Effective Date: February 1, 2020

Welcome to the Compass Working Capital, Inc. (“Compass,” "we" or "us") National Network platform known as FSS Link and located at the www.compassfsslink.org website (the “FSS Link”). FSS Link is intended to facilitate connections and learning among Family Self-Sufficiency (“FSS”) program practitioners from around the country to strengthen the impact and reach of FSS programs. FSS Link is owned and operated by Compass. 

At Compass, we value our relationship of trust and confidence with our partners. We take our responsibility to protect the personal information you share with us very seriously. This Privacy Policy applies to information we collect when you visit FSS Link. It explains the information we collect on FSS Link and how we use your information. By visiting and using FSS Link you consent to our collection and use of your information as described in this Privacy Policy. 

1.  Information We Collect and Why We Collect It

We collect your personally identifiable information only when necessary to provide you with our services, and we keep it only for as long as necessary to fulfill our program requirements or comply with applicable law. We collect information in three ways: when you provide it to us, automatically by us, and from others. 

(A) Information You Provide to Us

  • Contact Information. When you sign up for access to FSS Link, we collect contact information, such as your name, your organization’s name, e-mail address, and mailing address. We also keep track of your role and state if you provide it to us in the My Account section of your profile.  
  • Use Information. When you use FSS Link we will keep track of your use of the site’s content, including the materials you download or edit, discussion or forum contributions and other user activities such as the length of time you spend on the site generally, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service.
  • Periodic Surveys. As an FSS Link member, you may occasionally receive user surveys from us to help us improve your experience. We will keep, track, and may share your responses to these surveys in aggregate, de-identified format.
  • Credit Card Information. If you purchase a Pro or All Access membership to FSS Link, your name, credit or debit card information, phone and mobile number, mailing address, e-mail address, and billing address are collected by third party vendors with whom Compass works, in order to complete these transaction(s).  Compass does not receive, review or retain your credit card information, and our third-party credit card processor only retains this data for as long as necessary to complete the applicable transaction for which you provide your credit card data.

(B) Information We Collect Automatically

  • Usage Information. We may also collect general information about your use of FSS Link, such as your computer IP address, unique mobile device identifier, browser type, ISP or carrier name, and pages you access on our website. 
  • Social Media Information. If you log into or register using your LinkedIn or Google account, you must enter your LinkedIn or Google email address and password. By logging in through LinkedIn or Google, you are granting us access to your LinkedIn feed. When you “like” us on Facebook or "follow" us on or through other social media sites or services, we will also collect your name and e-mail address from those services.  If you submit information through social media sites, your information is governed by their privacy policies, and information you share might be seen by the general public.
  • Information from Cookies. Using “cookies,” we may collect information about your use of FSS Link, such as your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit FSS Link, and the referring URL, or the webpage that led you to FSS Link. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information.  Some cookies allow us to make it easier for you to navigate FSS Link and services, while others are used to enable a faster log-in process or to allow us to track your activities on our website. 
    • Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our website who disable cookies will be able to browse certain areas of FSS Link, but some features may not function.
  • Tracking Technology and Do-Not-Track Requests. We do not use any technology that tracks your online activities over time and across third-party web sites, nor do we plan on doing so in the future. Therefore, we offer no response to Do-Not-Track requests transmitted by web browser. 

We encourage you to review the privacy statements of websites you choose to link to from FSS Link so that you can understand how those websites collect, use and share your information. Compass is not responsible for the privacy statements or other content on websites outside of FSS Link.

(C)  Information We Collect from Others

We also may collect your personal information from others, such as third-party providers and industry groups that might also have your contact details. Generally, this information is limited to your name and email address. 

2.  How We Use Your Personal Information

We collect and use your personal information to provide you with access to FSS Link, to communicate with you regarding your use and membership, and/or to send you updates, newsletters, surveys and other communications that may be of interest to you. We may also use your personal information to improve FSS Link’s functionality, engage in research relating to FSS Link, personalize your experience, track usage of FSS Link, provide customer support, message you, and comply with legal obligations. From time to time, we may contact you on behalf of external service partners about a particular service or program that may be of interest to you. In those cases, your personally identifiable information (e-mail, name, address, telephone number) is not shared with third parties. 

When you sign up for any FSS Link membership, you are giving us permission to include your name, organization, role, and state in our searchable Member Directory. This Directory is only available to Pro and All Access FSS Link members. 

By using the FSS Link discussion board, you are opting to receive messages from other FSS Link users and you also give us permission to display your name, organization, and title on any posts where you participate or publish new content.

3.  How We Share Information

We do not sell, rent or share your personal information with third parties for their own marketing purposes without your consent. We may share your personal information with third parties in the following limited ways: 

  • Employees and Consultants. We may disclose information about you to our employees and consultants that need to know the information in order to help us deliver our services or to process the information for us. We require our employees and consultants to safeguard personal information that we share with them.
  • Third Party Vendors. We also may share data about you with our third-party vendors and services providers. These vendors help us provide services to you, such as hosting FSS Link, or providing data analysis and research to help us evaluate the impact of our programs. All such third parties are prohibited from using your personal information except to provide these services to Compass (and/or to you, as the case may be), and they are required to make privacy commitments to us before we share information with them.  Neither Compass, nor our third party service providers retain your credit card data for any reason once your transaction has been processed. 
  • With Your Consent. We may share and disclose information with your consent or as you request. 
  • Aggregated and De-Identified Information. We may share information that has been aggregated and de-identified so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the number of FSS Link members, partners and usage.
  • Compliance and Protection. We reserve the right to disclose your personal information, without notice, if required by law or when we believe in good faith that disclosure is necessary to comply with law; defend against legal claims; or to protect the rights, property or safety of our organization, other users of the site, or the public; or to enforce our Terms of Service.
  • Business Transfers. We may transfer the information we have collected from you to another entity in the event that we are acquired by or merge with another organization, or if substantially all of our assets are transferred to another organization, or if, as part of a bankruptcy or related proceeding, our assets are transferred to another entity or organization.

By signing up for any FSS Link membership, you also give us permission to share your organization name and other data, including your personal information and All Access program data, in aggregate in the following ways:

  • Monthly FSS Link Newsletter
  • FSS Link Member’s Page
  • With funders and other FSS stakeholders
  • For FSS Link marketing purposes

4.  Credit Card Processing

When you register with us to become a Member or make any other purchase through FSS Link, Compass uses Stripe to process your credit card transactions. Stripe’s privacy policy will apply to the information you provide on FSS Link. You must be 18 or older to authorize a purchase through FSS Link.  You agree to pay the fees and any other charges incurred in connection with your username and password (including any applicable taxes) at the rates in effect when the charges were incurred. All fees and charges are nonrefundable, except in instances where we are unable or unwilling to provide the requested services. We will never ask for your credit card information via email, text message or any other online service. If someone contacts you asking for credit card information claiming to be from FSS Link, please contact us directly at [email protected].

5.  Information You Share Publicly

Compass maintains social media pages that Members of those pages may post in.  Furthermore,  FSS Link contains a discussion board, messaging tools, personal web pages or profiles, forums, bulletin boards and other interactive features (collectively, "Interactive Services") that allow members to post, submit, publish, display or transmit to other members or users (hereinafter, "post") content or materials (collectively, "User Contributions") on or through FSS Link. User Contributions may be used, distributed and published by Compass and viewed by all users of FSS Link. When you use our social media pages and our Interactive Services you may share comments, reviews, stories, materials you have created or other information.  If you choose to submit this type of information to us, that information may be available to the general public and/or to staff members, contractors and other users of FSS Link. If you write a comment on our Facebook or other social media pages, remember that this information is governed by Facebook or the other website’s privacy policy and this information may be viewed by the general public. You understand that we do not guarantee any confidentiality with respect to any User Contributions. All User Contributions must comply with our Terms of Service.

6.  Security of Your Personal Information

We have implemented commercially reasonable precautions, including reasonable and appropriate technical and administrative measures, to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

7.  Access To My Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the website for a period of time.  You may also update your information by contacting us at [email protected] .

8.  What Choices Do I Have Regarding Use of My Personal Information?

We respect your privacy and give you an opportunity to opt-out of receiving messages from us. You may stop receiving our monthly newsletter and other email updates from us by clicking the unsubscribe link at the bottom of the email. You may also adjust the frequency at which you receive updates about new activity on FSS Link by editing your preferences in the My Account section of your profile. You can also reach out to us directly at [email protected] to change your preferences. If you opt out of any of these messages, we may still send you messages relating to your FSS Link account and legal notices.

9.  Children’s Privacy

Compass does not intentionally collect or maintain information on any person under 13 years of age. We ask that children do not submit information to us. In the event that we learn that we have collected personal from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at [email protected].

10.  Changes to this Policy

We reserve the right to change and update this Privacy Policy at our sole discretion. If we change this Privacy Policy, we will inform you by posting a notice on FSS Link. 

11. Contact Information

We welcome your questions or comments regarding this Privacy Policy. You can contact us at Compass Working Capital, 89 South Street, Suite 804, Boston, MA 02111 - Email: [email protected]. Phone: (617) 790-0810.