

CFCI is the data controller with respect to the personal information collected through the CFCI website. If you are located in the EU and you are unhappy with our resolution of your privacy-related inquiry or request, you have the right to lodge a complaint with your Supervisory Authority.