Older Adult Nest Egg Privacy Policy & Conditions of Use

This Privacy Policy and Conditions of Use (“Policy”) applies to use of the Older Adult Nest Egg website located at www.Older Adult Nest Egg.com (“OANE” or the “Website”). OANE collects information from Users, Visit, and Clients (as defined below). This privacy policy for Older Adult Nest Egg specifies the information OANE may collect, permitted uses of the collected information, and security protections for the information. OANE is owned by Wayne State University (“WSU”). Personal information will be retained by OANE only as necessary for the purposes described in this Policy or as required by law.

DEFINITION OF TERMS

Visitors — a Visitor to OANE can access limited informational pages without needing a log-in account. All Users are Visitors, but not all Visitors become Users.
Users — a User creates an account, which allows the User to input information about User and his or her Client into the Website.
Clients — A Client is an individual whose age, gender, educational level, ethnicity, and interview results (“Client Information”) are entered by the User into the Website, which generates a Client ID number and an Interview ID number.

INFORMATION COLLECTED

Visitors

OANE may collect information automatically from a Visitor’s computer or other devices (“Visitor information”). Visitor information includes an IP address, device type, operating system, browser, and pages visited. This information is used to assess OANE website usage and effectiveness, and ease of navigating the site.

If Visitors or Users contact us by email through OANE, we may keep a record of their contact information and correspondence and use their email address and any information provided to respond.

Users

Creating an account on OANE requires a User’s first name, last name, organization, profession, email address and password. WSU will not disclose User information to any third party without the User’s prior consent, except to the extent necessary or appropriate to comply with applicable laws or in legal proceedings where such information is relevant. Users may access, correct and delete their own personal information. By creating an account, Users consent to this Policy.

Registration and Password

Users are responsible for maintaining the confidentiality of their passwords. Passwords should not be shared with third parties as Users are responsible for all uses of their password, whether authorized or not. Users agree to immediately notify WSU of any suspected unauthorized password use.

Collecting Client Information

Users conduct interviews on OANE with their Clients, entering the Client’s data and responses into the Website. Therefore, each User is responsible for securing the permission (verbal or written) of each Client before entering any information and conducting an interview.

In addition, Users are responsible for the accuracy of all information entered into a Client file on OANE. If Users determine that any data on themselves or their Clients is inaccurate, they must correct such information on OANE as soon as possible.

Clients

Users conduct interviews with their Clients, and record the results and other comments into the Website’s form.

Client information entered by Users is limited to age at time of interview, gender, education level, ethnicity, and interview results. OANE generates a Client ID number and an Interview ID number for each interview conducted by that Client. ID numbers are associated with the Client’s age, gender, education level, ethnicity and interview results. Users are responsible for keeping their own offline log if needed to help identify Clients and securing appropriate permissions.

Research

WSU may use data collected from interviews for research or educational purposes. Research data will include only Client age at time of interview, gender, education level, ethnicity, and interview results, and the User who conducted the interview. All protocols for conducting research, collecting data and publishing results shall meet or exceed the standards of Wayne State University’s Institutional Review Board for Human Participant Research.

Access

Users may access their own or their Client’s information and Clients may access their Client Information maintained on OANE in the discretion of WSU. Access may be denied in the following circumstances:

• WSU is required or authorized by law to do so;
• the information relates to existing or anticipated legal proceedings against an individual;
• the granting of access would have an unreasonable impact on the privacy of others;
• to protect the rights and/or property of WSU; or
• the request is frivolous or vexatious.

If access is denied, WSU will explain the reason(s) behind such refusal.

DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION TO THIRD PARTIES

WSU will not voluntarily disclose personally identifiable information to persons outside the site.
WSU will disclose personally identifiable information to third parties only when required by law, such as Michigan’s Freedom of Information Act, or in response to legal processes such as subpoenas and court orders. In no event, however, will a Visitor’s, User’s, or Client’s information be sold to third parties.

COOKIES

OANE may store some information on the computer of a Visitor or User to the site in a file called a “cookie.” A cookie helps OANE recognize a repeat visit, but is not linked to the Visitor’s or User’s identity. Visitors and Users can set their browser to refuse cookies and can delete them after visiting OANE.

TRACKING BEHAVIOR

OANE may use Google Analytics and other technologies to track how Visitors and Users navigate the site.  When it does, this data cannot include personally identifiable information, although it may track a Visitor’s or User’s computer IP address. Although, this information can be shared with Google or the providers of other tracking technologies, it will not be used in Google’s products or other such providers’ products.

SERVER LOGS

OANE’s servers may routinely log information about site visits, including the date, time and length of a visit, and what files the Visitor or User downloaded. This information ensures the smooth running of the site and alerts OANE to potential performance issues and network attacks.

LINKS TO OTHER SITES

OANE may contain links to third party websites. However, OANE does not vouch for the privacy policies of sites linked to its pages; and it encourages Users and Visitors to make themselves aware of other sites’ privacy policies. Other terms and conditions may apply. Wayne State University is not responsible for the content of linked third party websites, or the treatment of personal information on those sites. Additionally, Wayne State University does not recommend or endorse any of the content, including without limitation any hyperlinks to or content found, on third party websites. Linking to third party websites is done at User’s and Visitor’s own risk.

SECURITY PRACTICE

WSU uses best practices and security measures to protect collected information and other data from unauthorized access and damage. It limits the amount and type of information collected to that necessary to record and tally interview results. WSU undertakes to keep all personal information strictly secure and confidential through technology safeguards available through its host servers at Go Daddy Operating Company, LLC.

Security Limitations

Unfortunately, no data transmission over the internet or by electronic mail can be guaranteed 100% secure. As a result, WSU cannot warrant the security of any information transmitted to the Website electronically. Go Daddy Operating Company, LLC, which hosts OANE, transfers data under the Privacy Shield Framework and is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. Go Daddy Operating Company, LLC may sometimes be required to disclose personal data in response to lawful requests by public authorities, including national security or law enforcement. See Go Daddy Privacy Policy for details.

CHANGES TO THIS POLICY

WSU reserves the right to change, modify, add, update or remove any portions of this Policy at any time, acting in its sole discretion. Changes to this Policy will be posted on OANE and effective immediately upon posting.

CONTACT INFORMATION

Submit questions or comments about this Privacy Policy and Conditions of Use to:

Peter Lichtenberg at p.lichtenberg@wayne.edu or by mail to:

Policy dated 10/16/17