1. Introduction and Scope of this Policy

Commitment to the Trust and Confidentiality of Our Community

The EUPHOTIC FOUNDATION (referred to herein as “the Foundation,” “we,” “us,” or “our”) is profoundly committed to protecting the privacy and security of the personal data entrusted to us by our students, participants, volunteers, donors, community partners, and website visitors (collectively, “Users” or “you”). Our mission, focused on empowering individuals through the transformative blend of culinary and fine arts, is built upon a foundation of trust, and maintaining the confidentiality of your personal information is paramount to upholding that trust. This comprehensive Privacy Policy outlines the types of personal data we collect, the methods we use for collection, the specific purposes for which we process this information, the duration for which we retain it, and your legal rights concerning your data. This policy is designed to be fully compliant with applicable data protection laws, including, but not limited to, global standards such as the European Union’s General Data Protection Regulation (GDPR) and relevant US state-level privacy legislation, reflecting our operational scope and digital outreach. We urge all users to read this document carefully and thoroughly to understand our practices regarding your personal data and how we will treat it. The policies and procedures detailed herein apply to all data processing activities across the Foundation, including those conducted through our website (eupfo.site), physical facility operations, enrollment systems, communication platforms, and fundraising initiatives. By engaging with the EUPHOTIC FOUNDATION, whether through enrolling in a program, volunteering your time, or simply visiting our digital properties, you acknowledge and agree to the data practices described in this policy, affirming your understanding of how your information contributes to the fulfillment of our creative and educational mission while remaining protected by our rigorous privacy protocols.

2. Data Controller and Contact Information

Accountability and Openness Regarding Your Personal Data

The EUPHOTIC FOUNDATION, a non-profit organization located in the United States, acts as the Data Controller responsible for the processing of your personal data as described in this policy, determining the means and purposes of the processing activity to further our mission. Our commitment to transparency requires that we provide you with readily accessible and complete contact information should you have any questions, concerns, or requests regarding this Privacy Policy, the data we hold about you, or your exercise of your privacy rights. For all general inquiries, including requests for clarification on data handling procedures or for accessing or amending your non-sensitive personal profile information, we recommend reaching out to our dedicated administrative office via email, which ensures a prompt and fully documented interaction. For matters requiring advanced attention, particularly those involving data breach reporting, formal data subject rights requests (such as the right to erasure), or complex compliance questions, please mark your correspondence clearly for the attention of the Data Privacy Officer (DPO) and utilize the contact details provided below. Our DPO is specifically tasked with overseeing our data protection strategy, ensuring that all processing activities across the Foundation, from the art studio enrollment records to the culinary kitchen’s allergy logs, adhere strictly to this policy and all applicable legal mandates.

Data Controller Identification and Contact Details:

• Organization Name: EUPHOTIC FOUNDATION
• Physical Address: 155 12TH ST, SAN FRANCISCO, CA 94103, USA
• Email for Privacy Matters: info@eupfo.site (Please include “ATTN: Data Privacy Officer” in the subject line for formal requests)

3. Information We Collect and Methods of Collection

A Comprehensive Overview of Data Collected to Support Our Educational Mission

We collect various categories of personal information to effectively operate our programs, ensure the safety and success of our participants, and engage with our community. This collection is necessary for several purposes, ranging from the secure enrollment of a minor in a Youth Program to the precise allocation of philanthropic funds donated by an individual. The personal data we collect falls into the following detailed categories, often obtained through online registration forms, direct communication with staff, physical sign-up sheets, and automated technology interactions on our website.

3.1. Identity and Enrollment Data (Directly Provided)

This category encompasses the fundamental information required to identify and register an individual for any of our Fine Arts, Culinary Arts, or Integrated Arts programs. It includes, but is not limited to, the participant’s full legal name, date of birth (essential for age-appropriate program placement and for verifying legal capacity for parental consent regarding minors), physical mailing address, primary contact telephone number, and active personal or professional email address. For student enrollment, we also collect specific program history data, such as previous enrollment dates, certification levels achieved, and any relevant student ID numbers generated by our internal administrative systems. This information is meticulously collected during the initial registration process and is essential for contract performance and service delivery.

3.2. Financial and Transaction Data (Directly Provided)

When you enroll in a tuition-based program or make a philanthropic donation to the Foundation, we collect financial information necessary to process the transaction securely. This data includes payment card details (which are immediately tokenized and processed by a third-party, PCI-compliant payment processor and not stored directly on our servers), bank account information for automated clearing house (ACH) transfers, billing address, and transaction history. For donors and sponsors, we track the amount, frequency, and designated purpose of their contributions to manage our financial records and fulfill legal reporting requirements for non-profit organizations.

3.3. Health and Safety Data (Sensitive Category)

Given the inherent physical risks associated with both professional kitchen environments (knife safety, heat) and art studios (chemical handling, dust exposure), and our dedication to participant well-being, we collect limited, sensitive personal information specifically related to health and safety. This data is collected solely for protective measures and includes known severe food allergies (e.g., peanut, gluten, shellfish), existing medical conditions (e.g., severe asthma, diabetes) that might require emergency attention or special accommodation during a class, and emergency contact details (name and phone number of a person not enrolled in the program). This information is highly restricted, stored separately using enhanced encryption, and accessed only by authorized staff (e.g., Chef-instructors, Youth Program leaders, and Executive Management) on a strict need-to-know basis.

3.4. Educational and Programmatic Data (Directly Generated)

This category comprises data generated throughout a participant’s tenure with the Foundation, providing a detailed record of their educational journey and progress within the curriculum. It includes class attendance records, assignment submission grades, formal and informal performance evaluations (such as critique notes from instructors and peers), completed portfolios, and evidence of certification completion (e.g., Food Handler’s Permit status). For students in professional tracks, we also maintain a record of their career aspirations and mentorship pairings to facilitate job placements and alumni network engagement.

3.5. Marketing and Communication Data (Through Interaction)

We collect data related to your preferences for receiving marketing communications from us, including opt-in or opt-out status for our newsletter, updates on new program launches, and invitations to exclusive donor events or public showcases. This information also includes details about your interaction with our communications, such as which emails you open, which links you click, and your response history to satisfaction surveys, allowing us to refine the relevance and quality of our outreach efforts in line with our legitimate interest in fundraising and community engagement.

3.6. Technical and Usage Data (Automated Collection)

When you interact with the EUPHOTIC FOUNDATION website (eupfo.site), certain technical data is automatically collected using cookies, server logs, and similar tracking technologies. This includes your Internet Protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and information about how you interact with our website, such as referral sources, pages visited, and the length of your visit. This data is primarily aggregated and anonymized for analytics purposes, helping us optimize website performance and user experience without directly identifying individual users.

4. How We Use the Information (Purposes of Processing)

Aligning Data Use with Mission Fulfillment and Operational Necessity

The EUPHOTIC FOUNDATION uses the personal data we collect solely for purposes that are necessary, legitimate, and directly aligned with delivering our educational programs, maintaining safety, managing our administrative operations, and furthering our non-profit mission. We will only use your personal data when we have a valid legal basis to do so, as further detailed in Section 5.

4.1. Service Delivery and Contract Performance

The primary purpose for processing Identity, Enrollment, and Educational Data is the provision of the specific fine arts, culinary arts, or integrated arts programs for which you have contracted and enrolled. This processing includes managing classroom assignments, tracking academic progress against curriculum benchmarks, scheduling classes and facilities, communicating directly with participants about course material changes or requirements, and issuing final certifications or degrees upon successful completion. For minors, this also extends to communicating essential program updates and achievement milestones with the legally registered parent or guardian, ensuring transparency and collaborative oversight of the child’s educational experience in line with the terms of enrollment.

4.2. Safety and Risk Mitigation (Processing Sensitive Data)

Health and Safety Data (e.g., allergies, medical conditions) is processed strictly for the critical purpose of protecting the vital interests of the data subject—that is, the enrolled student—and for the wider safety of all participants within our high-risk environments (professional kitchens and art studios). This data enables instructors to proactively plan for emergency scenarios, prepare safe food alternatives in cooking classes, ensure proper ventilation is used when specific art materials are handled, and quickly communicate necessary health information to emergency medical services personnel should an incident occur at our facility. Use of this sensitive information is monitored and recorded, and it is never used for any purpose beyond safeguarding the individual.

4.3. Financial and Administrative Management

Financial and Transaction Data is processed to fulfill our contractual obligation to accurately process tuition payments, manage fees, and reconcile refunds or credits. For donors, this data is used to process contributions, issue required tax receipts, and acknowledge philanthropic support transparently. Administrative Data is also used for internal operational purposes, including auditing our financial performance, conducting annual non-profit reporting, and managing our internal human resources and compliance functions, all of which are necessary for the Foundation’s lawful operation and financial solvency.

4.4. Marketing, Fundraising, and Community Engagement

We utilize Marketing and Communication Data, often alongside Identity Data, to pursue our legitimate interest in sustaining and growing the Foundation through strategic fundraising, community outreach, and program marketing. This activity includes sending targeted communications about new program offerings (e.g., a specific Master Class led by a visiting chef), inviting past students and community supporters to our Annual Student Showcases or fundraising galas, and distributing our regular institutional newsletter detailing the positive impact of our programs. You retain the absolute right to opt-out of these communications at any time without affecting your participation in enrolled programs.

4.5. Operational Improvement and Analytics

Technical and Usage Data, primarily in an aggregated and anonymized form, is analyzed to gain insights into website traffic patterns, user navigation efficiency, and the overall performance of our digital infrastructure. This analysis supports our legitimate interest in continuously improving the quality and accessibility of our website and administrative systems, ensuring that we provide an optimal and contemporary digital experience for our global audience without using this generalized data to track or profile individual behavior outside of service provision.

5. Legal Basis for Processing Personal Data

The Justification for Every Data Handling Activity

Under applicable data protection law, particularly GDPR, we must have a valid legal justification, or “legal basis,” for processing your personal data. The EUPHOTIC FOUNDATION relies on the following legal bases for the different types of data processing activities undertaken:

5.1. Performance of a Contract

A significant portion of our data processing, including the use of Identity, Enrollment, Educational, and Financial Data, is necessary for the performance of a contract to which the student or participant is party. This legal basis applies when we process data in order to fulfill our commitment to provide the agreed-upon educational services, such as delivering the curriculum, assessing progress, collecting tuition, and issuing certificates upon successful completion of a program.

5.2. Legitimate Interests

We rely on the legitimate interests of the Foundation for various administrative, marketing, and operational activities, provided that your rights and freedoms do not override those interests. Examples of processing under this basis include: a) utilizing Technical Data for website analytics and security improvements; b) using Identity Data for sending direct marketing communications to existing students about similar programs (unless you opt-out); and c) sharing limited, non-sensitive data with trusted service providers to run our administrative platforms (e.g., cloud storage, email hosting). We conduct a comprehensive Legitimate Interests Assessment (LIA) for any processing activity based on this ground, balancing our needs against your privacy rights.

5.3. Compliance with Legal Obligations

We process certain data categories, including Financial and Transaction Data, to comply with mandatory legal obligations imposed upon us as a US-based non-profit entity. This includes retaining transaction records for tax and accounting purposes (e.g., IRS regulations), responding to lawful requests from government authorities, and adhering to financial reporting standards and internal auditing requirements.

5.4. Consent

Where the processing does not fall under Contract or Legal Obligation, such as sending promotional materials to prospective, non-enrolled individuals, or processing highly specific, non-essential data, we rely on your explicit, freely given, and informed consent. For all photography and video documentation featuring identifiable individuals (used for promotional materials), explicit, revocable consent is always obtained separately from the main enrollment contract, and you have the right to withdraw this consent at any time without detriment to your participation in our educational programs.

5.5. Vital Interests (Sensitive Health Data)

The processing of Health and Safety Data, a sensitive category, relies on the vital interests legal basis. This is narrowly defined and applies only when the processing is necessary to protect the life or physical integrity of the student or participant, particularly in an emergency scenario within the inherently high-risk environments of the kitchen and studio. In non-emergency situations, the explicit consent of the data subject (or parent/guardian) is sought for the specific processing of this sensitive data.

6. Data Sharing, Disclosure, and Third-Party Processors

Transparent and Secure Collaboration with Trusted External Entities

The EUPHOTIC FOUNDATION will never sell, rent, or trade your personal information to external third parties for marketing purposes. We do, however, engage in limited, controlled sharing of data with trusted external partners and service providers who assist us in operating our business and delivering our programs effectively and securely. All third parties with whom we share data are contractually required to maintain the confidentiality and security of the information and are strictly prohibited from using your personal data for any purpose other than providing the contracted services to the Foundation.

6.1. Service Providers and Business Operations

We share necessary data with various third-party service providers who act as data processors on our behalf. These include: a) payment processors to handle tuition and donation transactions securely; b) cloud hosting and data storage providers to maintain our administrative and student databases; c) email service providers to manage our mass communication and newsletter distribution; and d) software vendors who provide our specialized Learning Management System (LMS) used for curriculum delivery and student tracking. In all cases, we only share the minimum personal data required for them to perform their functions, and we establish rigorous Data Processing Agreements (DPAs) to ensure compliance with our security standards.

6.2. Community and Institutional Partners

As part of our commitment to student success and community impact, we may share certain non-sensitive educational and identity data with approved community partners, but only with explicit participant consent. This may include sharing alumni lists with trusted local employers to facilitate job placement and apprenticeship opportunities for graduates of our Culinary Certificate Program, or sharing details of student artwork with galleries or public display venues for exhibition purposes. In all circumstances involving external partners, the participant or the participant’s legal guardian retains the right to opt-out of such sharing.

6.3. Legal and Regulatory Requirements

We reserve the right to disclose your personal information if required to do so by law, court order, or governmental regulation, or if we believe in good faith that such action is necessary to: a) comply with a legal obligation; b) protect and defend the rights or property of the EUPHOTIC FOUNDATION; c) act in urgent circumstances to protect the personal safety of participants, the public, or our staff; or d) protect against legal liability. This disclosure is always executed with careful attention to minimizing the data shared and verifying the legality of the request.

7. Data Security and Confidentiality Measures

Protecting Your Information with Layered, Professional Security Protocols

The security of your personal data is a top organizational priority, reflecting our fundamental commitment to trust. The EUPHOTIC FOUNDATION employs a comprehensive, multi-layered security framework incorporating appropriate technical, physical, and organizational measures designed to prevent unauthorized access, accidental loss, disclosure, alteration, or destruction of your personal information.

7.1. Technical Safeguards

All digital data is protected by industry-standard technical safeguards. This includes the use of Transport Layer Security (TLS) encryption for all data transmitted over our website and enrollment portals, ensuring secure communication between your browser and our servers. Data stored in our databases is protected by sophisticated encryption both at rest and in transit. Access to administrative systems requires multi-factor authentication (MFA) and strong, complex passwords. We employ enterprise-grade firewall protection and intrusion detection systems to monitor and block malicious network activity, and all systems undergo regular vulnerability scanning and penetration testing by certified third-party security experts to proactively identify and address potential weaknesses in our defense posture.

7.2. Physical Safeguards

Our physical facility at 155 12TH ST, SAN FRANCISCO, CA 94103 employs physical security measures to protect the integrity of our hardware and any paper-based records (though digital storage is always preferred). Access to server rooms and administrative offices where data is processed and stored is strictly controlled by key card access systems, monitored video surveillance, and visitor log requirements. Sensitive paper records, such as physical health forms or background check documentation, are stored in locked filing cabinets within secure areas and are subject to restricted access protocols.

7.3. Organizational Safeguards

Our security framework is reinforced by stringent organizational policies and staff training. All EUPHOTIC FOUNDATION employees and volunteers who handle personal data undergo mandatory, comprehensive data privacy and security awareness training upon hiring and annually thereafter, emphasizing the importance of confidentiality and adherence to this policy. Access to personal data is governed by the principle of “least privilege” or “need-to-know,” meaning staff members only have access to the specific data required to perform their direct job functions (e.g., a Fine Arts instructor does not have access to the Culinary kitchen’s allergy records). We maintain strict internal disciplinary procedures for any breach of our data security policies.

8. Data Retention Policy

Minimizing Storage and Ensuring Timely, Secure Disposal

The EUPHOTIC FOUNDATION retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. Our retention periods are determined by a combination of the following factors, designed to minimize the amount of time any identifiable data is held:

8.1. Program and Educational Records

For enrolled students and participants, we retain Identity and Educational Data for a period of up to seven (7) years following the date of the student’s last enrollment or program completion. This extended period is necessary to respond to potential requests for academic verification, provide duplicate certificates, address future alumni association engagement, and comply with standard educational auditing requirements. After this period, identifiable data is either securely destroyed or permanently anonymized for historical and statistical analysis of long-term program impact.

8.2. Financial and Transaction Records

Financial and Transaction Data, including donor records and tuition payment histories, are retained for a minimum period of seven (7) years following the end of the fiscal year in which the transaction occurred. This mandatory retention period aligns with the record-keeping requirements established by the Internal Revenue Service (IRS) and generally accepted non-profit accounting principles.

8.3. Health and Safety Records

Sensitive Health and Safety Data, which is only collected for the protection of vital interests, is subject to the strictest retention controls. This data is reviewed at the end of every program year or semester of enrollment and is securely destroyed or deleted from all active systems within ninety (90) days of the student’s last attendance, unless the individual is continuously enrolled or a longer retention period is specifically required by law or explicit medical necessity documented with the Foundation.

8.4. Marketing and Prospect Data

Marketing and Communication Data for non-enrolled prospects is retained only until the individual exercises their right to opt-out or for a maximum of two (2) years of documented inactivity in response to our communications, after which the data is deleted or moved to a suppression list to prevent future unsolicited contact.

9. Your Data Protection Rights

Empowering You with Control Over Your Personal Information

Depending on your jurisdiction and the legal basis for processing your data, you are afforded several rights concerning your personal data. The EUPHOTIC FOUNDATION is dedicated to facilitating the exercise of these rights, which we outline below. To exercise any of these rights, please submit a formal request, marked for the attention of the Data Privacy Officer, to info@eupfo.site. We will require verification of your identity to process your request securely and accurately.

9.1. Right to Access (The Right to Know)

You have the right to request confirmation as to whether or not we are processing your personal data, and where that is the case, you have the right to access a copy of the personal data we hold about you, along with detailed information regarding the purposes of the processing, the categories of data concerned, the recipients of the data, and the expected retention period.

9.2. Right to Rectification (Correction)

You have the right to request that the EUPHOTIC FOUNDATION rectify or correct any incomplete or inaccurate personal data we hold about you, whether in your Identity, Enrollment, or Educational Records. Upon receiving a verifiable request, we will take all reasonable steps to update your information accurately and promptly within our administrative systems and, where necessary, inform any third parties to whom the inaccurate data was disclosed.

9.3. Right to Erasure (The Right to Be Forgotten)

You have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This right applies, for example, when the data is no longer necessary for the purpose for which it was collected, or if you withdraw consent and there is no other overriding legal basis for retention. Please note that this right is not absolute and may be subject to exceptions, particularly concerning our legal obligations to retain Financial or Safety Data for a prescribed period.

9.4. Right to Restrict Processing

You have the right to request that we temporarily suspend the processing of your personal data in certain circumstances, such as: a) if you contest the accuracy of the data, allowing us time to verify its accuracy; b) if the processing is unlawful, but you object to erasure and request restriction instead; or c) if we no longer need the data for processing, but you require it for the establishment, exercise, or defense of legal claims.

9.5. Right to Data Portability

You have the right to request that we provide you with a copy of the personal data you have provided to us, processed on the basis of consent or contract, in a structured, commonly used, and machine-readable format (e.g., CSV or JSON), and to transmit that data to another data controller without hindrance from us, where technically feasible.

9.6. Right to Object

You have the right to object to the processing of your personal data where we are relying on a legitimate interest as the legal basis for processing, particularly when that processing involves direct marketing activities (e.g., promotional emails). If you object to processing for direct marketing, we will cease that processing immediately. If you object on other grounds, we will stop processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

9.7. Right to Withdraw Consent

Where the legal basis for our processing is your consent (e.g., for promotional photography or non-essential marketing), you have the absolute right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before you withdrew your consent, but it will mean we cease that specific processing activity moving forward.

10. Children’s Privacy (Youth Programs)

Special Provisions for the Protection of Minor Participants

The EUPHOTIC FOUNDATION is deeply committed to protecting the privacy of children, particularly those enrolled in our Youth Programs (Ages 6-12) and Teen Programs (Ages 13-17). We strictly adhere to the US Children’s Online Privacy Protection Act (COPPA) and similar international standards regarding the collection of personal information from minors.

10.1. Parental Consent Requirement

We do not knowingly collect personal information directly from children under the age of 13 without verifiable parental or guardian consent. All enrollment for minors must be initiated and completed by the parent or legal guardian, who provides all necessary Identity, Enrollment, and Health/Safety Data. The parent or guardian is required to sign a consent form granting permission for the child’s participation and for the limited collection and processing of their personal data necessary for the educational service.

10.2. Limited Data Collection

The data collected from minors is strictly limited to information necessary for program delivery and safety (e.g., name, age, emergency contact, allergy information). We do not require children to disclose more personal information than is reasonably necessary to participate in the program.

10.3. Parental Rights

Parents or legal guardians of children under the age of 18 enrolled in our programs have the right to review the personal information collected from their child, revoke the consent for the collection and use of that information, and request that the child’s information be deleted from our records. Such requests must be submitted to the Data Privacy Officer via the designated email address.

11. International Data Transfers

Ensuring the Security of Data Transferred Across Borders

As an organization located in the United States, all data collected and processed by the EUPHOTIC FOUNDATION will be initially stored on servers located within the United States. If we transfer personal data originating from individuals located within the European Economic Area (EEA) or other jurisdictions with strict data protection laws to a country outside of that jurisdiction (a “third country”), we take all necessary steps to ensure that the data transfer complies with applicable laws and that your personal data receives an adequate level of protection.

11.1. Safeguards for International Transfers

The primary safeguard used for any necessary international transfer of EEA data to our US-based processing systems or to third-party sub-processors is the implementation of Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses impose robust data protection obligations directly on the recipient of the data, ensuring the data remains protected at the high standards mandated by GDPR, even after it has left the EEA.

11.2. Transparency of Processing Location

By engaging with the EUPHOTIC FOUNDATION and providing your data, you acknowledge and understand that your data will be processed and stored in the United States, which may have different data protection laws than your country of residence. We commit to applying the highest standard of protection—as defined by this Policy and relevant comprehensive data protection frameworks—to all data processed, regardless of the user’s geographic origin.

12. Changes to This Privacy Policy

Notification and Transparency Regarding Policy Updates

The EUPHOTIC FOUNDATION reserves the right to update or modify this Privacy Policy periodically to reflect changes in our data processing practices, organizational functions, or evolving legal and regulatory requirements. When we make material changes to this policy, we will notify you through the following means: a) updating the revision date at the top of this document; b) posting a prominent notice on our website homepage for a period of no less than sixty (60) days; and c) for enrolled participants and active community members, sending an email notification summarizing the key changes to the primary email address associated with your enrollment or communication profile. We encourage all Users to review this Privacy Policy frequently to remain informed about how we are protecting the personal information entrusted to us. Continued use of our services or engagement with the Foundation after any notification of changes signifies your acceptance of the updated policy terms.

13. Specific Artistic and Media Clauses

Data Handling Related to Creative Output and Promotion

Given the nature of the EUPHOTIC FOUNDATION’s mission, which inherently involves the creation of visible artistic works and culinary displays, special consideration is given to data in the form of photographs, videos, and documentation of student projects and achievements.

13.1. Work Documentation and Promotion

All enrollment contracts include a provision for the non-commercial and promotional use of student work documentation (photographs of plated dishes, paintings, sculptures, etc.) for use in Foundation brochures, website galleries, and fundraising materials, unless a participant explicitly opts out. Where photographs or videos include the participant’s identifiable likeness, separate, specific media release consent is mandatory and is always revocable upon written request. We commit to using all promotional media respectfully and solely to advance the Foundation’s educational and philanthropic goals.

13.2. Attribution and Intellectual Property

While the documentation of a creative work is data managed by the Foundation, the intellectual property of the work itself generally remains with the student or artist, as governed by their specific enrollment agreement. We will always endeavor to provide accurate artistic attribution (artist name, program level) when displaying student work publicly unless the artist or guardian specifically requests anonymity for privacy reasons.

13.3. Right to Takedown Request

Any participant who has previously granted media consent retains the unequivocal right to request the digital takedown of their identifiable image or the image of their minor child from our public-facing digital properties (website, social media) at any time. We commit to fulfilling all verifiable takedown requests within a reasonable timeframe, not to exceed sixty (60) days from the date of confirmation of the request, recognizing that printed materials already in circulation cannot be recalled.

Policy Last Updated: December 16, 2025