Collection and use of PII and other information
We gather various types of PII from our users, as explained in more detail below. We use PII only in connection with our Services, including to personalize, provide, promote, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some PII with third parties, but only as described below.
A Note About Children. Pursuant to the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect or solicit PII from anyone under the age of 13. If you are under the age of 13, please do not attempt to register for the Services or send any PII about yourself to us. If we learn that we have collected PII from anyone under the age of 13, we will delete that PII as quickly as possible. Only persons aged 13 or older have permission to access our Services. If you learn that someone under the age of 13 may have provided us with PII, please contact us at email@example.com and we will respond accordingly by timely deleting that data.
A Note To Users Outside Of The United States. We are based in the United States. By using or accessing the Services or otherwise providing information to us, you consent to the processing, transfer, and storage of such information, including your PII, in and to the United States, where laws regarding processing of PII may be less stringent than the laws in your country of residence.
Why are we allowed to collect your PII and how do we use the PII?
We will only process PII where we have a lawful reason for doing so. The lawful basis for processing PII by us will be one of the following:
What information do we collect?
We receive and store any information you knowingly provide to us. If you contact us via e-mail, we may collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you post messages on our bulletin board, chat room, blog or forum of our Services, the information contained in your posting will be stored on our service provider’s servers. When you set up an account on the Breakthru app, we may collect information such as your name, date of birth, education, work experience, and age, and this information may be shared with our third party sponsors. If you do not wish to share this information with them, please refrain from using our Services.
Information collect automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device. That information may include your internet protocol (“IP”) address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers transferred to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
We may use automatically collected data to customize content to you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information collected from other websites and “Do Not Track” policy
Notice for California Residents
If you would like to submit a Data Subject Request, please email your request to firstname.lastname@example.org. To ensure that your request is timely processed, please verify that any information submitted to us is both accurate and complete. All Data Subject Requests must include the information needed to confirm your identity and verify whether we have any of the information you are seeking to access.
Please note that we are not required to retain any information about you to the extent that it would only be used for a one-time purpose and would not otherwise be maintained in the ordinary course of business. Moreover, we are not required to reidentify personal information if it is not stored in that manner already, nor are we required to provide the personal information to you more than twice in a period of twelve (12) months.
Furthermore, under CCPA, you may also request that we delete your personal information (“Data Subject Erasure Request”). Your Data Subject Erasure Request should be submitted as an email to email@example.com
Notice for Users Outside the United States
Please be advised that we do not operate our Services in the European Economic Area (“EEA”), the European Union (“EU”), and or the United Kingdom (“UK”). As such, we do not engage in the collection of any data originating from those regions such that we would be subject to the provisions of General Data Protection Regulation 2016/679 (“GDPR”). If we come into possession of any such data, we will proceed to discard it in its entirety.
Will Company share any of the PII it receives?
We do not rent or sell your PII in personally identifiable form to anyone, except as expressly provided herein.
Sharing Information with Institutions, Schools, Companies, and Other Users: We may share PII provided in your account or on your linked website, including but not limited to your mobile phone number, with the institutions, schools, and companies that we partner with (“Partners”). If you share portfolios or other information with various institutions, schools, colleges, universities, or companies, we may make your account information and/or linked website available to those entities or institutions. Additionally, our Partners may use information from your account to target particular communications or offers to you, and by providing such information you consent to receive such communications from Partners, although you may unsubscribe or opt-out at any time directly with the Partner and by contacting us at firstname.lastname@example.org. For example, our Partners may use the information we provide to determine whether certain users of Company may be a good fit for admission or other programs associated with such Partner. If you join communities associated with institutions, schools, colleges, universities and/or companies, we may make your information available to other Company users in those communities and you will be able to interact and communicate with other members of those communities.
You understand that when you use the Services, your profile and other information you post and actions you take through the Services, including, but not limited to, direct messages, posts on public forums, emails, nudges, push notifications, and chat Services, may be shared with other users and/or Partners that you indicate, and may be viewable on publicly available areas of the Services, depending on your applicable privacy settings. Partners may send you direct messages, emails, nudges, push notifications, and chat Services. For more information about how privacy settings work, please see the section titled "User Profiles and Submissions; Privacy Settings" below.
Information that’s been de-identified: We may de-identify your PII so that you are not identified as an individual and then provide that information to our Partners. We may also provide aggregate usage information to our Partners (or allow Partners to collect that information from you). Partners may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a Partner (or allow a Partner to collect such information) in a manner that would identify you as an individual person.
Affiliated Businesses: In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or Services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your PII with that affiliated business only to the extent that it is related to such transaction or service you have requested. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third-party account. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or Services to you. Unless we tell you differently, our agents do not have any right to use the PII we share with them beyond what is necessary to assist us based on our instructions.
User Profiles and Submissions; Privacy Settings: Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our Services. Your account privacy settings may allow you to limit the other users who can see the PII in your user profile and/or what information in your user profile is visible to others.
Third Party Partners; Sponsors: We have a number of third party partners and sponsors we work with to enhance our Services to users. We may share the information and data provided in the course of using our Services with these parties for business related purposes, including improving the overall user experience of our Services.
Our Services are designed, among other things, to help you share information. If you have a profile on our mobile application, most of the information you provide us through the Services is information you are asking us to make publicly accessible and will be public. When you share information or content like photos, videos, and documents via the Services, you should think carefully about what you are making public.
You may elect to restrict access to certain information, such as who can view your profile, by using the available privacy settings. It is important to note that regardless of the privacy settings you select for your own profile, information that you post and actions that you take on or in connection with other users’ profiles or in other areas of the Services may be viewable by other users and may be publicly available, depending on the applicable privacy settings for that profile or area of the Services. If you do not activate any privacy settings, your profile will be publicly available.
Business Transfers: We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, PII could be one of the assets transferred to or acquired by a third party.
Legal Disclaimer. We reserve the right to disclose your PII as required by law and when we believe that disclosure is necessary to protect our rights (or those of our Website users) and/or to comply with a judicial proceeding, any updates to the applicable rules and regulations, court order, or legal process served on our Website.
Text Messages/SMS: We may seek to communicate with you at times by phone, either through in-app notifications or by callsor text messages, if you have provided your mobile phone number. If you register and submit your mobile phone number to us, you consent to receive text message alerts from us containing product and service information or promotions that may be sent using automated dialing systems. Text messages may also include information or promotions from Partners you have expressed an interest in directly or while using the Services. We may send approximately 20 text messages/emails each month, but the number of messages you receive depends on the number of information requests. Your provider’s standard message and data rates may apply. You may elect to stop receiving text messages at any time by contacting us at email@example.com and it will not affect your ability to use any other Services or features.
Announcements: We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.
Customer Service: Based upon the PII you provide us, we may send you a welcome email to verify your username and password. We will also communicate with you by email in response to your inquiries, to provide the Services you request, and to manage your account.
Updating Personally Identifiable Information: If your PII changes, or if you no longer desire our service, you may update or deactivate it by making the change on our member information page, by emailing our Customer Support at firstname.lastname@example.org or the contact information listed below. We will aim to respond to your request within 30 days.
We will retain your information for as long as your account is active or as needed to provide you the Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Please be advised that the Internet and other technologies and communication channels are, by nature, not entirely secure, and your information may therefore be subject to interception or loss which is beyond our reasonable control. We maintain security measures in place to help protect against the loss, misuse, and alteration of the PII under our control. While we always strive to protect your PII, we cannot guarantee the security of any PII you provide to us, and any transmission is done at your own risk. Accordingly, we assume no responsibility or liability for disclosure of your Personal Information or other information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.
What PII can I access?
Through your account settings, you may access, and, in some cases, edit the following information you’ve provided to us:
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information, we have on file about you, please contact us at firstname.lastname@example.org.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of PII to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at email@example.com.
What choices do I have?
You may use the third party opt-out tools provided herein to process requests accordingly. Specifically, you can opt out through the Digital Advertising Alliance (“DAA”) AdChoices Program or through the Network Advertising Initiative (“NAI”) opt-out tool. If you do not want our mobile applications to collect any information from you, you should uninstall the application using the standard uninstall procedures that may be available as part of your mobile device or via the mobile application marketplace or network where you obtained the mobile application.
Please be advised that you are responsible for maintaining the accuracy of any information you submit to us, such as your contact information. You may be able to add, update, or delete information and adjust your privacy settings 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 contacting us at firstname.lastname@example.org, but note that we may retain certain information as required by law or for legitimate business purposes. We may use any aggregated data derived from or incorporating your PII after you update or delete it, but not in a manner that would identify you personally.
Your rights in relation to PII and how to exercise them
Under certain circumstances, you may have the following rights: