Welcome to Focus on The Gap Educational Services! This Privacy Policy ("Policy") applies to your access and use of focusonthegap.com ("the Site") and the software and services available on the Site or offered by our subsidiaries ("Focus on The Gap Educational Services"). This Policy expressly discloses i) the types of personal and non-personal information collected as a result of your use of the Site and the Focus on The Gap Educational Services; ii) how such data is used and stored; and iii) your choices and options regarding sharing and use of your data.
This Privacy Policy is incorporated as part of the Focus on The Gap Terms of Service. We take your privacy seriously. If you have any questions about this policy or about privacy at Focus on The Gap, please contact us at support@focusonthegap.com.
What Information is Collected & How is it Used?
Data Collected When You Visit Our Site:
Tracking Data ("Tracking Information")
When a user visits the Site's homepage, Focus on The Gap utilizes an electronic file, called a web beacon, to count users that have visited the Site. Beacons are tiny graphics with a unique identifier that may be included on our Site Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of the Focus on The Gap Services, to monitor how many visitors view our Site. Unlike Cookies, which are stored on the user's device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail). We do not use web beacons to track any activity related to user accounts.
Cookies and our Cookie Policy
Focus on The Gap Cookie Policy. We use cookies, small strings of numbers and letters that are placed on your browser. We use a persistent cookie that contains login information which automatically logs you in when you return to our website. We also use Google Analytics and Cookiebot cookies to help us understand how users use our Site and to improve Focus on The Gap Services.
If you login with your Facebook, Twitter, and LinkedIn account, cookies may also be placed in accordance with their privacy policies. You can set your browser to remove or reject cookies; however, some Site features or Services may not work properly without cookies.
Personal Information
IP Addresses. When you visit the Site or use Services, our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, or the webpage you were visiting before you came to the Services, pages of the Site that you visit, the time spent on those pages, information you search for on the Services, access times and dates, and other statistics.
Data Collected During Account Creation: We will collect your name, e-mail address, and password when you set up an account with us as a customer or as a competition entrant ("Account Information"). When you create an account to access the Focus on The Gap Services, you can sign up either with your email or through certain social media accounts. If you sign up directly with your email address, we will collect your First and Last Name, Email Address, and ask you to create and confirm an account password. If you sign up using your Facebook, Twitter, or LinkedIn accounts, you will be asked for your account login information. By using third-party social media accounts to create an account, you are allowing Focus on The Gap to access personal information in those accounts to pre-populate your account sign-up process with information from those accounts. All information is accessed by Focus on The Gap in accordance with the privacy policies of Facebook, Twitter, and LinkedIn.
Data Collected When You Set Up a Profile. After you set up your account, we may give you the option of setting up a profile to describe yourself and your project. You may also be given the option of providing your Account Information (except your password, which you should not share with others).
Data Collected When You Apply to Enter A Competition. When you apply to enter a competition that is powered by the Focus on The Gap platform, you may be required to provide both Personal Information (such as your name, address, contact information, email, phone number, resume or biography) and information about your educational needs (such as subjects, preferred tutoring hours, etc.) ("Competition Information").
With respect to Competition Information, Focus on The Gap and our subsidiaries are generally the Data Processor acting on behalf of the competition organizer or organizers identified in each applicable contest ("Competition Organizer"). The type of Competition Information collected is determined by the Competition Organizer in their sole and absolute discretion, and their collection and use of that information are governed by the rules, regulations, guidelines, and privacy policy of a given Competition Organizer. Entrants should review the applicable rules and policies of a Competition Organizer to understand the scope of their collection, use, and storage practices.
Competitions Sponsored and Organized by Focus on The Gap. In the event that a competition is sponsored and organized by us or a subsidiary, we will clearly identify and disclose how we intend to use the information from our competitions so that you can decide if you want to enter and provide your Competition Information to us as well as know who to contact regarding your Competition Information. For competitions that we sponsor, we will not ask for your race, ethnicity, or health information or any other data that is classified as "Sensitive Information" under applicable data protection regulations.
Data Collected When You Subscribe to or Purchase Focus on The Gap Services. When you subscribe to or purchase any Focus on The Gap Services, Focus on The Gap may additionally collect your email, first and last name, billing address, credit card number, and security code to process the transaction. Focus on The Gap may also, upon request, mail an invoice to the mailing address provided by a user to facilitate payment.
With respect to information collected in connection with the subscription or purchase of Focus on The Gap Software and Services, you should direct any inquiries or requests to us.
Data Collected for Purchases and Subscriptions. When someone makes a payment related to our Services, we collect and transmit Account Information and credit card payment information and transmit it to our payments processor. We do not store credit card payment information.
2. How is Collected Information Used?
Subsidiaries: Any information we share with subsidiaries will be subject to intra-company data sharing agreements that incorporate EU Model Contractual Clauses.
Account Information: Focus on The Gap and its subsidiaries may utilize email addresses provided during the creation of an account to (i) confirm account creation and validate the provided information, (ii) send secure links for accessing the Site or Focus on The Gap Services, (iii) send transaction confirmations for financial transactions, (iv) communicate with users to provide information about Focus on The Gap Services or respond to user inquiries, or (v) notify users of material changes to our Terms of Service and Privacy Policy. With user consent, users may receive Focus on The Gap's monthly newsletters or targeted notifications regarding competitions, programs, and opportunities available through Focus on The Gap's partners and clients. Users have the option to opt-out of these email updates if they prefer, from the Account page.
Competition Information: To enter a competition, you must provide your Competition Information as it is necessary to administer your entry and the competition. We use your Account Information, Competition Information, and Tracking Information to administer the Services, competitions, provide customer services, improve the Site and Services, and recommend other competitions that might be of interest to you. When you enter a competition, you authorize Focus on The Gap to share your Account Information and relevant Competition Information with the competition administrators and judges solely for the purpose of administering the competition unless you authorize or consent to the Competition Organizers to do otherwise. Except for the Competition Organizers, judges, and administrators, we do not share your Competition Information with any third parties. Additionally, Focus on The Gap and its subsidiaries may anonymize and aggregate Competition Information, Tracking Information, and Account Information to generate reports regarding trends in vertical markets. With the consent of the competition entrant, Focus on The Gap may prepare profiles of top startups and facilitate matchmaking and other communications between relevant third-party entities and startups.
Sharing Your Profile: We or our subsidiaries may offer the opportunity for you to share information in your profile with organizations that may be interested in supporting your efforts. We will only do this with your consent, which you may withdraw at any time from your account preferences.
Credit or Debit Card Information: Focus on The Gap and its subsidiaries do not store any credit card data associated with purchases made on the Site. Focus on The Gap utilizes AmberPay to process recurring payments and as a payment gateway. When you enter your payment information, AmberPay sends us back a token that we store in our servers. This token is linked to but cannot be converted to your credit or debit card information. Please review AmberPay's Privacy Policy for more information about how your information is collected, stored, and maintained by these third-party payment processors.
Anonymous Data – Analytics: Focus on The Gap utilizes Tracking Information, Log Information, and Google Analytics to access anonymous data that helps us understand how our Services are used. We use Tracking Information to customize content for you and improve our Services. Google Analytics is a web analytics tool that helps Focus on The Gap understand how users engage with our Site, enabling us to review and improve our Services. Google Analytics collects information anonymously and provides reports to Focus on The Gap regarding website trends without identifying individual visitors.
Data Retention: We retain data as long as your account is active. If you do not use your account for one year, we reserve the right to delete your information. We may de-identify and anonymize data you provide to us for research purposes, trend analysis, and sharing with third parties to improve the Services.
3. Third-Party Websites
Our site contains links to other websites. When you click on one of these links, you are directed to another website. Focus on The Gap does not control the data collection or privacy practices of such third-party sites. We encourage you to read the privacy policies of any third-party sites, as their collection, use, and storage practices and policies may differ from ours.
4. How is Information Shared
Third-Party Services
We may work with third parties to administer the Site and Services.
We use data storage services in the United States to store your Account Information to enable us to provide our Services.
We use customer management tools to help us manage our customer relationships and projects. We utilize Account Information, Profiles, Competition Information, and Competition Organizer information to provide the Services from servers in the United States.
We take steps to ensure that these parties prioritize the protection of your privacy, including entering into Data Processing Addendum, EU Model Clauses, and/or ensuring they have EU-U.S. and Swiss-U.S. Privacy Shield certifications.
In addition to our Competition Organizers and judges, we also use the following third-party services that provide Personal Data to us:
Google Analytics: Focus on The Gap utilizes Google Analytics to collect information about the use of this service on the Site. Google Analytics collects information such as the frequency of site visits, the pages visited, and the websites visited before coming to our site. We use this information to improve our site anonymously. Google Analytics collects only the IP address assigned to you on the date of your visit, using a user ID code rather than your name or other identifying information. We do not combine the information collected through Google Analytics with personally identifiable information. Google uses this information to analyze website usage, generate reports for website operators, and provide other related services. Google may share this information with third parties as legally required or if they process data on behalf of Google. While Google Analytics places a permanent cookie on your web browser to identify you as a unique user on your next visit, this cookie cannot be used by anyone but Google. Google's use and sharing of information collected by Google Analytics about your visits to our site are governed by the Google Analytics Terms of Use, Google Privacy Policy, and the Google Analytics Data Processing Agreement. Site usage is tracked using Google Analytics in accordance with their Privacy Policy. However, if you do not want your data to be used by Google Analytics, you may opt-out by installing the Google Analytics Opt-out Browser Add-on. Data processing takes place in the United States, and Google relies on Standard Contractual Clauses. You may deactivate Google Analytics using a browser add-on if you do not want your website usage analyzed.
reCAPTCHA: Focus on The Gap uses reCAPTCHA, a service from Google, to protect the Site from spam and abuse. Please review the reCAPTCHA Privacy Policy through Google for more information. Data processing takes place in the United States, and Google relies on Standard Contractual Clauses.
AmberPay: Focus on The Gap utilizes AmberPay as a payment gateway for collecting Account Information and payment information to validate payments and return an anonymous token. Focus on The Gap does not store your credit card information. Data processing takes place in the United States, and AmberPay relies on a Data Processing Addendum and Standard Contractual Clauses. Please review AmberPay's Security Policy before initiating transactions on the Site.
GoDaddy: We use GoDaddy as a website host, and it may collect the information you provide to us through online forms, which may include personal data. We have a Data Processing Addendum in place using the EU Standard Contractual Clauses. GoDaddy does not store this information, but you should consult the GoDaddy Privacy Policy for any inquiries or requests.
Additional Circumstances When Disclosures May Be Made to Third Parties
Information collected by Focus on The Gap may be disclosed when (i) required by law or (ii) in the event of a change of ownership.
When Disclosure or Use is Otherwise Permitted: Account Information or Competition Information may be provided when required by law or if we believe in good faith that it is reasonably necessary: (i) to respond to claims asserted against Focus on The Gap or to comply with legal processes (e.g., discovery requests, subpoenas, or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development, and debugging purposes; or (iv) to protect the rights, property, or safety of Focus on The Gap, its users, or members of the general public. We will make commercially reasonable efforts to notify users about law enforcement or court-ordered requests for data unless prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections you may have to any third-party request to disclose your information.
Acquisition/Merger/Assignment or other Business Transfer: Focus on The Gap may sell, transfer, or share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization, or sale of assets or in the event of bankruptcy. Under such circumstances, Focus on The Gap will make commercially reasonable efforts to notify its users if their personal information is to be disclosed, transferred, and/or becomes subject to a different privacy policy.
5. How is my Data Stored and Kept Secure?
Security Measures: We have implemented reasonable administrative, technical, and physical security measures to protect your personal information against unauthorized access, destruction, or alteration. For example:
SSL encryption (https) is used everywhere when dealing with personal data.
Lost passwords cannot be retrieved; you can only set a new password upon receiving a reset email.
Data is stored on secure servers located in the US.
Restricting staff access to Collected Information and Account Information
Payments Encryption: Focus on The Gap utilizes only PCI-DSS-compliant third-party payment processors to ensure the security of your personal information. Users should review AmberPay's Security Policy before initiating transactions on the Site.
Abuse Prevention: Focus on The Gap uses reCAPTCHA, a service from Google, to protect the Site from spam and abuse. Users should review reCAPTCHA's Privacy Policy through Google for more information.
Despite our best efforts, users should be advised that no method of transmission over the Internet and no method of storing electronic information can ever be 100% secure.
6. Your Choices: How Do I Review or Revise Account Information or Withdraw Consent?
Viewing or Correcting Your Information: You can access and update Account Information in your account at any time by logging into your account. If you need assistance deleting inaccuracies within your personal information or would like to know what information about you was collected, please contact us at support@focusonthegap.com. We will respond to your request within 10 business days. We reserve the right to charge for copies of data undergoing processing.
Removal or Withdrawing Consent: If you would like us to delete your Account Information, follow the link from your account page to submit a request. In such cases, we will retain your Account Information only as required by law or for legitimate business purposes permitted by law or de-identify and anonymize information that we wish to retain so that it cannot be connected to you.
Marketing Communications: Users have the option to opt-out of email updates from their Account page.
Data Portability: If you would like us to transmit your personal data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the receiving company.
Right to Redress: Focus on The Gap has further committed to referring unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.com/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
7. COPPA and Access by Minors
Focus on The Gap does not knowingly collect or store any personal information from or about children under the age of 16.
If you believe that a child under the age of 16 has provided us with personal information, a parent or legal guardian can email us at support@focusonthegap.com to request the deletion of their children's information from our records.
8. EU-U.S. and Swiss-US Privacy Shield Frameworks Summary
Note: Following recent decisions invalidating the adequacy of Privacy Shield, Focus on The Gap no longer relies on Privacy Shield for cross-border Personal Data transfers. Instead, we rely on the direct collection of Personal Data from individuals located outside of the U.S., or we use other legal bases, such as standard contractual clauses, for cross-border Personal Data transfers. However, we continue to comply with the Privacy Shield framework, including its dispute resolution process. Please read our statement for more information about how we comply with the Privacy Shield framework. Focus on The Gap remains committed to protecting personal information in accordance with applicable privacy laws.
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, Focus on The Gap adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification, please visit PrivacyShield.gov.
Focus on The Gap has further committed to referring unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.com/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
Please note that if your complaint is not resolved through these channels, under limited circumstances, individuals in the European Union and/or Switzerland may seek a binding arbitration option before a Privacy Shield Panel.
Consistent with the terms of this Privacy Policy, Focus on The Gap collects personal data from clients, customers, and applicants for the purpose of logging into our system (email and password), as well as for running startup program competitions and similar programs. The data collected is primarily determined by our clients in their application forms hosted on our website, and the use of this data is governed by our Privacy Policy and Terms and Conditions.
Focus on The Gap receives information from users, such as startups, and shares that information with the organizers of the programs, who are our direct clients. When startup users share information about their startup with Focus on The Gap, they are fully aware and intentional in providing it to the program organizers.
Users have the right to access, correct, and delete their personal information, as stated in our Privacy Policy and Terms of Service.
Users can edit or delete their information from their Account page and request additional information to be deleted, unless otherwise permitted by law.
Additionally, on this page, users can opt-in or out of email communications. When a user provides any information to program organizers using our website, they can always access and view the information. Before a program deadline, they can access, view, edit, and delete any information. After a program deadline, they are unable to edit that information, but they continue to have access. If needed, they can always contact Focus on The Gap and/or the program organizer to delete the information, where permitted by law.
Focus on The Gap is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Focus on The Gap may also be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In cases of onward transfer to third parties of data of individuals from the European Union and Switzerland received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, Focus on The Gap may be held liable.
9. How Does Focus on The Gap Respond to "Do Not Track" Signals?
"Do Not Track" or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, Focus on The Gap's website does not respond to or alter its practices when a DNT signal is received.
10. How Will I Be Notified of Any Changes to this Privacy Policy?
Focus on The Gap reserves the right to amend this Privacy Policy at any time. If there are material changes to the Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and (2) providing additional notification either via email or other means that we consider commercially reasonable.
Your continued use of our services after such changes have been made to the Privacy Policy constitutes your consent to our modified data collection and use practices.
11. Questions?
If you have any questions about our Privacy Policy or need to contact us for any reason, you can reach us at:
Focus on The Gap Educational Services
12 Fraser Boulevard, Fraser Content
Spanish Town, St. Catherine
Phone: +1-876-834-0824
Email: support@focusonthegap.com
Focus on The Gap Educational Services
Copyright © 2023 Focus on The Gap Educational Services - All Rights Reserved.
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