Last updated: July 2019
This privacy notice (the “Privacy Notice”) discloses the privacy practices for Generation: You Employed, Inc. (the “Organization” or “We”). It explains our practices for the collection, use, maintenance, protection, and disclosure of information that we may collect from you or that you may provide when you (1) visit our website: https://www.generation.org/ (the “Website”) or (2) use any of our mobile or desktop applications (“Applications”, and collectively with our Website, the “Platform”).
This Privacy Notice applies to information collected by our Platform. It applies only to information that we collect: (1) on the Website, (2) on any of the Applications, and (3) via electronic message between you and the Platform (e.g. e-mail, text message, etc.). This Privacy Notice does not apply to information collected by: (1) us offline; (2) through any other website operated by the Organization or any third party (including our affiliates), or (3) by any third party (including our affiliates) that may link to or be accessible via the Platform.
This Privacy Notice will notify you of what personal information is collected from you through the Platform, how it is used and with whom it may be shared, as well as how you can correct any inaccuracies in the information. Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you may not elect to use either the Website or any of the Applications; if you do not agree with these policies and practices, you should immediately refrain from using the Website and you should remove and cease to use any of our Applications. This Privacy Notice may change from time to time. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check back periodically for updates.
This Privacy Notice applies only to the Website, Applications, and Platform and the Organization’s collection, use, disclosure, and protection of your data. It does not apply to third party websites, applications, or services.
For the purposes of the EU General Data Protection Regulation, which regulates our use of your personal information, the Organization is considered the Data Controller. Our registered address is 1200 19th Street, NW, Suite 910, Washington, DC 20036, and should you have any comments or questions about how we collect and use your personal information, you should address them to firstname.lastname@example.org.
Types of Information Collected and Processes for Collection
The Organization collects information about you and your use of the Website, Applications, and Platform through various means, including when you provide information to us and when we automatically collect information about you when you access, use, or interact with the Platform. Such processing is necessary to provide you with the Platform.
By using the Website and Platform, you acknowledge that the Organization will use your information in the United States and any other country where the Organization operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to these countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections. Please read on to learn more about how we protect personal information that’s transferred outside of Europe.
The types of information the Organization may collect about you include:
Information You Provide to Us
We process the information you provide to us on the legal basis of the Organization’s legitimate interests in providing the function or service you requested. We may rely on alternate legal bases where appropriate, such as your consent to certain types of processing.
- Account Information: In some instances, certain Platform users may register for an account (a “Platform Account”). We do not require you to register to use our Platform. However if you do register a Platform Account, you will gain access to those areas and features of the Platform that require registration. The Organization will collect certain information about you in connection with your registration for a Platform Account, which may include personal data and other information such as a username and password.
- Post-Graduate Services: In some instances and if you consent to such services, when you have graduated from our programme we may collect certain information (including the title and the compensation details) from you and your employer on your performance and progress so that we can stay in touch and monitor the results of your employment pursuits.
- Correspondence Information: If you apply for a job, sign up, email us, subscribe to our newsletters, distributions, or mailing lists, or donate through the Platform, we may keep your message, postal address, e-mail address, IP address, telephone number, social security number, notes/comments, job title, employer, employer type, employer size, country in which your employer is headquartered, areas of interest, source of referral, and contact information to respond to your requests, provide the requested services, and to provide notifications or other correspondences to you. If you do not want to receive communications from us in the future, please let us know by sending us an e-mail requesting the same to email@example.com or by following the unsubscribe instructions found in any e-mail we send. If you supply us with your postal address on-line, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at firstname.lastname@example.org or by calling our phone number provided above. Please note requests to remove your email address from our lists may take some time to fulfil. We may also still contact you as needed to provide important announcements or notifications regarding the Platform.
- Support Information: You may provide information to us via a support request submitted through the Platform or via email to email@example.com. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for the Organization or our service providers to have access to or use in the future in a manner consistent with this Privacy Notice.
- Form Information: We may use forms to request certain information from you on the Platforms, such as your contact information to assist with contacts or job applications. This information may include personal data.
We may allow visitors to provide information to be published or displayed on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users on the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Gather Through Automated Collection
As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to and uses of the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on the Platform (including your IP address, browsing and navigation patterns, click stream data, device metrics, etc.)
- Information about your computer, mobile device and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to: (1) estimate our audience size and usage patterns, (2) store information about your preferences, allowing us to customize the Platform according to your individual interests, (3) speed up your searches, (4) recognize you when you return to our Website, (5) optimize your user experience across the Platform.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Organization, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Unique Identifiers: When you use or access the Platform, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Websites. Some features of the Platform may not function properly if use or availability of Unique Identifiers is impaired or disabled.
- Analytics Information: We use data analytics to ensure site functionality and improve the Platform. We use mobile analytics software to allow us to understand the functionality of the Platform on your phone. This software may record information such as how often you use the Platform, what happens within the Platform, aggregated usage, performance data, app errors and debugging information, and where the Platform were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
- Log File Information: When you use our Platform, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Platform, for example, when you visit our websites, sign into our Platform, or interact with our email notifications. The Organization uses log file data to provide, understand, and improve our Websites, and to customize the content we show you. The Organization may link this log file to other information the Organization collects about you via the Platform.
- Public Information: The Organization may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Notice, and may be accessed and collected by the Organization. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Platform is neither private, nor confidential. The Organization is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.
Any information that we collect automatically may be paired with personal information about you that we collect from other sources or you provide to us.
We process the information we collect about you automatically on the legal basis of the Organization’s legitimate interests in providing the function or service you requested. We may rely on alternate legal bases where appropriate, such as your consent to certain types of processing.
How We Use Your Information
We use the information we receive about you for the purposes described in this Privacy Notice. We process certain personal data received about you through our Platform on the legal basis of the Organization’s legitimate interests in providing the Platform and its functionality to you. Such processing is necessary for the purposes of the legitimate interests pursued by the Organization or by our Service Providers related to the Platform. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing, or where such processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
We use information that we collect about you or that you provide to us, including any personal information: (1) to present our Platform and its contents to you, including to optimize the use of our Platform and its interface, (2) to provide you with communications, information or services, including those that you request from us, (3) to analyze your use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features (4) to fulfill any other purpose for which you provide it, (5) if you have registered for a Platform Account, to provide you with notices about your account, (6) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, (7) to notify you about changes to our Platform or any services we offer or provide though it, (8) to allow you to participate in interactive features on our Platform, (9) in any other way we may describe when you provide the information, (10) or any other purpose with your consent.
The following table provides legal basis identifications for certain uses of your information.
|Use of information||Legal basis|
|(1) to present our Platform and its contents to you, including to optimize the use of our Platform and its interface||GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(2) to provide you with communications, information or services, including those that you request from us||GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(3) to analyze your use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features||GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(4) to fulfill any other purpose for which you provide it||GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(5) to provide you with notices about your Platform Account||GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(6) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us||GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract.|
|(7) to notify you about changes to our Platform or any services we offer or provide though it||GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(8) to allow you to participate in interactive features on our Platform||GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(9) in any other way we may describe when you provide the information||GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by the Organization or by a third party, and there is no prejudice to the data subject arising from the use.|
|(10) or any other purpose with your consent||GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes.|
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
Where you have provided consent, you have the right to withdraw that consent at any time by firstname.lastname@example.org, but a withdrawal of consent will not affect its validity up until the point you have withdrawn it.
How Your Information May Be Disclosed and Shared
We may disclose aggregated information about any user of or visitor to the Platform, including information that does not identify any individual, without restriction. We will not share, sell, rent, or otherwise disclose your private personal information to third parties without your consent or another valid legal basis permitted by law.
The Organization will share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Services:
- Subsidiaries, Affiliates, and Personnel: We may share the information within the Organization and to our subsidiaries and affiliates. The Organization’s personnel may have access to your information as needed to provide and operate the Platform in the normal course of business. This includes information regarding your use and interaction with the Platform.
- Partners: We may share the information with our employer partners who will interview and/or hire you upon or after the completion of our programme
- Service Providers: The Organization works with various individuals, organizations, contractors, vendors (“Service Providers”), including for the performance of hosting, providing analytics, performing research, undergoing development on the Platform, and engaging in social media services, as well as to other third parties as we determine necessary to support our business, including to students, teachers, alumni, and mentors who may or may not be on the Platform. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share with our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files. We share personal information with our Service Providers on the legal basis of the Organization’s legitimate interests in providing you with the Platform. Our engagement of Service Providers is often necessary for us to provide the Platform to you, particularly where such companies play important roles like helping us keep our Platform operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Platform, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Platform better.
- Business Transactions: The Organization may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction.
- Lawful Requests: We may be required to disclose Platform user information pursuant to lawful requests such as such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Platform or using the Organization name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
The Organization seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon your jurisdiction.
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, the Organization will provide you with information about whether we hold any of your personal information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format.
To the extent that such rights are mandated by the laws applicable to the individual data subject, such as all data subjects residing in the European Union (“EU”), the following rights may apply: the right to access (GDPR, Article 15); the right to rectification (GDPR, Article16); the right to erasure (GDPR, Article 17); the right to restrict processing (GDPR, Articles 18); the right of object (GDPR, Article 21); and if applicable, the right to data portability (GDPR, Article 20). You may also have a right to lodge a complaint with an appropriate data privacy regulatory authority (GDPR, Article 77).
If we process your information based on our legitimate interests as explained in this Privacy Notice, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings if you have registered for a Platform Account. However, please note you may not opt-out of Platform-related communications, such as account verification, changes or updates to features of the Platform, or technical and security notices.
Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting the Organization at: email@example.com. A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.
Access to the Information the Organization has Collected About You
The Organization welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Platform uses of your information, or to withdraw any consent you may have granted to the Organization. You can change, correct, request the deletion or removal of, and express any concerns relating to the collection, use, or disclosure of your personal information by e-mailing firstname.lastname@example.org. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may retain the information we receive about you for as long as necessary to fulfil our contractual and legal obligations, consistent with our data retention schedules, or indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. In addition, we may delete your personal data from our systems as part of a data retention plan. Following termination or deactivation of a Platform Account, the Organization may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Platform, may no longer be available to you.
You also have the right to ask to see what information we hold about you, and what we are doing with it. This is known as a Subject Access Request, and must be made in writing to email@example.com.
You also have a right to request your information in a format which supports its portability. Please contact firstname.lastname@example.org should you wish to exercise this right.
Do Not Track
The Organization does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use the Platform. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), Organization students and customers who are residents of California, USA may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. When you submit sensitive information via the Platform, your personal information is protected. We also protect your information offline. Only employees who need the information to perform a specific job (for example, communications or recruiting) are granted access to personal information. The servers on which we store personal information are kept in a secure environment. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Please do not to share your password with anyone.
Unfortunately, the transmission of information via the internet is always subject to security vulnerabilities. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
Changes to Our Privacy Notice
It is our practice to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and Platform and this Privacy Notice to check for any changes.
International Transfer of Information
Please note information the Organization collects about you may be transferred, processed and/or accessed by us in the United States or another country where we, or our Service Providers operate. Please be aware your personal data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that the Organization may transfer your personal data to the United States and process and store it there.
If you are located in the European Economic Area (“EEA”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Notice. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers, also as disclosed.
The EEA. This Platform is not intended for children living in the EEA who are under 16 years of age. No one under the age of 16 may provide any information to or on the Platform. If you are under 16, do not use or provide any information to the Organization or otherwise interact with the Platform. If we determine that we have collected or received any information from any child under the age of 16, we will delete that information immediately. If either (1) a child under 16 has provided information to the Platform or (2) you believe that we might have any information from or about a child under the age of 16, please contact us at firstname.lastname@example.org to provide additional information or to request the removal of the relevant information from our database.
Outside of the EEA. Also, the Platform is not intended for children under the age of 13 years of age living outside of the EEA. No one under the age of 13 may provide any information to or on the Platform. If you are under 13, do not use or provide any information to the Organization or otherwise interact with the Platform. If we determine that we have collected or received any information from any child under the age of 13, we will delete that information immediately. If either (1) a child under 13 has provided information to the Platform or (2) you believe that we might have any information from or about a child under the age of 13, please contact us at email@example.com to provide additional information or to request the removal of the relevant information from our database.
If you feel that we are not abiding by this Privacy Notice, you should contact us immediately via email at firstname.lastname@example.org.