PRIVACY AND COOKIES POLICY

Effective Date: December 15, 2013
Last Updated: September 29, 2016

INTRODUCTION

This privacy policy ("Privacy Policy") is incorporated by reference into the General Assembly Terms of Use. The terms "General Assembly," "we," and "us" include General Assembly Space, Inc., a Delaware corporation, General Assembly Space, Limited, a United Kingdom limited company, General Assembly Limited, a Hong Kong limited company, General Assembly Australia Pty Ltd., an Australian proprietary limited company, and General Assembly Space Academy Pte. Ltd., a Singapore private limited company.

This Privacy Policy explains how General Assembly may collect, use, disclose and secure the personally identifiable information ("Personal Information") that we obtain through the General Assembly website (the “Site”) and the General Assembly Service, which includes all General Assembly online and offline products and services (the "Service"). By using the Site or the Service you are authorizing us to gather and retain data related to the provision of the Site and Service in accordance with this Privacy Policy, and (for non-EU residents) you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with General Assembly or the Site or Service will be in accordance with the Terms of Use.

THE CATEGORIES OF INFORMATION GENERAL ASSEMBLY COLLECTS

The categories of Personal Information that we may collect from you or receive about you include, but are not limited to, the following: name, date of birth, email address, login/user ID and password details, booking requests, postal address, telephone number, other categories of information that may be designated “optional” at the time of submission, any information that you have made publicly available on social media networks when you use your social media login credentials to register for a Course or post a comment to the Site or Service, and, when combined with personal identifiers, information regarding your previous registration, website browsing history, interests and demographic information such as age, gender and education level. Under certain limited circumstances we may collect your Social Security Number where required for reporting purposes. Personal Information does not include anonymous or aggregate statistical information that does not allow a third party to identify a specific individual. We reserve the right to use anonymous or aggregate data for any purpose, including, but not limited to, improving the content of our Site and the functionality of our Service, marketing, and analyzing the use of our Site and our Service. We may also disclose such anonymous aggregate information to our partners or third-party service providers, excluding any Personal Information, except as otherwise provided in this Privacy Policy.

HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION

We collect your Personal Information when you:

Create an account on the Site or register to use the Service;
Register or apply for a Course, either directly or by using your social networking credentials on the Site or Service or a third-party website;
Participate in our surveys, promotions and competitions;
Interact with us on various social media channels such as Facebook, Twitter, LinkedIn, etc.;
Post information to the Site or Service that includes Personal Information, for example, by posting in a chat room or on a blog post;
Communicate with us, for example, by submitting queries regarding the Site or the Service, interacting with our customer support, marketing or sales teams, or requesting additional information from us, including newsletters or other marketing materials; and
Sign up, in person or online, for events or programs that are run by us or by the third party organizations that we partner with.

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Site and/or Service. See below for more information on our use of cookies.

COOKIES, AUTOMATIC DATA COLLECTION AND RELATED TECHNOLOGIES

When you visit the Site or use the Service, we and our third-party service providers, which may include third-party analytics service providers and third-party advertisers, may use cookies, server logs and other similar technology to collect and store your preferences, usage statistics, website traffic and performance data, as well as other information such as your IP address, the type of Internet browser or device you use, any website you have come to the Site or Service from and your operating system.

Cookies are small text files that include a unique reference code placed on a visitors' device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our Site or Service and will last for longer. Some cookies are necessary to enable you to move around the Site and use the Service such as accessing the secure areas of the Site, and they enable us to provide you with the Services you have requested. “Performance cookies” collect aggregated, anonymous, statistical information on how visitors use our Site and Service. We use this information to make improvements to the Site and our Service and to enhance your overall experience. Other cookies, called “functionality cookies,” allow the Site and Service to remember choices you make such as your user name when you login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

We and our third-party vendors, including Google, use first-party cookies and third-party cookies to gather information about the pages visited through our advertising partners, both on our Site as well as other websites that you visit, so as to place you in a "market segment." This information is then used by us and our third-party vendors to serve interest-based advertisements when you visit our Site and other websites. For more information about this type of interest based advertising, and about how to opt-out of the automated collection of information by third-party ad networks, please visit the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/. Without these cookies, advertisements you encounter will be less relevant to you and to your interests.

We also use Google Analytics Advertising Features including Google Analytics Remarketing to advertise across websites, Demographics and Interest Reporting and AdWords and AdSense integrations to collect data about our Site traffic via advertising cookies and anonymous identifiers. We do not facilitate the merging of Personal Information with non-personally identifiable information previously collected through any Google advertising product. Google may serve ads across other websites that you visit based upon your past visits to our Site, and may also serve our advertisements on other websites. Site visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings found at https://www.google.com/settings/u/0/ads?hl=en. You can also opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on found at https://tools.google.com/dlpage/gaoptout/.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can use your browser to notify you each time a cookie is set or to block and delete cookies from your browser. However, please note that if you do that, the Site and Service may not work properly and you may not be able to take full advantage of the Site or our Service. You can learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers.

In addition to cookies, we use the following similar technologies:

Pixel Gifs/web beacons: These are small image files that may be placed by us or third parties on the Site or Service, or within the body of our newsletters so we or third parties can understand which parts of the Site and Service are visited or whether particular content is of interest.
Flash cookies: We do not serve Flash cookies but Adobe Flash Player may be used by third parties serving advertisements to the Site in cases where these advertisements are served with flash related content. It is not possible to block or restrict or block flash cookies using your browser setting, however information on how to do this is available from the Adobe website at: http://www.adobe.com/products/flashplayer/security.

NOTICE TO JOB APPLICANTS

When you apply for a job posted on our Site, we may collect the Personal Information that you voluntarily submit to us, including, but not limited to: name, personal email address, telephone number, postal address, education, employment history and any other information included in a resume, cover letter or personal LinkedIn profile, gender, race or ethnic origin, veteran status, disability status and information relating to references. If you provide us with the details of a reference as part of your resume, it is your responsibility to obtain such third party’s consent prior to submitting their information to us. The Personal Information that you submit in connection with a job application will be used by General Assembly in accordance with this Privacy Policy and may be used for the following purposes: to evaluate your capabilities and qualifications for a job; to conduct reference checks; and to clear conflicts of interest and conduct background checks, if applicable. If you become an employee or contractor, any Personal Information you submit will become a part of your file and may be used for other employment/work related purposes.

If you are located outside of the United States, please note that the Personal Information that you submit will be stored in the United States (and may also be stored in the relevant jurisdiction(s) if the job relates to one of our affiliated entities outside of the United States), and you consent to the transfer, storage and processing of your information in the United States. To the extent your Personal Information contains details of your race or ethnic origin or physical or mental health or condition, you expressly consent to the collection, storage and processing of this information for the purposes of your job application.

HOW GENERAL ASSEMBLY USES YOUR INFORMATION

We use Personal Information in the following ways:

To identify you and your account and to enable you to register to use the Service;
To provide our Site and its content to you and to enhance users’ experience;
To provide and facilitate the Service;
To enable Course registration;
To respond to your communications and to send you information that you request or agree to receive, via regular or electronic mail, text message, or other marketing channels;
To notify you about changes to our Site, Service or practices;
To improve the functionality of the Site or Service, customer service and for other internal business purposes;
To monitor the Site and Service for security purposes;
To display content to you, including advertisements, on social media channels (e.g., Facebook, Twitter, LinkedIn, etc.); and
To send you advertisements or other marketing materials via email, text message or other marketing channels about other programs, promotions or services (or those of our affiliates), including our newsletter, that we think may be of interest to you if you have requested or agreed to receive such information, or where we are otherwise permitted by local law to contact you for these purposes.

How to opt-out of future communications. If you do not want us to contact you with marketing communications or other information regarding our products and services (or if you agreed to be contacted for such purposes at the point Personal Information was collected by us but you no longer wish to be contacted or have your information used in such way), you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at [email protected].

Please note that if you have registered an account on the Site or Service or are registered for a Course, we reserve the right to send you certain communications relating to your account, your registration, and your use of the Site and Service such as messages relating to account management, customer service and system maintenance. These transactional account messages may be unaffected if you choose to opt-out of marketing communications.

NOTICE TO CALIFORNIA RESIDENTS

We do not rent, sell or share Personal Information about you with third parties who are not our partners or affiliates for their own direct marketing purposes unless you have opted-in to such a disclosure or were offered the opportunity to opt-out of such a disclosure at the time you provided your Personal Information and elected not to opt-out.

“Do Not Track” Signals. Some web browsers may transmit "do not track" signals to the websites and other online services with which the browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals, therefore, our Site, like many others, may not respond to “do not track” signals.

In addition, California residents are entitled to know that third parties may collect Personal Information about your online activities over time and across different websites when you visit our Site. For additional information about this, please refer to the section entitled "Cookies, Automatic Data Collection and Related Technologies."

HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

We Use Vendors and Third-Party Service Providers. We may share any information we receive, including your Personal Information, with vendors and third-party service providers, including Instructors, retained in connection with the provision of the Site or Service. These third parties may have their own privacy policies but we also require that they maintain the confidentiality and security of any Personal Information disclosed to them in accordance with applicable law.

Payments are made through our secure payment solutions providers. You will be providing debit or credit card information directly to our payment solutions providers that operate a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information that you supply to our payment solutions providers is not stored by us or within our control, and is subject to each of our payment solutions providers’ own privacy policies and terms and conditions.

Events and Partnerships. From time to time, we may partner with other organizations to run events. If you register for an event on our Site and we indicate on our Site that the event is in partnership with or sponsored by another organization, in circumstances where either you agreed to be contacted by marketing communications at the time we collected your information or where we are otherwise permitted by local law to contact you for marketing purposes, your email address may be available to that organization and you may receive emails from them after the event. Please refer to that organization’s privacy policy for information on how to opt-out of their communications should you receive an email from them but no longer wish to be contacted by them.

Displaying to Other Users. Some content that you post to the Site or Service may be displayed publicly. Other users of the Site or Service may be able to see some information about you, such as information contained in comments posted in a chat room or on a blog post. You should exercise caution when using public forums. We discourage the posting of sensitive or Personal Information in comments or posts to the Site and/or Service and we are not responsible for the use of any Personal Information by third parties that you publicly post on the Site or Service.

Social Networking and Other Websites. The Site or Service may allow you to post information to social networking websites. We do not share your information with such social networking website unless you direct the Site or Service to share it. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, usage information and device identifier (including IP address), and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order, warrant or subpoena; respond to your requests; enforce our Site or Service, or other applicable policies; or protect yours, ours or others' rights, property, or safety. Unless prohibited by law or court order, or unless we determine in our sole discretion that notification is inappropriate under the circumstances, we will take all reasonable steps to notify all affected users of the request for information or intended disclosure prior to disclosure.

Merger, Sale, or Other Asset Transfers. 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, including Personal Information, may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

With Your Consent. We may also disclose your information, including your Personal Information, where you have specifically provided your consent for the disclosure.

SECURITY OF YOUR INFORMATION

We have implemented appropriate physical, technical and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All payment transactions are conducted through our PCI compliant secure payment solutions provider Braintree, a division of PayPal, Inc. For additional information on how Braintree secures your payment card information during transmission and storage, please refer to Braintree's privacy policy located at: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

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 Site or the Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or the Service like message boards. The information you share in public areas may be viewed by any user of the Site or the Service.

Unfortunately, no electronic data transmission or storage of information can be guaranteed to be completely secure or error free and we cannot warrant or guarantee the security of any Personal Information transmitted to our Site or Service. Any transmission of Personal Information is at your own risk.

CHILDREN'S PRIVACY

Our Site and the Service are not intended for nor directed toward children under the age of 13 and we do not knowingly collect Personal Information from children under 13 years of age. If you believe that your child may have provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have inadvertently collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child's account.

EXTERNAL LINKS

The Site or Service may, from time to time, contain links to external websites. We have no control over these third parties and we are not responsible for the content of such websites or for the privacy policies or practices of such third parties. You should review the privacy policy carefully for any third party website that you visit.

EU AND INTERNATIONAL USERS

The Site and the Service are operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including Personal Information, will be transferred to the United States. By using the Site or Service, you consent to the transfer, processing and storage of your information, including Personal Information, in the United States in accordance with this Privacy Policy.

If you are located in the United Kingdom, for purposes of the Data Protection Act 1998, General Assembly Space, Limited is the data controller with respect to any information collected by it in the United Kingdom and then transferred to General Assembly Space, Inc. in the United States.

General Assembly and its affiliated entities and subsidiaries adhere to the US-EU Privacy Shield Principles, which can be found here: https://www.privacyshield.gov. GA is committed to following Privacy Shield principles, including those regarding collection, use, retention, notice, choice, onward transfer, and security, for all personal data received from individuals in the EU and Switzerland in reliance on the Privacy Shield. As part of our participation in the Privacy Shield certification program, we agree to resolve disputes you have with us in connection with our policies and practices through cooperation with the EU data protection authorities (DPA) and compliance with advice as presented by EU DPA panels, in accordance with Privacy Shield principles. For more information on the dispute resolution process, please contact us at [email protected]. As explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. General Assembly is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Please see elsewhere in this Policy for more information on: types of personal data collected, purposes for data collection, types of third parties receiving personal data and purposes of disclosure to such parties, GA’s liability for onward transfer of personal data, rights of individuals to access data, choices for individuals regarding limitation and disclosure of data, and GA’s obligation to disclose data in response to valid national security and law enforcement requests.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to obtain a copy of the Personal Information held about you by us, or update, correct, or delete any information that you have provided to us through your use of the Site or Service, or otherwise, or if you have any questions or suggestions for improving this Privacy Policy, please send an email to [email protected]. If you have questions about unsubscribing from email or other communications, you may send an email to [email protected].

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

From time to time, we may revise or update our Privacy Policy. We will notify you of any changes by posting updates to the Privacy Policy on this web page. The date the Privacy Policy was last revised is identified at the top of the page.

CONTACT INFORMATION

If you have any further questions about this Privacy Policy or General Assembly’s privacy practices, please contact us at the information below:

General Assembly
902 Broadway, 4th Floor
New York, New York, 10010

[email protected]