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Privacy Policy

Effective date: May 25, 2026

1. Who We Are

This Privacy Policy describes how the Rotary Club of Pohnpei(“we,” “our,” or “the Club”), a nonprofit civic organization based in Pohnpei, Federated States of Micronesia, collects, uses, and protects personal information submitted through this online scholarship portal (“Portal”).

The Portal facilitates applications for the Rotary Scholarship and the Vital Scholarship programs. No commercial transactions occur on this Portal.

Contact: Rotary Club of Pohnpei, Pohnpei State, FSM. For privacy inquiries: [email protected]

2. Information We Collect

We collect the following categories of information when you create an account and submit an application:

Account Information

  • Full name
  • Email address
  • Encrypted password (we never store your password in plain text)

Personal Information

  • Date of birth
  • Phone number
  • Mailing address
  • FSM passport number
  • FSM citizenship status

Academic Information

  • Educational institution name
  • Field of study and academic year
  • Expected graduation date
  • Grade Point Average (GPA) and GPA scale
  • SAT score (optional)
  • Academic honors and awards
  • Community service activities

Financial Information

  • Estimated educational expenses (tuition, room and board, books, other)
  • Family financial contribution
  • Other scholarship or grant funding received
  • Personal savings and other income sources

Uploaded Documents

  • Letters of recommendation (PDF)
  • Personal essay
  • Proof of enrollment or acceptance letter
  • Academic transcript
  • FSM passport copy
  • University Financial Resources Form

Award Disbursement Information (awardees only)

  • Bank account details or mailing address for fund transfer (collected directly from confirmed awardees — not through the Portal)

Technical Information

  • Login session data (stored in an encrypted browser cookie)
  • Application activity log (status changes, review events)
  • IP address and browser type (captured automatically in server logs)

3. How We Use Your Information

We use the information collected for two distinct purposes, each with its own legal basis:

Scholarship Administration (required)

The following uses are necessary to operate the scholarship program. They apply to all registered accounts regardless of any additional preferences you select:

  • To evaluate scholarship applications and determine eligibility
  • To allow committee members to score and review applications
  • To communicate with applicants about their application status
  • To notify award recipients, collect disbursement details, and process scholarship distributions
  • To publicly announce the names, institutions, and award amounts of scholarship recipients via the Club’s Facebook page, local press (Kpress), and — for Vital Scholarship awardees — the Vital Energy FSM website
  • To maintain accurate records of past awards
  • To detect and prevent fraudulent applications

Club Communications (optional — consent-based)

With your separate, explicit consent at registration, we may also use your email address to send you communications from the Rotary Club of Pohnpei about club activities, initiatives, fundraising events, and community programs that are not directly related to your scholarship application. Examples include:

  • Rotary Club event invitations and announcements
  • Community fundraising campaigns
  • Club newsletters and updates
  • Volunteer opportunities and club initiatives

This use is entirely optional. You may opt in at registration or opt out at any time by emailing [email protected] with “Unsubscribe” in the subject line. Declining or withdrawing consent for club communications has no effect on your scholarship application.

We do not sell, rent, or trade your personal information to any third party. We do not use your information for commercial advertising or profiling.

4. Information Sharing

Your information is shared only in these limited circumstances:

Scholarship Review Committee

Committee members assigned to a scholarship cycle will have access to application information (academic, financial, essays, and documents) to perform their scoring duties. Committee members are bound by confidentiality obligations.

Vital Energy FSM

For the Vital Scholarship program, relevant application information may be shared with Vital Energy FSM as a co-sponsoring organization for award decisions.

Email Service Provider (Brevo)

We use Brevo (Sendinblue SAS) to send transactional emails (account confirmations, status updates). Your email address and name are transmitted to Brevo for this purpose only. Brevo’s privacy policy is available at brevo.com.

Public Announcement of Award Recipients

If you receive a scholarship award, your name, educational institution, field of study, and award amountmay be announced publicly. Announcements are made via the Club’s Facebook page, local press including Kpress, and — for Vital Scholarship awardees — the Vital Energy FSM website. This is consistent with the public-interest and educational purpose of the program. If you have objections to a specific channel, please notify the Club in writing before accepting your award.

Legal Requirements

We may disclose information if required by applicable law, court order, or governmental authority.

5. Sensitive Data and Financial Privacy (GLBA)

This Portal collects certain categories of sensitive personal data, including passport numbers and financial information. This information is required solely to verify applicant identity and assess financial need for scholarship purposes.

Financial information collected on this Portal (including expenses, income, family contributions, and other funding sources) is handled in accordance with principles established by the U.S. Gramm-Leach-Bliley Act (GLBA). This means we maintain administrative, technical, and physical safeguards to protect your financial information, and we do not use it for any purpose other than scholarship eligibility evaluation. We do not sell or share your financial data for marketing or commercial purposes.

We apply additional care to all sensitive data:

  • Passport numbers and financial data are accessible only to authorized committee members and administrators
  • All data is transmitted over HTTPS (TLS 1.2+)
  • Database access is restricted to the application server — no public access
  • Passwords are stored using bcrypt hashing and are never recoverable in plain text
  • Daily encrypted database backups are retained for 30 days

6. Academic Records (FERPA Context)

You may submit academic transcripts and records as part of your application. These are submitted voluntarily by you, the applicant, and are not obtained directly from your educational institution. The Family Educational Rights and Privacy Act (FERPA) protects your right to control access to your educational records held by your institution. By uploading a transcript to this Portal, you are consenting to share that record with the Rotary Club of Pohnpei for scholarship evaluation purposes only.

7. Children and Minimum Age

This Portal is intended for individuals who are at least 18 years of age or who are currently enrolled or accepted in a recognized post-secondary institution. We do not knowingly collect personal information from children under the age of 13. If we become aware that a child under 13 has submitted information through this Portal, we will delete it promptly.

8. Data Retention

We retain your personal information as follows:

  • Active applications: Retained for the duration of the scholarship cycle and the subsequent annual cycle for comparison and audit purposes.
  • Award records:Retained indefinitely as part of the Club’s permanent scholarship records.
  • Unsuccessful applications: Retained for up to three (3) years following the conclusion of the relevant scholarship cycle, then securely deleted.
  • Account data: Retained while your account is active. If you request account deletion and have no awarded scholarship, your account and associated data will be deleted within 90 days.

9. Your Rights and Choices

You have the following rights regarding your personal information:

  • Access: You may log in at any time to view the information stored in your application. You may also request a complete copy of your data in a portable format (CSV or PDF).
  • Correction: You may update your account information and application sections while the application cycle is open.
  • Deletion: You may request deletion of your account and application data by emailing us. Note that we may retain records required for legal or audit purposes. Deletion is completed within 30 days for production systems and within 90 days including encrypted backups.
  • Withdraw consent: You may withdraw your application at any time before submission by contacting us. Submitted applications cannot be withdrawn once they enter the review process.

EU Residents (GDPR): If you are located in the European Union, you additionally have the right to data portability, the right to restrict processing, and the right to object to processing. You also have the right to lodge a complaint with your local supervisory authority.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Cookies and Sessions

This Portal uses a single, essential session cookie to keep you logged in. This cookie is encrypted, stored only on your device, and is deleted when you sign out or when the session expires (sessions last up to 8 hours). We do not use advertising cookies, tracking pixels, analytics services, or any third-party cookies.

11. Data Security

We implement reasonable technical and organizational measures to protect your personal information, including HTTPS encryption in transit, encrypted sessions, bcrypt password hashing, role-based access controls, and daily encrypted database backups. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

In the event of a data breach that affects your personal information, we will notify affected individuals and relevant authorities as required by applicable law.

12. International Data Transfers

This Portal is operated from Pohnpei, FSM. If you are applying from outside FSM, your personal information will be transferred to and stored in systems located in FSM and, for email delivery purposes, processed by Brevo (located in the European Union). By using this Portal, you consent to this transfer.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised effective date. Continued use of the Portal after changes are posted constitutes acceptance of the revised policy. For significant changes, we will notify registered users by email.

14. Contact Us

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

Rotary Club of Pohnpei
Pohnpei State, Federated States of Micronesia
Email: [email protected]
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