How we collect and use your data

How we collect and use your data

Privacy Policy

Privacy Policy

Effective Date: 08/27/2025

1. Introduction

Fletch Scholarship Foundation ("Fletch," "Foundation," "we," "us," or "our") is committed to protecting the privacy and security of the personal information we collect from users of our website and services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, submit scholarship applications, make donations, or otherwise interact with our services.

Fletch Scholarship Foundation is a 501(c)(3) nonprofit corporation organized under the laws of Texas. Our mission is to provide merit-based scholarships that recognize achievement, address need, and amplify community service nationwide.

By using our website or services, you consent to the data practices described in this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not access or use our website or services.

2. Information We Collect

Personal Information

We collect personal information that you voluntarily provide to us when you:

  • Submit scholarship applications

  • Make donations

  • Subscribe to our newsletter or communications

  • Contact us with inquiries

  • Participate in surveys or feedback

  • Apply for educational partnerships

Types of Personal Information we may collect include:

  • Full name, address, phone number, and email address

  • Date of birth and age verification

  • Social Security Number or Tax Identification Number (when required for tax purposes)

  • Academic information including GPA, test scores, transcripts, and school enrollment

  • Financial information including family income, tax returns, and financial aid status

  • Demographic information including race, ethnicity, and gender (voluntary)

  • Emergency contact information

  • Parent or guardian contact information (for minors)

Sensitive Academic and Financial Information

As a scholarship foundation, we may collect sensitive information that may be necessary to evaluate applications and determine eligibility:

  • Official transcripts and academic records

  • Standardized test scores (SAT, ACT, etc.)

  • Letters of recommendation

  • Personal essays and statements

  • Community service records

  • Financial aid documents (FAFSA, tax returns, bank statements)

  • Verification of financial need documentation

User-Generated Content

We may collect content you create and submit, which may include:

  • Scholarship application essays and personal statements

  • Testimonials and success stories

  • Photos and videos (with consent)

  • Survey responses and feedback

  • Communications with Foundation staff

Technical Information

We may automatically collect certain technical information when you visit our website:

  • IP address and device identifiers

  • Browser type and version

  • Operating system

  • Pages visited and time spent on pages

  • Referring website addresses

  • Cookies and similar tracking technologies

3. How We Collect Information

Direct Collection

We collect information directly from you when you:

  • Complete online forms and applications

  • Create user accounts

  • Make donations through our website

  • Subscribe to communications

  • Contact us via email, phone, or contact forms

Third-Party Collection

We may collect information through third-party services we use to operate our website and programs:

  • Application Platforms: Online form and application management systems

  • Communication Services: Email and text messaging platforms for program communications

  • Website Analytics: Tools to understand website usage and improve user experience

  • Payment Processing: Secure payment processors for donation handling

  • Cloud Storage and Collaboration: Cloud-based storage and document management systems

  • Customer Relationship Management: Systems for managing donor and applicant relationships

Educational Institution Verification

We may collect information from schools, colleges, and universities to verify:

  • Academic records and enrollment status

  • Recommendation letters

  • Program participation and achievements

4. How We Use Your Information

Nonprofit Purpose Limitation: All personal information collected by Fletch Scholarship Foundation may be used solely for our exempt nonprofit purposes under Section 501(c)(3) of the Internal Revenue Code. We do not use your information for commercial purposes or private benefit.

We may use collected information exclusively for the following charitable and educational purposes:

Scholarship Program Administration

  • Evaluate scholarship applications and determine eligibility

  • Verify academic and financial information

  • Communicate application status and decisions

  • Distribute scholarship awards and funds

  • Monitor academic progress of recipients (when required)

Operational Purposes

  • Provide customer support and respond to inquiries

  • Process donations and provide tax documentation

  • Send program updates and important communications

  • Improve our website, services, and user experience

  • Ensure security and prevent fraud

Marketing and Outreach (with consent)

  • Send newsletters and program announcements

  • Share success stories and testimonials (with permission)

  • Promote scholarship opportunities to eligible students

  • Engage with educational partners and donors

Legal and Compliance

  • Comply with legal obligations and regulations

  • Respond to legal requests and court orders

  • Protect our rights and defend against legal claims

  • Maintain records as required by nonprofit regulations

5. Legal Basis for Processing (GDPR Compliance)

For users in the European Union, our legal basis for processing personal information includes:

  • Consent: When you provide explicit consent for specific purposes

  • Contractual Necessity: To fulfill our scholarship and service obligations

  • Legitimate Interests: To operate our nonprofit mission and improve services

  • Legal Compliance: To meet regulatory and legal requirements

6. Information Sharing and Disclosure

Educational Partners

We may share limited information with schools, colleges, and universities for:

  • Verification of academic records and enrollment

  • Coordination of scholarship disbursements

  • Reporting on scholarship recipient progress

Service Providers

We may share information with trusted third-party service providers who may assist with:

  • Website hosting and maintenance

  • Application processing and data management

  • Payment processing and financial transactions

  • Communication and email services

  • Data analytics and website optimization

All service providers may be bound by confidentiality agreements and may be authorized to use information only as necessary to provide services to us.

Legal Requirements

We may disclose information when required by law or when we believe disclosure is necessary to:

  • Comply with legal process or court orders

  • Protect our rights, property, or safety

  • Prevent fraud or illegal activities

  • Respond to government or regulatory requests

Donors and Supporters (Limited)

With appropriate consent, we may share:

  • General scholarship recipient information for donor recognition

  • Aggregate statistics about program impact and success

  • Testimonials and success stories (with recipient permission)

Business Transfers

In the event of a merger, acquisition, or transfer of assets, user information may be transferred as part of the transaction, subject to the same privacy protections.

7. Data Security

Educational Records Protection (FERPA Compliance)

As a scholarship foundation that collects and maintains educational records, we comply with the Family Educational Rights and Privacy Act (FERPA) when applicable:

  • Educational Record Definition: We treat academic transcripts, test scores, and related academic information as educational records subject to FERPA protections

  • Parental Rights: For students under 18, parents have rights to inspect and review educational records we maintain

  • Student Rights: Students 18 and older have direct rights to access their educational records

  • Directory Information: We may designate certain information as directory information, which may be disclosed without consent unless you opt-out

  • Consent Requirements: We obtain written consent before disclosing non-directory educational records, except as permitted by FERPA exceptions

Despite our security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.

8. Data Retention

We retain personal information for different periods based on the purpose of collection:

  • Scholarship Applications: Active applications and recipient records are retained for the duration of the scholarship program plus seven (7) years for administrative and compliance purposes

  • Donor Information: Retained for seven (7) years for tax and regulatory compliance

  • Website Analytics: Typically retained for two (2) years

  • Marketing Communications: Until you unsubscribe or request deletion

  • Legal Obligations: As required by applicable laws and regulations

When personal information is no longer needed, we securely delete or anonymize it according to our data retention schedule.

9. Your Rights and Choices

Access and Correction

You have the right to:

  • Access personal information we hold about you

  • Request correction of inaccurate or incomplete information

  • Receive a copy of your personal information in a portable format

  • For scholarship applicants under 18: Parents have the right to access and correct their minor child's information

Communication Preferences

You can:

  • Unsubscribe from marketing emails using the unsubscribe link

  • Update your communication preferences by contacting us

  • Contact us to modify how we communicate with you

Data Deletion

You may request deletion of your personal information, subject to:

  • Legal obligations requiring us to retain certain records

  • Legitimate business interests in maintaining historical records

  • Ongoing scholarship obligations and agreements

European Union Rights

If you are in the EU, you have additional rights under the General Data Protection Regulation (GDPR):

  • Right to restrict processing of your information

  • Right to object to processing for direct marketing

  • Right to lodge a complaint with a supervisory authority

10. Cookies and Tracking Technologies

Types of Cookies We Use

  • Essential Cookies: Required for website functionality and security

  • Analytics Cookies: Help us understand website usage and improve user experience

  • Communication Cookies: Enable communication features and support

Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect website functionality.

Third-Party Tracking

Our website may include third-party analytics and social media features that use their own cookies and tracking technologies, subject to their respective privacy policies.

11. Third-Party Links and Services

Our website may contain links to third-party websites, including:

  • Educational institutions and partner organizations

  • Social media platforms

  • External resources and tools

We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy (COPPA Compliance)

Our services are designed for users aged 15 and older. We comply with the Children's Online Privacy Protection Act (COPPA) as follows:

For Users 15-17 Years Old:

  • Parental consent is required for scholarship application submission and data collection

  • Parents have the right to review, modify, or delete their minor child's information

  • Parents can consent to collection and use of their child's information without consenting to disclosure to third parties

  • We provide clear notice to parents about our data collection practices

  • We take additional measures to protect the privacy of minor users

Prohibited Collection from Children Under 15:

  • We do not knowingly collect personal information from children under 15 without verifiable parental consent

  • Our website includes age verification mechanisms

  • If we learn that we have inadvertently collected information from a child under 15 without proper consent, we will delete that information within a reasonable time

Parental Rights Under COPPA:

  • Right to review their child's personal information

  • Right to request deletion of their child's personal information

  • Right to refuse further collection or use of their child's information

  • Right to be notified of any material changes to our privacy practices regarding children

13. International Data Transfers

If you are accessing our services from outside the United States, please note that your information may be transferred to, stored, and processed in the United States. By using our services, you consent to the transfer of your information to the United States, which may have different data protection laws than your country of residence.

For users in the European Union, we ensure adequate protection through appropriate safeguards such as:

  • Adequacy Decisions: Transfers to countries with adequacy decisions from the European Commission

  • Standard Contractual Clauses: EU-approved standard contractual clauses for transfers to countries without adequacy decisions

  • Binding Corporate Rules: Where applicable, binding corporate rules approved by EU data protection authorities

  • Certification Mechanisms: Transfers under approved certification mechanisms

  • Codes of Conduct: Adherence to approved codes of conduct

We will not transfer personal data to countries that do not provide adequate protection unless appropriate safeguards are in place.

14. California Privacy Rights

California residents have specific rights under the California Consumer Privacy Act (CCPA):

Right to Correct

Under CCPA, you have the right to request correction of inaccurate personal information we maintain about you.

Right to Know

You have the right to request information about:

  • Categories of personal information we collect

  • Purposes for collecting personal information

  • Categories of sources from which we collect personal information

  • Categories of third parties we share information with

  • Specific pieces of personal information we hold about you

  • Categories of personal information we have sold or disclosed for business purposes in the preceding 12 months

Right to Delete

You can request deletion of your personal information, subject to certain exceptions including:

  • Legal compliance and regulatory requirements

  • Legitimate business purposes (scholarship administration)

  • Exercise of free speech rights

  • Research purposes (when deletion would impair the research)

  • Internal uses reasonably aligned with your expectations

Right to Opt-Out

You have the right to opt-out of the sale of personal information. Note: We do not sell personal information to third parties for monetary consideration.

Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights by:

  • Denying goods or services

  • Charging different prices for goods or services

  • Providing different levels of quality

  • Suggesting you may receive different pricing or quality

Authorized Agents

You may designate an authorized agent to make CCPA requests on your behalf. We may require proof of authorization and verification of your identity.

Response Timeframes

  • We will acknowledge receipt of your request within 10 business days

  • We will respond to your request within 45 calendar days

  • We may extend this period by an additional 45 days with proper notice

To exercise these rights, contact us at info@fletchfoundation.org.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes:

  • We will post the updated Privacy Policy on our website

  • We will update the "Effective Date" at the top of this policy

  • For material changes, we will provide additional notice through email or website notifications

  • Your continued use of our services after changes constitutes acceptance of the updated policy

16. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Fletch Scholarship Foundation
Email: info@fletchfoundation.org
Subject Line: Privacy Policy Inquiry

For specific privacy requests, please include:

  • Your full name and contact information

  • A detailed description of your request

  • Any relevant account information or reference numbers

  • Verification of your identity (as required for security)

We will respond to your inquiry within 30 days of receipt.

17. Effective Date and Compliance

This Privacy Policy is effective as of the date first set forth above and applies to all information collected by Fletch Scholarship Foundation on or after this date.

We are committed to maintaining compliance with applicable privacy laws and regulations, including:

  • Family Educational Rights and Privacy Act (FERPA): Protection of educational records and student privacy rights

  • General Data Protection Regulation (GDPR): Comprehensive data protection for EU residents

  • California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): Enhanced privacy rights for California residents

  • Children's Online Privacy Protection Act (COPPA): Special protections for children under 13, with enhanced protections for users under 18

  • IRS regulations for 501(c)(3) organizations: Donor privacy and tax-exempt organization requirements