Introduction and Scope
To contact us, please see the Contact Information section below.
Acknowledgement and Consent
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific 2 individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”). Personal Information also does not include publicly available information about you, whether or not such publicly available information has been de-identified.
Individuals under the Age of 13
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 13 or knowingly allow such persons to register for or participate in our Services. The minimum age of 13 is clearly marked on the registration section and users must affirmatively verify they are 13 or older in order to successfully register. If you are under 13, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will use commercially reasonable efforts to delete all Personal Information other than email addresses from our database. Please contact us if you have any concerns.
Personal Information We Collect
We collect several categories of Personal Information from and about you as summarized in the following:
For All Users
Category : Identifiers
Specific Items of Personal Information: first and last name; email address
Category : Demographic
Specific Items of Personal Information: birth year (13 or older); city and state of residence
Category : Internet or other electronic network activity
Specific Items of Personal Information: browsing, session, interaction, and search history related to our Website; Internet Protocol (or IP) address, protocol, and sequence information; cookies; browser language and type; material and pages viewed; time and date of access to the Services; number of clicks per visit; operating system and platform, device type and 3 device identifiers;
Category : Geolocation
Specific Items of Personal Information: location associated with IP address
Category : Educational Information
Specific Items of Personal Information: school name and location; school graduation year; records pertaining to challenges and contests and honorary certifications
Category : Other information
Specific Items of Personal Information: self-reported information pertaining to website bio, mentor applications, and honorary certifications; video/audio recordings of research and judging sessions
For Mentors Only
Category : Current and Previous work experience and credentials
Specific Items of Personal Information: Information pertaining to your work experience and or profession including current place of work, education, and experience background
How We Collect Personal Information and from What Sources
Information You Provide Us. The Personal Information we collect through our Website or our Service Providers may be obtained as part of the following:
Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, participating in our Services, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, reporting a problem with our Website, products, or Services, or otherwise communicating with us.
Records and copies of your correspondence (including email addresses), if you contact us
Registering for a session
Applying to become a mentor
Hosting a session
Your responses to surveys that we or our service providers might ask you to complete for research purposes
Your search queries on the Website
When communicating with customer support
When making a donation via our Website
Third party websites (e.g., websites that share information with us)
Social media companies
Other service providers
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
Behavioral Tracking: We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Website.
These cookies are essential to allow you to browse our Website and use its functions. Without them, services would not be able to work.
These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Local Storage Cookies. Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.
Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Google, etc.), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results from service providers like identity verification services for our risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships. Other examples of such providers include, but are not limited to, backend processing and automation, certification, video hosting platform, email management, authentication, form processing, website usage tracking, managing calendar invites and scheduling, and database hosting and management.
Some content or applications on the Website are served by third parties, including content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first- party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly. Learn more about how to opt-out of third-party tracking mechanisms.
You also may submit information, such as comments, feedback, etc., (collectively, “Content”) to be posted on public areas of the Website, or transmitted to other users of the Website or third parties (“posted”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. By posting any Content or submitting Content for posting you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, redact, modify, aggregate, summarize, adapt, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”).
The Right to Use you grant us above also extends to any Content that you have posted to our Facebook or other social media account pages, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. The term “Use”includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the content.
If we permit you to post Content, by posting any Content, or submitting Content for posting, you agree to with the following “User Content Posting Guidelines”:
To the extent our Website contains areas where you can post or submit to be posted such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post or submit any Content that:
Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
Promotes or provides instructional information about illegal or illicit activities;
Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
Includes personal or identifying information about another person without that person's explicit consent, or is doxxing;
Contains software code of any kind, including, but not limited to, code that contain viruses, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person's computer or network or telecommunications equipment;
Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.
You may not attempt to gain unauthorized access to our computer systems or those of any our service providers or third parties, or engage in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of, the Website or our services. We reserve the right, but do not undertake the obligation, to refuse to post or remove any posted Content from our Website for violation of these rules or for any other reason, and to refuse to accept any future postings by you.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
To present our Website and its contents to you.
To provide you with information and respond to your questions on products or Services that you request from us and information on new products and services, and features or offers that we believe will be of interest to you.
To provide you with the products, services, or information that you have requested.
To provide you with notices about your account.
To notify you about information regarding or changes to our Website, our policies, terms, or any products or Services we offer or provide, or regarding your account.
To process your account application and any changes to your account information.
To process Personal Information or other information that you submit through to us.
To allow you to participate in interactive features on our Website.
To contact you about our own and third-parties’ products and services that may be of interest to you.
To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.
To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.
For internal purposes, such as Website and system administration or internal audits and reviews.
For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
To operate, maintain, and provide to you the features and functionality of the Services.
To provide statistics about the usage levels of the Website and other related information to our service providers.
To notify you of data privacy incidents or provide you with legally required information.
To request your participation in ratings, reviews, surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
To determine eligibility for membership, credentials, designations, or volunteer opportunities.
To evaluate your performance on continued learning courses and assist you in the tracking of your progress.
For event registration, scheduling, event attendance, administration and related purposes.
To fulfill any other purpose for which you provide Personal Information.
In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.
How We Share Your Personal Information
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:
School or educational partners with an interest in viewing student solo or group submissions for assigning school credit or other educational or district purposes
Industry partners who help with mentoring and competition judging functions
Data storage or hosting providers for the secure storage and transmission of your data.
Database and software service providers for the management and tracking of your data.
Volunteers for peer review, session review, and mentoring.
Technology providers who assist in the development and management of our Website.
Identity management providers for authentication purposes.
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants.
Our volunteers or committee members who perform various functions on our behalf.
We may disclose aggregated information (such as # of Challenges completed, # of logins weekly, etc) to our funders, research partners, and educational organizations for the purposes of educational research and/or product improvement.
Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, processing payments and awards redemptions, and screening checks. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we 10 will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
We do not disclose or share your Personal Information, with any third parties (e.g., colleges and universities) for which we receive any monetary or other valuable consideration without first obtaining your explicit consent.
Disclosure of De-Identified Personal Information: We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non- Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose. We may disclose, sell, rent, etc., your De-Identified Personal Information to third parties and we may receive valuable consideration for doing so.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
We retain your information after you request such deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. We may retain De-Identified Personal Information for as long as we deem appropriate. For example, if we process your donation payments, we will retain this data for longer periods of time as required for tax or accounting purposes. Additional examples of specific reasons we would retain some data for longer periods of time include:
Our contractual and business relationships with you.
Security, fraud and abuse prevention – i.e., to protect you, other people, and us from fraud, abuse, and unauthorized access.
Financial recordkeeping – when you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute investigation and resolution, and compliance with tax, anti-money laundering, and other financial regulations.
Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Video Storage and Retention. We store video recordings on our video hosting service provider’s servers. We currently use Microsoft Teams, and Zoom and their “Zoom for Education” platform. To learn more, read the Zoom Retention Policy.
You can delete your account or request that we delete your account by contacting us.
Even if you delete your account, keep in mind that the deletion by our Service Providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. We may retain De-Identified Personal Information for as long as we deem appropriate.
What Information You Can Access, Change, or Delete
Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as bio, country, and languages. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding our Service, our Website, your personal information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.