First Responder Benefit Association and its affiliates are committed to protecting the personal information of our customers, clients, first responders and their families, current and potential business partners, employees, and the public.  We comply with all applicable data privacy laws including the California Consumer Privacy Act (“CCPA”). This Privacy Policy was last updated on December 1, 2020.

Our commitment to your privacy

This Privacy Policy describes: 

• The information we collectabout you and how we collect it;

• How we use and share this information;

• How you can access and update this information;

• The choices you can make about how we collect,use and share your information; and

• Your privacy rights.

If you have any questions regarding this Privacy Policy or our information collection and use practices, please contact us using the information in the “Contact Us” section below.

Information we collect

We collect the following personal information about you:

• Personal information and identifiers, such as name, address, contact information, social security number, date of birth.

• Demographics, such asage, disability status, citizenship, gender.
• Professional or employment information, such asincome and employment history.
• Agency information, such as rank/title and agency name and contact information.

• Education information, such as school records, degree, academic achievements.
• Financial information, such asbank accounts, investment or brokerage accounts, assets/debts, donation information, account balances and credit information..
• Medical information, such as medical history and health information.
• Assistance needs, such as financial or other needs for families of fallen first responders.
• Internet or network activity, such asbrowser history, search history, IP address

• Profile information, such asprofiles reflecting a person's preferences such as interests, hobbies, characteristic tendencies, behaviors, or attitudes

• Product information, such as policy/account number and policy/account values
• Employment-related information for our job applicants and employees, such asqualifications, experience, education, work history, and reference check information, pay and benefits information, tax information, performance information, equality and diversity information, health and safety information, and legal information.

How we collect your information

We collect information that you provide to us when you purchase our products and services or communicate with us. We also collect information about you from our trusted service providers, government authorities, agencies, references and other public information sources.

We also collect information about you on our website and online platforms through the use of cookies and other technologies. Cookies are small text files that are stored by the browser (for example, Internet Explorer or Google Chrome) on your computer or mobile phone. They allow websites to store things like user preference. You can think of cookies as providing a “memory” for the website, so that it can recognize you when you come back and respond appropriately. Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes.

What cookies do we use and why?

The cookies used on our site are categorized as follows:

• Strictly necessary
• Performance
• Functionality
• Targeting

Strictly Necessary

“Strictly Necessary” cookies let you move around the site and use essential features like secure areas and donation processing functions. Without these cookies, information or services you have asked for cannot be provided. Please note that these cookies do not gather any information about you that could be used for marketing or remembering where you've been on the internet.

We use these Strictly Necessary cookies to:

• Remember information you have entered on forms when you navigate to different pages during a web browser session;
• Identify you as being logged in to our site;

• Make sure you connect to the right service on our website when we make any changes to the way the site works;
• To route users to specific applications of a service or specific server.

Accepting these cookies is a condition of using the website, so if you prevent these cookies, you may not be able to use the site or its functionality, nor can we be certain that our site security controls will function properly or fully during your visit.

Performance

“Performance” cookies collect information about how you use our site (e.g., which pages you visit, and if you experience any errors). These cookies do not collect any information that could identify you directly and are used only to help us improve how our site works, understand what interests our users, and measure the effectiveness of our advertising.

We use Performance cookies for:

• Web Analytics: To provide statistics on how our sites are used;
• Ad Response Rates: To see how effective our advertisements are, including those pointing to our sites;
• Error Management: To help us improve the site by measuring any errors that occur;
• Testing Designs: To test distinctive designs of our sites;

• Content Management: To help optimize the delivery of certain media, such as video.

Some of our Performance cookies are managed for us by third parties. Where this is the case, we don't permit the third party to use the cookies for any purpose other than those listed above.

By using our site, you accept the use of “Performance” cookies. Accepting these cookies is a condition of using the site, so if you prevent them we cannot guarantee how the site will perform for you.

Functionality

“Functionality” cookies are used to provide services or to remember settings to improve your visit.

We use Functionality cookies to:

• Remember settings you've applied, such as layout, text size, preferences, and colors;
• Remember if we've already asked you if you want to fill in a survey;
• Remember volume settings when playing video.

Some of these cookies are managed for us by third parties. Where this is the case, we don't permit the third party to use the cookies for any purpose other than those listed above.

How a user can opt out of having cookies placed on their device(s)?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our site. Blocking or deleting cookies will not prevent device identification and related data collection from occurring. Blocking the browser's cookies will prevent cookies from measuring the relevance and effectiveness of our site/emails and advertising as well as the tailored advertising brought to you by our partners. You also may not be able to use all the interactive features of our site/emails if cookies are disabled.

Can I withdraw my consent?

Once you have given us your consent to the use of cookies, we shall store a cookie on your computer or device to remember this for next time. This will expire periodically. If you wish to withdraw your consent at any time, you will need to delete, then block, your cookies using your internet browser settings.

For further information about deleting or blocking cookies, please visit: https://cookiepedia.co.uk/how-to-manage-cookies or https://www.aboutcookies.org/how-to-delete-cookies/.

How we use information

We use information collected about you:

• To Provide our Products and Services. We use the information that we collect to (i) provide you with and enhance our products and services and (ii) operate, maintain, enhance and provide our website and other online platforms, and (iii) to manage our relationship with you.

• To Provide Financial and Other Assistance to Families of Fallen First Responders. We use the information we collect from you regarding donations or requests for assistance to the First Responder Benefit Association.

• To Improve, Analyze, and Personalize our Website and Products and Services. We use the information that we collect to understand and analyze usage trends and preferences; to monitor and analyze the effectiveness of our website and products and services; to improve our website and products and services and develop new products, services, features, and functionality; and to personalize our website and products and services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our website, or providing customized content and information.

• To Contact You. We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including marketing or promotional communications, relating to our products and services.  

• For Employment-Related Purposes. We use employment-related information to hire our employees and manage our employment relationships.   

How we share information

We do not sell your personal information. However, we may share, transfer, or disclose your information if you consent to us doing so, as well as in the following circumstances:

• To Trusted Service Providers. We work with third party service providers to provide our products,service, and assistanceto you. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. These service providers are not permitted to use information we share that might identify you for any purpose other than to provide services to us or to you.

• In Aggregate Form. We may make certain aggregated non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests and usage patterns.

• Compliance with Laws and Law Enforcement; Protection of Our Rights. We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of our website or data bases, (d) to protect the property, rights, and safety of First Responder Benefit Association and our affiliates from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations

• In Significant Business Transactions. Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Additional Privacy Notice and Rights for California Residents

We comply with the California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA), and other applicable California laws. In addition to the privacy protections and rights described in our Privacy Policy, California residents have the following rights:

• You have the right to know about the personal information we collected and disclosed about you and your household during the prior 12 months including:

• The specific pieces of personal information we have collected about you and your household, and 

• The categories of personal information we have collected about you, and your household including the categories of sources from which your personal information was collected, business or commercial purposes for which your personal information was collected, the categories of third parties to whom we disclosed yourpersonal information, and the business or commercial purpose for disclosing your personal information to a third party.

• You have the right to request us to delete the personal information that we have collected or maintained about you and your household. We will delete your personal information by permanently erasing the information on our existing systems, de-identifying the personal information, or aggregating the personal information. If your personal information is stored on or archived or back-up systems, we will delete the personal information when our archived or back-up system is next accessed or used. We will also direct the third parties to whom we have provided your personal information to delete your personal information. 

You can request access to or deletion of your personal information or the personal information of your household by submitting a request to us byemailing usatinfo@frba.org; or asking for and completing a written request form at one of our physical locations. To protect the security of your personal information, we will require you to provide us with identifying information for you or your household such as email address, telephone number, a description of the product or service you purchased or inquired about, and/orother information that we can match with the personal information we have collected about you or your household to verify your identities.

You may use an authorized agent to request access to or deletion of your personal information or the personal information of your household. We will require your authorized agent to provide us with either (1) a power of attorney authorizing the authorized agent to act on your behalf or (2) your written authorization permitting the authorized agent to request access to your personal information on behalf of you or your household. Further, we will require you or your authorized agent to provide us with identifying information to verify your identity and/or the identities or your household members.

Within 10 days of receiving your request to know, we will confirm receipt of your request and provide information about how we will process your request. Generally, we will respond to your request within 45 days. If we need more time to respond, we will provide you with notice and an explanation of the reason we need more time to respond.  We may deny your request if we cannot verify your identity or are legally permitted to deny your request. If we deny your request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than permitted by the denial.Wewill maintain a record of your request and our response for 24 months.

You have the right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.

Individual California residents also have the right under the California Online Privacy Protection Act (CalOPPA) to request information about our disclosures of certain categories of personal information to our affiliates or third parties for their direct marketing purposes. We will provide a list of the categories of personal information disclosed to third parties or our affiliates for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties or affiliates. This request may be made no more than once per calendar year. Individual California Users must submit their requests to us either by email at: info@frba.orgor write us at the mailing address in the Contact Us section below. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

If you have questions or concerns regarding our privacy practices or your privacy rights as a California resident, please contact us as described in the Contact Us section below.

This Additional Privacy Notice and for California Residents section was last updated on December 1, 2020.

Privacy Rights for Nevada Residents

You have the right to direct us not to sell certain personally identifiable information that we collect about you on our Websites or other online services by emailing us at info@frba.org. This information includes: your first name or first initial and last name in combination with your social security number; driver’s license number, driver authorization card number or identification card number; account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to your financial account; medical identification number or a health insurance identification number; user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.

Additionally, you may review and request that we change the personally identifiable information that we collect about you on our websites or other online services by emailing us at info@frba.org.

Our service providers and other third parties may collect personally identifiable information about your online activities over time and across different internet websites or online services when you use our Websites or online services.

Our policy concerning children

Our products and services are not directed to persons under 18, and we do not knowingly collect any personal information from persons under 18. If we become aware that a persons under 18 has provided us with personal information, we will take steps to delete such information.

Privacy policies of linked sites and advertisers

Our website may contain links to other sites, as well as advertisements from companies linking to their own sites. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your information, you should contact them directly.

To obtain information about opting-out of targeted advertising, you may contact one of the following industry groups:

• Digital Advertising Alliance (“DAA”): http://www.aboutads.info/choices/

• Network Advertising Institute (“NAI”): http://www.networkadvertising.org/choices/
• European Interactive Digital Advertising Alliance (“EDAA”): http://www.youronlinechoices.eu/ and http://www.edaa.eu/

Please note that when using the ad industry opt-out tools above, such opting-out only applies to members of that specific industry group and only those members will no longer deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our sites or other websites. You may continue to receive advertisements, for example, based on the website that you are viewing. Also, if your browsers are configured to block cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective.

We do not respond to “do not track” browser signals at this time.

Security

We haveimplemented reasonable security measures to maintain the security, confidentiality and integrity of the information collected, and to help protect against the loss, misuse and alteration of such information.  While we take measures to protect your personal information against security breaches and unauthorized access, no security system can be effective all of the time against all security threats.

Changes to our privacy policy

This Privacy Policy may be revised from time to time. If we decide to make material changes to our Privacy Policy, we will place an update notice on our website.

Contact us

If you have any questions, comments or concerns regarding our Privacy Policy or our privacy practices, please send an email to:  info@frba.org or write to us at:

General Counsel

FRBA

221 Pelham Road, Suite #200

Greenville, SC 29615