Privacy Policy
Effective Date: June 15, 2023
This Privacy Notice (“Notice”) describes how Girls Who Know® (“Girls Who Know®”, “we,” “us,” “our”) an online marketplace platform for education and engagement, collects, uses, and otherwise processes your personal information. Below, we provide more details about our practices including, but not limited to the types of personal information, individuals, activities, and third parties.
This Notice applies to the information that we process including what we do with personal information that is provided to us. We can only tell you what we do with the personal information, not what any other organization does unless they are our vendor, hired to process data according to our instructions.
Our website and applications may contain links to other websites or applications not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy notices of those other sites or applications that may collect your personal information.
We may change this Notice at any time. If necessary or there are material changes, we will provide notice or obtain consent regarding such changes if required by law.
Please review the sections below and if you have any questions, please do not hesitate to contact us at https://www.girlswhoknow.com/contact.html.
1. KEY TERMS
Our Notice contains the following key terms that you should know as you read the information:
1.1 “Customers” include Students and their Parents, Teachers, and Partners:
· “Students” are the minors (18 years and younger) who participate in Girls Who Know® activities.
· “Parents” are the parents or legal guardians of the Students.
· “Teachers” are a person who teaches a class through the Girls Who Know®’s platform.
· “Partners” are third-party companies that we work with including, but not limited to schools, technology vendors, employers, or non-profit organizations, and who are not “Teachers”.
1.2 “Services” means the Classes or Activities or other engagement by Customers with Girls Who Know®:
· “Classes” means the courses developed and/or taught by Teachers.
· “Activities” means the groups, challenges, and other types of engagement through or with Girls Who Know® in which any Customers may participate whether such Activities are paid or free.
1.3 “Personal Information/Data” means information linked to an identified (or identifiable) person.
1.4 “Process” means any activity with personal information including, but not limited to collecting, using, sharing, storing, etc.
2. YOUR PERSONAL INFORMATION
2.1 We collect information: We collect information through technology for website visitors and general consumers (meaning anyone) who does not engage with us directly, please see the “Cookies” section below for more information. If you interact on our website, we will track your activities online, but we do not know who you are.
2.2 If you submit a form with your contact information: We will engage with you as requested and may follow up with you to further build a relationship, generally through Communications and Marketing, please see the “Communication” and “Marketing” sections below for more information. You can opt out of marketing communications at any time by providing us with written notice that you are opting out of marketing communications.
2.3 Anyone can engage with us: Anyone can engage with us in Communications, Social Media, and Marketing, please see the “Communication”, “Social Media” and “Marketing” sections below for more information.
2.4 How do we collect your personal information?: Your personal information is typically provided by you voluntarily. Where it is not provided voluntary, your personal information may be collected through employment, legal proceedings, or following the requirements under applicable law. In addition, we may buy or acquire services or information that help us learn more about you and to assist us with communicating with you.
2.5 Why do we collect this information?: We respond or initiate communications in provision of the Activities or in response to a request. The information collected is to assist us in better providing services to you or our legitimate interest to grow our business and understand our Customers and their needs better. Our legitimate interests in collecting this information is not outweighed by the risk to you.
2.6 Social Media: We may interact with you using social media in a variety of ways. We may “follow” you or ask you to “follow” us. We may create groups on social media for interaction. We may ask for your social media handles or tags to use in advertising. We may copy your posts or statements and follow up internally or with you.
2.7 Communication: We keep records of communications when you communicate with us and we act on those communications as we deem to be appropriate, whether communication is by email, messaging, or other forms of communication. Communications may be managed by various departments and/or third parties. We may also communicate with you to better understand our market or to ask you to participate in study groups, surveys, video interviews, etc.
2.8 Marketing: We will use your contact information to communicate with you, unless you instruct in writing otherwise. We may obtain information from third parties, such as matching your email address to a publicly available physical address and sending physical marketing materials, like postcards or letters. You can request that your email or other information in your profile not be used for marketing purposes in writing to https://www.girlswhoknow.com/contact.html. If you opt out of marketing emails, we will continue to send emails related to Classes or Activities and we also will continue to respond to any requests we receive from you. Please do not hesitate to contact us at https://www.girlswhoknow.com/contact.html if you have any questions.
Children may receive marketing emails and other emails, such as a notification that class is starting. If your would like for your Child to not receive marketing emails, please notify us by sending us a message at https://www.girlswhoknow.com/contact.html.
2.9 Individuals with Third Parties: If you work for or are with a Partner, vendor, or other third party, we will engage with you as required for the relationship to build, maintain, and terminate. We will only process your business-related information in furtherance of our relationship and engagement in the potential or actual relationship including, but not limited to payments, contracts, and via technology. You may also engage with us as a member of the general public as described above or as a Customer as described below.
2.10 Customers (Teachers, Parents, Students, and Partners): The personal information we process can be grouped into three main categories: (1) information you or your Student provides to us; (2) information we get from third parties about you; and (3) information we get from cookies and trackers.
(a) Customers - information you provide to us: You provide us information directly for your Account, Services, and Finance when you engage with us:
· How do we collect this information?: If you engage with us directly, we collect this information from you or from linked accounts (for example, Google or Facebook log-ins) that you choose to share the data with us. You also volunteer information when you complete parts of your profile. You can choose not to provide this information by notifying us in writing to https://www.girlswhoknow.com/contact.html. If you come to us through a partner then some of the data may come from that partner; however, information would still be provided to us when you complete the registration. If you are a Student, your Parent may provide your information. When engaged with classes or activities, participants may be requested to submit some information to complete the assignment and some information is volunteered through your engagement (for example, in comments or feedback).
· Why do we collect this information?: We collect this data to add you to our platform and to let you engage with us, generally at your request or consent, which you may revoke at any time by notifying us in writing to https://www.girlswhoknow.com/contact.html. Revoking consent may end your classes, activities, or account, depending on your request. Some information is provided for Student safety, such as video evidence that the person in the Activity other than the Teacher is a child. If you refuse to provide us with access to a video, you may be refused to join Activities. You can participate without providing any voluntary information, but you must provide required information. We may also use information provided to us to prevent fraud. In general, we use your information to provide the Services, customer support, and to improve our platform and Services.
(b) Services: We collect information about the Classes, Activities, or other Services for which you or a Student engages in, comments and communications, instructions, information you share including, but not limited to drawings or photos, class or Teacher reviews, video and audio, and the history of activity in and with Girls Who Know®. This may include uploaded items including, but not limited to photos or drawings. If information is uploaded to Girls Who Know®, it may contain metadata such as who created or last modified it, the date created or modified, location, and such. We do not require any metadata on submitted items.
(c) Finances: For purchases we collect the name, credit card or other payment information including, but not limited to the billing address and information about the Services purchased. We also use financial information to detect or prevent fraud.
(d) Sensitive Data: “Sensitive data” has different meanings depending on location. Where possible, we apply heightened protection to sensitive data. In some places, information from a child may be considered sensitive information itself. You or a Student may voluntarily provide sensitive information including, but not limited to health or disability information included in forms, messages, or with a complaint or concern. Students may also be enrolled in special classes offered for Students with disabilities and Teachers may volunteer their disabilities within a class. Teachers and Students are otherwise not allowed to have discussions that may elicit or result in sharing of sensitive information, and where they do learn sensitive information, they are not permitted to share that outside Girls Who Know® or use it in an inappropriate way.
· Fraud: If we suspect that a Student is over the age of 18 or misrepresenting their identity then we may request proof of appropriate age or identity, such as a video clip or the Student’s birth certificate, passport, or driver’s license for the safety of other Students. This documentation may contain sensitive data such as full date of birth, place of birth, and government ID numbers. We only retain the information necessary.
· Background Check Information: Teachers and potential employees must provide information as part of our background check process, including criminal history information, professional education and qualifications, work history, references, and teaching abilities. We provide separate written notices and consent forms before performing background checks.
2.11 Information we get through Third Parties: We may get information on you from Customers, Partners, third parties or vendors on Customers or potential Customers. This may include us getting the information directly or it may be getting your information from Partners.
(a) How?: We get information from third parties either by purchasing or leasing it, indirectly through our own vendors, or by engaging with you through third parties, like social media (see “Social Media” which is discussed above). Also, our current Customers may share information in our referral program. We do not buy or lease information from third parties on Students.
(b) Why?: In most cases, we obtain or purchase data so we can grow our business; therefore, it is in our legitimate interests as a business to do so. We may use this data to report suspicious activity to a local agency either for addressing fraud or for the safety of Students.
(c) Information from Partners: Girls Who Know® may partner with other organizations including, but not limited to schools, non-profits, and employers to provide services. In general, these Partners would provide your information to us for you to participate in Classes or Activities in which they have control or where they are offering the Services to you as a joint effort. Partners will likely provide you with specific information when the relationship is set up, especially if they have control over the Classes or Activities. If so, you need to look at the third party’s specific privacy notice to see how the third party will handle your information.
We also may partner with technology companies to jointly provide some services. In some cases, you may need to create an account with the Partner to use their services and when you link your account there with your account with us, they may provide information to us.
(d) Information from Vendors: At times, we may purchase or lease data from third parties for certain reasons. We do not know how these third parties get your data but it is generally through advertising services or other companies you have used who are able to share your information. We do not sell that information but we may share it with our vendors including, but not limited to sharing those addresses with a vendor who may print and mail the postcards if we buy a mailing list of parents in a certain area. The data we get may be on a group of people where we provide characteristics we want or we may provide the names (not including Students) to get more information on them including, but not limited to addresses for marketing materials or for reporting an event to the local agencies.
(e) Information from other third parties: At times, you may decide to login to our services using a linked account including, but not limited to Facebook or Google. You should check the privacy notices of these providers to see what they share with us and others. We may also get information through third parties if you use them in Classes or Activities.
2.12 Information we get through Technology: Some data we get through technology including, but not limited to cookies and trackers on the website. We do not knowingly track children.
(a) How do we collect this information?: This data is collected through technology; therefore, you are providing certain information automatically by coming to our website or using our app. Some of this you can opt out through our Cookies page or through your computer or browser settings but others are necessary.
(b) Why do we collect this information?: Some data is necessary for the operations of the website and app and some data is optional. Optional reasons include analytics, preferences concerning testing certain features or preferences on our website, assessing user behavior and tech problems, along with other useful information. Unless it is necessary for the website or app to work, our reasons are linked to our legitimate interests in having this information that we do not believe impact your rights and freedoms. This information also helps us personalize your experience with us. It also helps us detect, investigate fraud and violations of our policies.
(c) Technical, Device, and Usage Data: This is information that we automatically collect about your device and connection when you engage with Girls Who Know® and this information includes, but is not limited to your IP address, device identifiers such as cookie identifiers and mobile device identifiers, operating system type, and the type of browser. This information may include, but is not limited to data about your usage (such as login times, search terms, items you click on, error messages, and pages you viewed) and location data. For information about what cookie and mobile device identifiers are and how we use them, please see the information concerning Cookies below. We do not collect data from third-party ad trackers on Students.
2.13 Information we get through Technology: Some data we get through technology including, but not limited to cookies and trackers on the website. We do not knowingly track children.
(a) How do we collect this information?: This data is collected through technology; therefore, you are providing certain information automatically by coming to our website or using our app. Some of this you can opt out through our Cookies page or through your computer or browser settings but others are necessary.
(b) Why do we collect this information?: Some data is necessary for the operations of the website and app and some data is optional. Optional reasons include analytics, preferences concerning testing certain features or preferences on our website, assessing user behavior and tech problems, along with other useful information. Unless it is necessary for the website or app to work, our reasons are linked to our legitimate interests in having this information that we do not believe impact your rights and freedoms. This information also helps us personalize your experience with us. It also helps us detect, investigate fraud and violations of our policies.
(c) Technical, Device, and Usage Data: This is information that we automatically collect about your device and connection when you engage with Girls Who Know® and this information includes, but is not limited to your IP address, device identifiers such as cookie identifiers and mobile device identifiers, operating system type, and the type of browser. This information may include, but is not limited to data about your usage (such as login times, search terms, items you click on, error messages, and pages you viewed) and location data. For information about what cookie and mobile device identifiers are and how we use them, please see the information concerning Cookies below. We do not collect data from third-party ad trackers on Students.
2.14 Inferred and Combined Data: We provided information on how and why we collect and process your information and provided a lot of information about the sources of information and the purposes for which we use your information. However, using your information is not always this straightforward as we infer information about you and we combine data to have a more complete understanding of you.
(a) Inferred Data: We may infer new information from other data we collect to generate information about your likely interests. For example, we infer the class subjects you may be interested in from searches you may perform. We may also infer your general geographic location based on your IP address.
(b) Combined Data: We may obtain information from you from sources other than you including, but not limited to through partners, employers, third parties, or social media. Where possible we combine these sources to have one extensive view of individuals engaged with Girls Who Know®.
As explained in the sections above, we may use any of the above categories of your personal data to:
· Provide services to Customers, Partners, third parties, and employees;
· Perform our business operations; and
· Manage our relationship with Teachers, Parents, and other individuals.
3. SHARING YOUR DATA
We may disclose your personal data to the following categories of third parties:
· Teachers: When Parents sign up for Services, they agree that Teachers may receive certain
personal data about the Parents and their Students including classes they have taken and requests or needs.
· Other Customers: Members of a class or activity will be able to see, hear, and read the interactions with the other members, unless a Student private messages a Teacher. This may include other Parents, Students, and other individuals any member of the activity or class requires in order to participate, such as an interpreter. However, no one should have other individuals involved in class that should not be there for a legitimate and pre-approved purpose. Girls Who Know® prohibits non-approved people on our site engaging with Students or other Customers.
· Teachers using third-party sites or tools: We request that Teachers only share or use tools / third party sites that are Children’s Online Privacy Protection Act (“COPPA”) compliant. However, at times, Teachers may prefer to use tools or sites that have not been reviewed by our team. Parents should review what sites or tools that Teachers list for specific Classes and either agree or let us or the Teacher know in writing if you disagree. Parents should check email registrations carefully and review your Student’s Activity description or listing.
Unless you notify us otherwise in writing, you are also consenting to the pre-approved third-party sites and tools. We will keep an updated list of these sites and tools. We review requests for third-party sites and tools on a quarterly basis and determine if they are approved or prohibited. At any time, you are able to decline to use these sites or tools by providing us with written notice. While you are not required to use them if you disagree, it may have an impact on the Classes or Activities.
· Partners: When we work with organizations including, but not limited to schools, employers, non-profits, tech companies, etc. that provide opportunities or funding to you for Services, we will share information with them about Student engagement. As mentioned above, you will be aware of these engagements as generally, that is how you came to Girls Who Know® or used their codes / vouchers to pay for Services or you specifically connected your account with them to us.
· Vendors/Service Providers: We may engage third-party service providers to perform certain activities on our behalf including, but not limited to hosting (AWS), communications (for example, Google, Intercom), marketing (for example, Postmark), analytics, payment processing (for example, Paypal), video hosting (for example, Zoom), and website maintenance.
· Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets. This may occur before the transaction is complete as part of the transition or evaluation, although where possible, we will ensure the other entity honors the privacy protections.
· Legal Requirements: We may disclose your personal data if required to do so by law or when we believe that such action is necessary to: (i) comply with a legal obligation or a request from someone with legal authority to do so; (ii) protect and defend the rights or property of us or those of Customers or Partners; (iii) operate and maintain appropriate security, including to prevent or stop an attack on our computer systems or networks; (iv) to protect the personal safety of Customers or the public; or (v) protect against legal liability. Teachers are required to report to us any suspected case of child abuse or neglect they become aware of during their work with Students. Teachers and Partners may also be required to report suspected abuse or neglect to local authorities, and we expect all Teachers and Partners to comply with their individual reporting responsibilities. We may also report instances of suspected abuse or neglect.
· Third-Party Analytics and Advertising Companies: We allow third-party analytics and advertising vendors to collect personal information including, but not limited to the Technical Data described above, data about your usage, and inferences about you based on such data. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. If you reside in California, you can opt out of this processing by immediately notifying us by sending us a message at https://www.girlswhoknow.com/contact.html and also please also see our California Notice below. We do not sell your data for money, but we may receive services or a discount in exchange for some data collected online (not Student data). For more information about the cookies and other technologies we use and your choices regarding what personal data they collect, please see the section concerning Cookies below.
· Information Disclosures Requested by You: You may transmit information to third parties or request us to do so, including the general public. For example, you may voluntarily: (i) message others using Girls Who Know® or our team; (ii) upload personal data to your user profile which is accessible to other users; (iii) disclose information about yourself to Teacher(s) and other participants in your Classes or Activities; and (iv) participate in discussion boards, social media, and public forums that may also be available to the general public. We expect everyone to respect the privacy of others and follow our requirements on posting and disclosing activities including, but not limited to disclosing private material, communications or information, or disclosing other personal data about others that may cause harm, embarrassment, or conflict. Please also see our Terms of Service.
Please note that Classes and Activities may include references or links to or suggestions to engage with third parties whose privacy practices differ from ours. Teachers may also suggest third-party resources for Parents and Students. If you provide personal data to any of those third parties, or instruct us to disclose personal data to them, that data is governed by their privacy notices.
4. WHERE IS YOUR DATA
4.1 We are located in the United States. Our service providers are located and process personal data in the United States. Our third-party analytics and advertising vendors are located in the United States. We also have support services in the United States. This may not be a complete list and not all personal information may go to the United States. Please contact us if you would like more information.
4.2 If transferring your data outside your country requires your consent or other transfer process, we intend to follow the requirements. In most cases, our legal reason for processing your information is to complete a contract with you, generally to provide the Services you have engaged in with us, whether free or paid or to allow you to provide Services on our platform. If you have any questions, please contact us at https://www.girlswhoknow.com/contact.html.
5. YOUR RIGHTS
5.1 To submit a request to exercise any rights you may have under data protection laws, please contact us at https://www.girlswhoknow.com/contact.html and clearly describe your request. If you have such rights and your request complies with applicable legal requirements, we will respond in a timely manner.
5.2 If you request your account to be deleted, we will do so unless there is a legal reason not to do so of which we will inform you once known. If you are a Parent/Guardian, your account deletion may impact multiple Students and if you do not specify a specific student then all will be deleted. Before doing so, we will verify your identity, such as receiving the request from your verified Girls Who Know® account. Once deleted, you will not be able to reinstate your activity, class, or other history, including interactions with teachers or payment.
6. KEEPING AND SECURING YOUR DATA
6.1 We take steps intended to protect the personal data that we collect from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure, and we cannot ensure the security of any content or information you provide to us. You are also responsible for helping to protect the security of your account credentials. For example, never give out your password, and make sure to safeguard your username, password, and personal credentials used to access Girls Who Know®, so that other people will not have access to your personal data. Please do not use the username and password you use with us with any other services.
6.2 We retain the information we collect for the duration of the services with you. For Parents and Students, this is generally one year past the time you cease interacting with us, or at your request. For Teachers, local law may dictate certain retention periods for payment purposes.
7. CHILDREN’S PRIVACY NOTICE
This Children’s Privacy Notice specifically addresses the U.S. Children’s Online Privacy Protection Act (“COPPA”). This information also applies to all students where local law regulates activities to children under certain ages. For COPPA, this is someone who is under 13 years of age.
For more information about COPPA and general tips about protecting Children’s online privacy, please visit the U.S. Federal Trade Commission’s (FTC's) consumer information site at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.
7.1 Some of the features on our websites or in our applications may be blocked or provided in a limited form to restrict the collection or sharing of data from children (typically those under 13 years of age or the age indicated by law) or to prevent them interacting with adults.
7.2 We collect almost all personal data about Children directly from Parents / Guardians, but we do
collect data from Children. Once we have verified parental consent of Parents or Guardians, we collect
information directly from Children in our platform.
7.3 We collect a little information from Children under a "limited consent" (see more below) when Children sign up for Girls Who Know® directly and alert Parents or Guardians.
7.4 Once Parents or Guardians set up an account, they will create Student accounts for their Child and may provide optional information such as the type of schooling the Child receives, time zone, preferences, and other information such as ethnicity or learning challenges.
7.5 Children cannot enroll themselves in activities that require payment, but they may join free challenges or free Student groups, if available.
7.6 Parents or Guardians will receive notice via email for all Services, whether paid or free, and can un-enroll their Children at any time. Parents or Guardians can always see the Student accounts, but cannot themselves participate in Student activities.
7.7 Mobile apps: If applicable, Parents or Guardians can choose permissions to allow push notifications to, and camera and photo access by Children. Parents or Guardians should consider enabling parental controls to help prevent Children from changing permissions they have chosen.
7.8 What can Children do with Girls Who Know®?: We may allow Children to mark activities they like or want to attend and we may infer a Child’s interest in topics from these records in order to make recommendations and offerings using AI (machine learning). Children also share information during classes or in activities as well as when reporting emergency safety and compliance issues. Our activities take place over online videos in which video images and audio of the Children are recorded, along with chats and messages. Certain information is required that we need to provide the Services. Other information is optional and if not provided, Parents or Guardians and Children will still be able to participate with Girls Who Know® without any changes in the quality of Services.
7.9 Verified accounts: Once we obtain verified parental consent, we may use and share personal data collected from Children for many of purposes described in our Privacy Notice and emphasized in this Section 7. We recommend activities and new features to Parents or Guardians and Children based on their engagement with us. We may send these messages within our platform or mobile apps to Children and Parents or Guardians through push notifications if applicable. We may also send this information via email to Parents or Guardians, along with surveys or other information related to Girls Who Know®.
We do use technology, like cookies and other trackers, to help us gather information about activities once logged into Girls Who Know®, but we do not allow third-party analytics or advertising providers to collect personal data for their own purposes of the Students. Please see our Privacy Notice and Cookie Page below for more information.
7.10 Information is shared to:
(a) Teachers can see information such as:
· Account and profile information provided by Parents or Guardians or Children
· Video verification
· Child communications to the teacher (Parents or Guardians can receive a copy by sending us a message that notifies us at at https://www.girlswhoknow.com/contact.html stating that the Parent or Guardian wishes to have a copy of the Child communications to the teacher.)
(b) Teachers, other Students, and Guests can see information such as:
· Video image and voice audio and potentially background images of their home and family members (recorded and shared)
· Children’s communications, posts, uploads, content, responses, opinions, etc.
· Sometimes, Teachers or other Students may need assistance such as an interpreter available during sessions or may have guests or other Teachers.
(c) If Children engage in any activity, what they do is available to the other participants, whether children, Teachers, assistants, or guests and may be available to other Parents or Guardians, as well as Girls Who Know® employees, contractors, partners, and vendors. We moderate communications for compliance with our community standards and guidelines and for safety reasons.
7.11 Video recordings: We record video, audio, and written communications of Children and Teachers during classes. The class recordings are made available to the Teacher for the class and may be shared to the entire class (and their Parents or Guardians) to view.
We may use recordings to provide feedback to Teachers, for customer support, for operational needs including, but not limited to a glitch in the recording and for compliance, enforcement, and safety purposes.
We will obtain additional parental consent before we use recordings for promotional or other unexpected purposes.
We request that Teachers not copy the recordings or share the recordings with anyone aside from those who are permitted to have them, and also request that recordings not be downloaded or re-shared. We expect all participants to abide by our standards of conduct, but we cannot control or monitor what such third parties including, but not limited to other parents, ultimately do with recordings.
7.12 Third-party sites and tools: Some Teachers may ask Child Students and their Parents to use third-party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.
7.13 Children may have tried to sign up with an account on their own. If so, Parents will receive a verification email. The information we collect is limited in this circumstance. Students cannot enroll in classes and their information is not shared to Teachers or other Students.
7.14 Parental consent and rights: We follow the required processes to obtain verified parental consent to set up a Student accounts. Where activities are paid by an organization, other verification methods may be used to verify a parent’s or guardian’s identity.
7.15 No consent / revoke consent: If Parents or Guardians do not consent or withdraw consent, then we will not collect, use, or disclose any personal data about their Child, except as needed for legal compliance and enforcement purposes, and their Child will not be allowed to use Girls Who Know® in any way, shape or form.
7.16 Deletion: Parents or Guardians can request that we delete the personal data we have collected in connection with the Student’s account. Please keep in mind that a request to delete records may lead to termination of an account, membership, or other services.
However, if we need to keep the data for other valid reasons, such as fraud, compliance, and safety, we will not delete the information. We will continue to protect that information and delete it when appropriate.
In addition, we will exercise commercially reasonable efforts to delete personal data collected from Children when it is no longer needed for the purpose for which it was collected.
We will not generally be able to guarantee a deletion from backups, but when feasible we will. If the backups are used for restoration, we will re-delete the records, based on the record of deletion requested.
7.17 Review and update information: Parents or Guardians may review and update certain of their Child’s information by logging into their account.
7.18 Contact us: Please contact us at https://www.girlswhoknow.com/contact.html if you have any questions or concerns about our COPPA Notice or practices or any rights.
8. CALIFORNIA PRIVACY NOTICE
This California Privacy Notice (“CA Notice”) to you if you reside in California and use our websites, applications, or activities offered through either (collectively “Services”). This CA Notice does not reflect our collection, use or disclosure of California residents’ personal data where an exception under the CCPA applies.
8.1 Our Personal Data Handling Practices: In the last twelve (12) months, we collected the categories of personal data described in the section titled “Your Personal Data” as stated in our Privacy Notice. These categories of personal data correspond with the following categories enumerated under definition of “personal information” in the California Consumer Privacy Act (CCPA):
· Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
· Characteristics of protected classifications under California or federal law, including age (40 years of age or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex including, but not limited to gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions, sexual orientation, and veteran or military status.
· Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
· Information that identifies or is capable of being associated with you, including payment information.
· Audio, electronic, visual or similar information.
· Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a California resident’s interaction with an internet website, application, or advertisement.
· Professional or employment-related information.
· Education information.
· Geolocation information.
· Inferences drawn from any of the information identified above reflecting your preferences and characteristics.
We collected this personal data as described in the section titled “Your Personal Data” as stated above. In the last twelve (12) months, we used the personal data we collected for the purposes described in that section. In the last twelve (12) months, we disclosed the personal data we collected to the categories of recipients described in the section titled “Sharing Your Data” as stated above. In the last twelve (12) months, we may have “sold” data about California residents’ IP addresses and device identifiers and their usage of our Services to third-party analytics and advertising vendors who may use this data to provide them with tailored advertising and for their own purposes. We do not sell personal data for money. We do not have actual knowledge that we sell the personal data of California residents under 16 years of age.
8.2 California Rights and Choices: You have certain legal rights related to your personal data if you are a California resident. Except as otherwise provided or excepted by applicable law, you may exercise the following rights:
(a) Right to Know/Portability: You have the right to request that we disclose to you certain information about personal data we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
· the categories of personal data we have collected about you;
· the categories of sources from which the personal data is collected;
· the specific pieces of information we have collected about you;
· our business or commercial purpose for collecting personal data; and
· the categories of third parties to whom we have disclosed or sold personal data.
(b) Right to Opt Out: You have a right to opt-out of future “sales” of personal data. Note that the CCPA defines “sell” and “personal data” very broadly, and some of our data sharing relating to cookie data and other tracking methods used for analytics and advertising purposes described in this CA Notice may be considered a “sale” under those definitions. To opt-out of this limited “sale” of personal data, please contact us at https://www.girlswhoknow.com/contact.html.
We do not “sell” the personal data of California residents we know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the California resident who is between 13 and 18 years of age, or the parent or guardian of a California resident less than 13 years of age. California residents who opt into personal data sales may opt out of future sales at any time.
(c) Right to Deletion: You have the right to request deletion of your personal data that you provided that we have retained, subject to certain exceptions. Once the deletion request is approved, we will delete and direct our service providers to delete, as applicable, your personal data from our records. Please know that if your Girls Who Know® account is deleted, you will no longer be able to access the account. You would have to create a new account.
(d) Right to Non-Discrimination for Exercise of a California Privacy Rights: We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your rights, we will not deny you access to our services, charge you different prices or rates for services or provide you a different level or quality of services.
(e) How to Submit A Request: You may submit a request to exercise the rights listed above by contacting us at https://www.girlswhoknow.com/contact.html. In your request, please include: (i) the full name used to create your account; (ii) the email address with which you created your account; (iii) your phone number in case we need to contact you; and (iv) what CCPA right(s) you would like to exercise.
(f) Verifiable Request: As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected personal data or an authorized agent. We may limit our response to your exercise of the above rights as permitted under applicable law.
(g) Agent Authorization: You may designate an authorized agent to make a request on your behalf. You may also make a request on behalf of your minor child if they reside in California. As permitted by law, we may require additional verification in response to a request.
(h) Responding to Requests: We will confirm receipt of your request within 10 days from receipt and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request.
We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.
8.3 Additional California Privacy Rights: California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code §22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed using https://www.girlswhoknow.com/contact.html. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
9. COOKIES
9.1 Girls Who Know® uses cookies and similar technologies to help deliver our service.
9.2 Most web browsers are set to accept cookies by default. If you prefer, you can also go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
All of these choices are specific to the browser and device you are using. If you access our website from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
9.3 We may also use cookies and web beacons in emails we send to Parents and Teachers. We use these to tell if an email was opened and to tell what links are clicked in emails. Most email services have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
10. CONTACT US
Please contact us at https://www.girlswhoknow.com/contact.html if you have any comments or questions about this Notice or our information processing practices.