WRO® Privacy Policy

World Robot Olympiad Association Ltd. (WRO®) takes your privacy seriously. As a nonprofit and mission-driven organization, we are compelled to understand who we are serving, how our programs are performing, and make improvements so that we can achieve our goals of making WRO accessible to as many young people around the world as possible. Thus, we need to collect certain personal data from you to ensure we are meeting our organizational goals and responsibilities. This WRO Privacy Policy describes how WRO ("WRO," "our," "we," "us,") collects and processes personal data that users (“user,” “your,” or “you”) provide to us at any of our web sites where this Policy is posted (the “Sites”). This Privacy Policy also applies to personal data which WRO obtains by other means, as described below.

Treatment of Data for Minor Youth Our treatment of youth data is governed by the European Union’s General Data Protection Regulation (GDPR) and the United States Children’s Online Privacy Protection Act (COPPA) It is our policy to gain consent from parents/legal guardians when collecting data on anyone under the age of 18. Youth under the age of 13 are not permitted to create accounts or provide personal data on our Sites. If we learn that we have personal data obtained directly from a child under 13 we will delete that data as soon as possible. If you believe we have collected data on a minor under age 13, notify us per section 17 of this policy and we will delete that data as soon as possible. ________________________________________

1. Agreement to the Policy
By accessing or using any of our Sites, you agree to be bound by all of the Sites’ terms and conditions including this Privacy Policy. If you do not agree to any of the Sites’ terms and conditions or this Privacy Policy, please do not access or use any of our Sites. In the event you believe data was collected without your consent please see section 17 for instructions on how to contact us.

2. What personal data does WRO Collect:
In the instances and for the reasons outlined in sections 4 and 5 of this document, WRO can collect the following personal data categories: Name, mailing address, email address, phone number, date of birth, gender, secondary or emergency contacts, credit card or banking information, passport details (e.g. for VISA applications), images (photos and video) and your Internet Protocol (“IP”) address.

3. How does WRO collect the data:
We collect data when you provide it to us directly or indirectly through a third party and by “cookies” (as described in section 9, below). You may provide certain data to us when you: (a) register for in person or virtual participation in any WRO program or event; (b) apply for, or be nominated for, awards; (c) subscribe to our newsletter; (d) send e-mail messages; (e) submit forms; (f) transmit information by telephone or letter; (g) order products; (h) submit your credit card or other payment information; (i) access certain forms or request information on our Sites; (j) visit other points on the Sites that state that such information is being collected; (k) attend a WRO event; (l) complete a WRO Consent and Release form; (m) complete a survey or evaluation; or (n) make a donation to WRO When you engage in certain activities on any of our Sites, we may ask you to provide data by filling out and submitting an online form. Depending upon the activity, some of the data may be mandatory and some may be voluntary. If you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity.

4. How does WRO use the data:
By entering personal data into WRO Sites or providing it to WRO (directly or indirectly through third parties), you agree to allow WRO to collect and use the data for the following purposes: a. To process registration for and assist with travel to WRO events: We use personal information to register participants, volunteers and judges etc. for WRO events. Personal data including your name, gender, date of birth and passport number may be required to assist you with visa and manage your travel arrangements to events including but not limited to accommodation and local transportation. b. To improve our programs, products and services: WRO uses data to evaluate and improve our programs, understand whom we are serving, assess program impact, report aggregate/de-identified data, monitor growth, improve the delivery of WRO programs, improve our product and service-offerings, customize and improve our Sites’ content, layout, and services, diagnose problems with our servers and software, and administer our Sites, often with the assistance of our vendors. WRO sometimes uses third parties to help implement, manage, and evaluate programs and efforts, and may share personal data with those third parties only for the purposes outlined in this Policy. c. To improve quality and facilitate use of our Sites. WRO may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies, to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of our Sites (for example, to facilitate navigation and the login process, enhance security, and preserve order information between sessions). d. For insurance purposes: WRO is required to collect and share information including name, address, phone number, guardian/parent name, date of birth, and details about the nature of the injurious event and care provided with our insurance company if you are injured while participating in events organized by WRO.

5. How does WRO and its partners use the data:
By entering personal data into WRO Sites or providing it to WRO (directly or indirectly through third parties), you agree to allow WRO and its partners to collect and use the data for the following purposes: a. To register you as a WRO program participant or volunteer. b. To manage events: We use personal data in relation to event registration, badging, volunteer management and general event management. c. To communicate with you: We use personal data to communicate with you about WRO information and related opportunities. d. To conduct marketing, promotional activities, and outreach to support the WRO mission. e. To process transactions: We use personal data to engage in interactions with you including to communicate with you about your registration status, payment of team registration, processing of sponsorship information, event information and to process orders, mail program related materials and items, and to collect registration fees or donations. f. To provide support or other services: We use personal data to provide you with support or other services that you have requested. We may use your data to respond directly to your requests for information including registering for newsletters, registering a WRO team, registering for trainings, professional development or webinars and any other specific requests you make directly of WRO. We may pass your data along to the appropriate partner to respond to your request.

6. How long does WRO retain data:
WRO will retain your data for as long as needed to fulfill the purposes and uses described in this Policy. When we no longer need your data (for example, when an event has been concluded) and there is no need to keep it to comply with our legal obligations or protect our legal rights, we will either delete it from our systems or depersonalize it so we can’t identify you. If you wish to understand how to request your personal data be deleted, please refer to section 14 for more information.

7. How does WRO share data:
WRO does not rent or sell data to others. We share personal data with WRO event organizers, partners, vendors, services providers, and other third parties (collectively, “Service Providers”) who are acting on our behalf to help operate our Sites, handle communications, implement, manage or evaluate WRO programs and events, or complete transactions you request. Except as otherwise provided in this Privacy Policy, WRO will keep your personal data private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with the law or legal process served on us; (b) provide you the products, services and/or information that you may have requested; (c) protect our rights or property; (d) enforce our rights; (e) protect the interests of users of the Site or any other person; (f) operate or conduct maintenance and repair of our equipment; (g) detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law; and/or (h) otherwise comply with applicable laws.

8. How does WRO protect information:
WRO uses technical and organizational measures to protect data including, but not limited to: firewalls, maintaining security patches on external systems, and ensuring that all web connections are over HTTPS. In addition, your personal data resides on a secure server to which only select WRO personnel and Service Providers have secure access.

9. Cookies:
When you use any of our Sites, we may store cookies on your computer in order to facilitate and customize the experience. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your log-in name to welcome you back to a Site. Our cookies: (a) make your use of our Sites easier; (b) make our Sites run more smoothly; (c) track authenticated users visiting our Sites; and (d) help us to maintain secure Sites. You may decline our cookies, but some parts of our Sites may not work properly as a result. You can at any time use your browser setting to delete our cookies from your system. We may use a third party to display information on our Sites. As part of the third-party service, they may place a separate cookie on your computer.

10. Privacy Policies of Third-Party Sites:
This Privacy Policy only applies to WRO. Other sites accessible through our Site have their own privacy policies and data collection use and disclosure practices. Please consult each site’s privacy policy.

11. How you can rectify incorrect information:
Requests in writing should be sent to privacy [at] wro-association [dot] org. Please include your name, address, e-mail address, and/or phone number when you contact us regarding an update or correction to data. We reserve the right to confirm your identity before updating or correcting personal data. We encourage you to promptly update your personal data if it ever changes.

12. How you can object to certain uses of your data:
If you do not wish to receive email from WRO you may “opt-out” of receiving these communications by exercising your right to “opt out” by using the unsubscribe feature in the email or sending us an e-mail at privacy [at] wro-association [dot] org.

13. How you can exercise your right to be forgotten:
You may request that your personal data at WRO be deleted, by emailing privacy [at] wro-association [dot] org. We reserve the right to confirm your identity before taking any action to delete your data. WRO will assess each request to be forgotten on a case-by-case basis to determine the extent to which data can be deleted. WRO will comply with all requests to be forgotten except where WRO has a legal obligation to retain your data.

14. How you can exercise your right to data portability:
You have the right to receive a copy of the personal data you have provided to WRO by emailing privacy [at] wro-association [dot] org.

15. Transfer of data to other countries:
WRO and its programs operate internationally and WRO is registered in Singapore. WRO stores data in Singapore and inside the European Union.When you transfer data to WRO it will be primarily transferred to, stored and processed in one of these locations. WRO may need to share your personal data with WRO partners in other countries in order to carry out the activities specified in this Policy. By submitting your personal data to WRO, through WRO Sites, or in connection with your interactions with WRO offline, you consent to such transfers and to the processing of this information in any country where WRO operates.

16. Changes to this Privacy Policy:
We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, posting the revised Privacy Policy at any of our Sites. You acknowledge and agree that it is your responsibility to review the Site you are using and this Policy periodically, and to be aware of any modifications. Your continued use of a Site after any such modifications will constitute your; (a) acknowledgment of any modified Policy; and (b) agreement to abide and be bound by any modified Policy. To the extent that any modifications to this Policy materially alters how WRO will use information collected under prior version of the Policy, WRO will provide you notice by email using your email on file, and where required by law, will obtain your consent.

17. How to contact us and how to lodge a complaint:
If you have any questions about this Privacy Policy, the practices of any of our Sites, or your dealings with any of our Sites, contact us via email at privacy [at] wro-association [dot] org.