Franklin County Digital Equity Coalition’s Privacy Notice

Effective Date: 10.04.2021  //  Last Revised: 10.04.2021

I. Introduction

The Franklin County Digital Equity Coalition (collectively, “the Coalition,” “we,” “our,” or “us”) are committed to protecting the personal information that we may collect in the course of our operations.  The Coalition is comprised of its organizational members (the “Members”), which are identified on the Site.

This Privacy Notice (“Notice”) applies to personal information collected through this website, (the “Site”) and otherwise in the course of providing our other products and services (collectively, the Site and our other products and services are the “Services”) only to the extent this Notice is expressly incorporated in connection with such Services, such as by internet link on a website, express incorporation by reference in a contract, or other presentation or display to users.  If not so expressly incorporated, this Notice does not apply to any other data or information collected by or for us online or offline.

This Notice is part of our Terms of Use, and any other applicable agreements or policies that govern your use of our Services.  A link to our Terms of Use is also provided at the bottom of each page within our Site and can also be found here.

II. The Types Of Information We Collect

“Personal information” is defined by local law.  Generally speaking, this may include information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to a specific natural person.  Depending on local law, certain information may be excluded from the definition of “personal information,” including anonymous, de-identified, or aggregated information.

As a general matter, our Site collects comparative little Personal Information for the purpose of providing the Services.  The information we collect includes the following:

  1. Information You Provide to Us
    • The amount and type of personal information we collect about you depends on your interactions with us.  For example, we may collect personal information if you use our internet speed test widget or submit information through the Contact page on the Site.
    • Depending on your interaction with us, we may collect the following categories of personal information:
      • Geolocation Information, such as your general latitude and longitude, address, city, state, and country, etc.
      • Name, telephone number, and email address.
      • Other information you choose to provide, including on online surveys, information requests, and in communications with us.
    • When you provide us with personal information, you agree to provide accurate, complete, and true information. You agree to not use a false or misleading name that you are not authorized to use.
  2. Information We May Automatically Collect
    • In addition to the information that you voluntarily provide to us, we may automatically collect information that your web browser provides to us.  The categories of personal information that we may automatically collect include:
      • Geolocation Information, such as your general latitude and longitude coordinates.
      • Strictly necessary cookies to provide our Services and to secure the Site, including cookies set by Google Maps and security cookies.
      • We generally do not collect IP addresses on the Site except in specific cases necessary to secure the Site.

III. How We Use The Information We Collect

We may use collected personal information to:

  • provide you with the Services that you request.
  • respond to your questions, comments, and requests made through our Site;
  • update our mailing lists;
    • invite you to participate in surveys and provide feedback to us (unless you have chosen not to receive these communications);
    • prevent fraudulent use of our Site or our systems;
    • enforce our Terms of Use or comply with laws;
    • maintain a record of how you use our Site or Services;
    • for administrative purposes;
    • and for any other purposes that we may disclose to you when we request personal information and your consent to use it.

We may use anonymous, de-identified, or aggregate information that does not reasonably identify you for any purpose, as permitted by applicable law.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

IV. How We May Share The Information We Collect

We do not sell, trade, or rent your personal information to others.  There may be times when we need to share your personal information with third parties to provide you Services, for the proper functioning of Site features, to comply with the law, and for other lawful bases consistent with locally controlling laws and regulations. The occasions when we will share your personal information because of these reasons are explained below.

  • Our Members – we may share information between our Members for any of the purposes listed above.
  • Our service providers – we use third parties to assist us with providing certain Services (g., data storage and processing and web hosting) and we may share your personal information with these third-party service providers to help us to serve you. We limit the amount and types of personal information we share with service providers to what they need to reasonably perform their functions.
  • Legal Protection – we may disclose personal information if we believe we must to comply with a law, or if disclosure is in our interest to protect property or other legal rights. This may include disclosing personal information to enforce contracts and agreements, to protect the rights or property of others, or to help protect the security of our Service and the information of other users.
  • Others with your consent or at your direction

V. Online Analytics

We may share aggregate, non-personally identifiable location information with third parties to assist in understanding our user’s interests and usage of our Site or Services.  However, we do not currently use any online analytic features on our Site.

VI. How Long We Keep Your Information

We store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with applicable law and legitimate business interests, which may include long term longitudinal studies on internet speeds in specific geographic areas.

When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

VII. How We Keep Your Information Safe

We utilize commercially reasonable administrative, technical, and physical safeguards to comply with applicable legal requirements and safeguard the information that we collect and maintain.

Unfortunately, no data transmission or storage can be guaranteed to be completely secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) we cannot control security and privacy indefinitely; (b) the security, integrity, and privacy of information or data exchanged between you and us cannot always be guaranteed; and (c) any such information and data may be viewed or compromised when in transit by a third party.

VIII. Do Not Track Disclosures

We follow the standards explained in this Privacy Notice and do not interact with or implement “Do Not Track” requests or web browser settings.

IX. Children

Our Site is not directed at children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 without obtaining parental consent. It is our procedure to promptly delete any personal information collected from a child under the age of 18 upon discovery of such a circumstance. If you believe that we may have collected personal information from a child under the age of 18, please contact us using the contact information at the end of this Policy and we will take appropriate steps to rectify this inadvertent collection.

X. Visitors Outside Franklin County, Ohio

The Franklin County Digital Equity Coalition works to create long-term solutions to digital equity in Franklin County, Ohio.  Although our Site may be accessible in some locations outside of the United States, it is not our intention to offer Services to individuals located outside of Franklin County, Ohio, United States via the Site. Any information we collect via the Site will be stored and processed in Franklin County, Ohio, United States and if you are located outside of the State of Ohio or the United States, the laws of the State of Ohio or the United States may offer less protection than the laws of your place of residence. We will collect and maintain any personal information only as long as we need it for the purposes outlined in this Privacy Notice. By providing your Personal Information to us through your use of the Services or Site, you agree to our transfer, storage, and processing procedures based in the State of Ohio, United States. Please note that different regions and countries can have their own privacy and data security laws; some of which may be less protective of your Personal Information than the laws of your own region or country.

In the event that we collect or process Personal Information subject to the GDPR, we will comply with the requests of European data subject requests to: (1) access Personal Information, (2) have inaccurate or unnecessary Personal Information rectified or deleted, or (3) stop using your Personal Information in a certain way. If your use of our Services or Site is subject to GDPR you would also have a right to lodge a complaint with your local EU regulator.

Likewise, in the event we collect or process Personal Information subject to the laws of another jurisdiction, including another U.S. state, we will comply with the laws of that jurisdiction to the best of our knowledge and understanding.

Changes To This Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date.  However, we will not treat your previously collected personal information, to the extent it is not collected under the new privacy notice, in a manner materially different than represented at the time it was collected without your consent. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

How To Contact Us

If you have any questions or concerns about this Notice, please contact us using the Contact Us page on the Site.