PRIVACY AND COOKIES POLICY
Effective Date: December 15, 2013
Last Updated: September 29, 2016
THE CATEGORIES OF INFORMATION GENERAL ASSEMBLY COLLECTS
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.
COOKIES, AUTOMATIC DATA COLLECTION AND RELATED TECHNOLOGIES
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
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.
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
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.
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.
EU AND INTERNATIONAL USERS
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.
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New York, New York, 10010