DNA Assessment Terms & Privacy Policy

Effective date: January 1, 2023

Founder Institute, Incorporated (FII) ("us", "we", or "our") operates the website, https://fi.co/ (the “FII Site” or the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from https://fi.co/terms_of_use


Definitions 

  1. “CCPA” means California Civil Code Sec. 1798.100, et seq. (also known as the California Consumer Privacy Act of 2018);
  2. “Cookies” are small pieces of data stored on a User’s device.
  3. “Data Controller” means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, FII is the Data Controller of your data.
  4. “Data Processor” means any natural person or legal entity which Processes Customer Dat other than an employee of the Data Controller who processes data on behalf of the Data Controller; and, with respect to the Processing of Customer User Personal Data pursuant to this Service, “Processor” means FII; We may use the services of various Service Providers in order to process your data more effectively.
  5. “Data Protection Laws” means: (i) CCPA, GDPR (and any related national implementing legislation), any
  6. replacement or repealing legislation, and any regulations issued by a Supervisory Authority relating to the same; (ii) the laws of any jurisdiction applicable to the Services and/or FII’s business; and (iii) the laws of any other jurisdiction the parties agree in writing applies to FII’s Processing of User Personal Data;
  7. “Data Subject” means a particular identified or identifiable natural person who is the subject of User Personal Data;
  8. “EEA” means the European Economic Area;
  9. “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
  10. “Model Clauses” means the EC Standard Contractual Clauses for Processors as published in the Decision of the European Commission of February 5, 2010 (Decision 2010/87/EC) as updated from time to time;
  11. “Process,” “Processes,” and “Processing” means (performing) any operation or set of operations on Customer User Personal Data, whether or not by automated means;
  12. “Sub-Processor” means any Processor appointed by FII to assist with FII 's Processing of Customer User Personal Data; and “Supervisory Authority” means a government agency responsible for enforcement of the Data Protection Laws, with competent jurisdiction over the parties.
  13. “Usage Data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  14. “User” is the individual using our Service. The User corresponds to the Data Subject, who is the subject of User Personal Data.
  15. “User Data” means User Content, as well as any Confidential Information other than User Content.
  16. “User Personal Data” means any User Data that identifies (or can be used to identify) a particular natural person and that is considered “personal data,” “personal information,” or a like characterization under Data Protection Laws; means any User Data that identifies (or can be used to identify) a particular natural person and that is considered “personal data,” “personal information,” or a like characterization under Data Protection Laws;


Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected: 

  1. Personal Data
  2. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("User Personal Data"). Personally identifiable information may include, but is not limited to:
  3. Email address
  4. First name and last name
  5. Gender
  6. Assessment Results
  7. City Cookies and Usage Data

We may use your User Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  1. Session Cookies. We use Session Cookies to operate our Service.
  2. Preference Cookies. We use Preference Cookies to remember your preferences and various settings. Security Cookies. We use Security Cookies for security purposes.

Use of Data

We use the information we collect to provide you with our services as well as content that’s relevant and personal to you. Consequently, it’s necessary for us to use your information to:

  1. To provide and maintain our Service
  2. To send you your assessment test results, if you request them 
  3. To send you account-related messages, such as recovery of your password
  4. To collect payments from you, if you decide to purchase something from us
  5. To notify you about changes or updates to our Service
  6. To allow you to participate in interactive features of our Service when you choose to do so
  7. To provide customer support and administrative purposes
  8. To gather analysis or valuable information so that we can improve our Service
  9. To monitor the usage of our Service
  10. To detect, prevent and address technical issues


Additionally, we have a legitimate interest in maintaining our relationship with you, improving our website and services, and protecting both you and other users.


Your Choice

You may, of course, decline to share your personally-identifiable information with FII, in which case FII will not be able to provide to you some of the features and functionality found on the FII Service.. If you are a Registered User (as defined in the Terms of Use) with a registered account on the FII Service, you may update, correct, or delete your account information and preferences at any time by going to https://fi.co/.

To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.


Retention of Data

FII will retain your User Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your User Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

FII will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including User Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the Data Protection Laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including User Personal Data, to the United States and process it there. Transfer of User Personal Data will be according to Data Protection Laws, including GDPR and CCPA.  

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

FII will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your User Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data 

FII does not share your personally identifiable information with other organizations for their marketing or promotional uses without your express consent. 

FII may disclose automatically collected and other aggregate non-personally-identifiable information with interested third parties to, among other things, assist such parties in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the FII Service.

FII may disclose User information to affiliated companies or other businesses or persons to: provide website hosting, maintenance, and security services; conduct data analysis and create reports; offer certain functionality; and assist FII in improving the FII Service and creating new services features. We require that these parties process such information in compliance with this Privacy Policy, we authorize only a limited use of such information, and we require these parties to use reasonable confidentiality measures.

Disclosure for Law Enforcement

Under certain circumstances, FII may be required to disclose your User Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

FII may disclose your User Personal Data in the good faith belief that such action is necessary to:

  1. To comply with a legal obligation
  2. To protect and defend the rights or property of Founder Institute, Incorporated (FII)
  3. To prevent or investigate possible wrongdoing in connection with the Service
  4. To protect the personal safety of users of the Service or the public
  5. To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your User Personal Data, we cannot guarantee its absolute security.

If FII learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the FII Service or providing personal information to us, you agree that we can communicate with you electronically regarding security and privacy issues relating to your use of the FII Service. FII may post a notice on the FII Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. 

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights

FII aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your User Personal Data.

Whenever made possible, you can update your User Personal Data directly within your account settings section. If you are unable to change your User Personal Data, please contact us to make the required changes.

If you wish to be informed what User Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

  1. To access and receive a copy of the User Personal Data we hold about you
  2. To rectify any User Personal Data held about you that is inaccurate 
  3. To request the deletion of User Personal Data held about you

You have the right to data portability for the information you provide to FII. You can request to obtain a copy of your User Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your User Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/


Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy

PayPal 

Their Privacy Policy can be viewed at: https://www.paypal.com/webapps/mpp/ua/privacy-full

Children's Privacy

Protecting the privacy of young children is especially important. Our Service does not address anyone under the age of 13 ("Children"). For that reason, FII does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the FII Service is directed to persons under 13. If you are under 13 years of age, then please do not use or access the FII Service at any time or in any manner. Any person who provides their personal information to FII through the FII Service represents that they are 13 years of age or older. If FII learns that personally identifiable information of persons less than 13 years of age has been collected then FII will take the appropriate steps to delete this information from our servers.

In the Event of Merger, Sale or Bankruptcy

In the event that FII should ever be acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of such merger, acquisition, sale, or other change of control. In the event of FII’s bankruptcy, insolvency, or assignment for the benefit of creditors, we may not be able to control how information that we have collected from Users is transferred or used.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: help@fi.co