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Hats & Ladders Privacy Policy

Updated and Effective 2/05/2025

Hats & Ladders, Inc. (“Hats & Ladders”) owns and operates the website available at https://www.hatsandladders.com/ (the “Website”), as well as web applications and related educational planning and counseling curricular materials and tools (the “Products”). We refer to the Website and Services together as the “Services.” This Privacy Policy describes how we collect, store, use, and disclose personal information from our customers (“Authorized Institution”), their employees (“Administrators”), the youth, and other individuals who use our Products (“Learners”). We refer to visitors to our Services  as “Users.” 

This Privacy Policy also explains some of your rights regarding your personal information.  

Personal Information that We Collect and How We Use It

When you access and use our Services, we may collect certain personal information, which is information that identifies, relates to, and/or describes, directly or indirectly, a particular individual (“Personal Information”). 

The Personal Information we collect from you varies based on what type of User you are, and on the Products you access and use, as described below:

From Administrators, we may collect, store, use, and disclose:

  • Administrator contact information such as first name, last name, email address, mobile number, program, and/or affiliated school or institution, which we use to set up accounts and rosters and verify access to our Products 
  • Learner information, including program, first and last name, institutional ID, email, Product usage, assessment results, and career interests, which enables you to track Learner usage and progress 
  • Comments, questions, or other feedback submitted about our Products which allows you to access support and suggest improvements

From Learners, we may collect, store, use, and disclose the following:

  • Contact information such as first name, last name, email address, mobile number, affiliated school or institution
  • Month and year of birth, grade level, and/or employment status
  • Information relevant to college and career counseling, including information about your interests, academic preferences or aptitudes, skillsets of in-school and extracurricular activities, personal values, obstacles faced, skills, and other career-related preferences and goals
  • Learner-generated content, including reflections on your learning and experiences.

In addition, Users may log into the Products using a third-party single sign-on portal provided by the Authorized Institution or may provide us with their own username and password. 

When you visit our Website, we collect Personal Information from you when you choose to provide it. For example, if you choose to schedule a demonstration of our Products, we will ask you to provide your first and last name, job title, the name of your organization, your email address, phone number, city, state, your organization’s website, as well as how you learned about us. We’ll use this information to contact you to schedule a demonstration. We will also use this information to provide updates and information about our products that we believe may interest you.  

If you submit a support ticket, you will be asked to provide your first and last name, email address, the nature of the Product you are using, your role in the program, and information regarding the issue you are experiencing. 

If you apply for a job, you may be asked to submit a resume, cover letter or work sample. We will only use the information for the application process and in accordance with any other privacy notice on the page in which you enter the job posting.

Children and the Children’s Online Privacy Protection Act (“COPPA”)

When operating our Products, Hats & Ladders does not solicit and does not knowingly collect or use Personal Information from children who are less than 13 years of age without verifiable parental consent. When operating in partnership with an Authorized Institution that is an education institution, Hats & Ladders relies on that Authorized Institution to attest that they have the authority to act in lieu of the parent to authorize our collecting and use of personal information from children under age 13 for the purpose of providing Hats & Ladders.

In circumstances in which we are providing the Products to an Authorized Institution that is not an education institution, we will work with that Authorized Institution to ensure that we can obtain verifiable parental consent directly from the parents.  If Hats & Ladders learns that the Personal Information of persons less than 13 years of age has been collected inadvertently without the proper authorization from the Authorized Institution or otherwise without required parental consent, then Hats & Ladders will take appropriate steps to delete this information from our systems.

Our Website is a general audience website and is not intended for children. We do not knowingly solicit or collect Personal Information from children. If we learn that Personal Information of individuals less than 13 years of age has been inadvertently collected, we will take steps to promptly delete it.

Information We Collect Automatically

As Users navigate through and interact with our Services, we automatically collect certain information about the User’s equipment, browsing actions, and patterns, including:

  • Traffic data, logs, and other technical communications data, including the Services that are accessed and used
  • Pages that are viewed, links clicked, and other User actions taken in the Services
  • Technical information from the browser or device, such as the Internet Protocol (IP) Address, browser type, version, referring URL, clickstream data, device and operating system, and the dates and times Users visit our Services. On occasion, we may also receive your internet service provider (ISP).

We use this information to help us administer and secure the Services, remember your preferences, and diagnose technical issues. We also analyze the information for aggregate trends about how our Services are used and to help us improve our Services. When the information that we collect automatically is in a format that is identifiable of an individual, we treat it as Personal Information in accordance with this Privacy Policy.

We collect this information using these tracking technologies:

  •  Cookies – small data files sent by a website and stored on your browser – set by us. We do not use third-party cookies or other web trackers. Most browsers can be set to detect browser cookies and to let a user reject them, but some of our Products may not work properly without cookies. To learn more about cookies, including how to manage or delete them, refer to the “Tools,” “Help,” or similar section of your web browser. 
  • HTML5 localStorage - this type of storage allows some data to be stored in the browser.  You can “clear” browser storage using tools available from your web browser.

We use third-party service providers to help us collect and understand usage information. Most browsers can be set to detect browser cookies and to let you reject them, but doing so may affect certain features of our Website that are provided for your convenience.

We do not serve targeted advertising on our Website (and we do not serve any advertising in our Products). 

As with many websites, we do not honor “do not track” signals transmitted by web browsers as there is no industry standard for implementing such programs. To find out more about DNT, please visit http://allaboutdnt.com. 

How We Use and Share Personal Information

We don’t sell or rent Personal Information, and we don’t use Personal Information for targeted advertising. When providing our Products to an Authorized Institution subject to the Family Educational Rights and Privacy Act (“FERPA”), we operate under the direct control of the Authorized Institution with respect to our use and maintenance of the education record as it is defined in FERPA.

We use the Personal Information collected via our Products to provide our Products, including for the following purposes: 

  • To provide and maintain our Products;
  • To create, manage, and administer User accounts and credentials;
  • To create a personalized map of learner interests, skills, academic preferences or aptitudes, personal values, obstacles, and other career-related preferences and goals;
  • To recommend careers, activities, and next steps in the exploration and pursuit of careers and related aptitudes or skills;
  • To provide support to Authorized Institutions, Administrators, and Learners, including to respond to requests, notify of changes to our Products, and solicit feedback on the Product experience;

We may use the Personal Information that we collect via our Website and Products:

  • To protect the security of our Services; 
  • To respond to known or suspected fraud, violation of our terms of use, or to protect our rights or the rights and safety of others, including to share Personal Information with parties assisting us in any such investigation as may be necessary or required by applicable law. 
  • To respond to a court order, regulatory inquiry, or other lawful request, provided, however, that unless legally prohibited from doing so, we will direct any such request to the Authorized Institution or notify you before responding unless such an action would prejudice prevention or detection of a crime;
  • In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar change in our organization, we may need to transfer your Personal Information to a new or reorganized entity for them to use in accordance with this Privacy Policy.

We also use the Personal Information collected via our Website to provide and maintain the Website and to respond to your inquiries as described above.

We may create, use, and share aggregated and/or de-identified information for lawfully permissible purposes unless specifically prohibited by an Authorized Institution.

We use third parties to support us in the delivery of our Services and to provide certain features, such as data hosting, analytics, content delivery, video hosting, security, and similar functions. Some third parties require access to Personal Information to perform their Services. 

How Long We Retain Personal Information

Hats & Ladders will retain Personal Information that we collect via your access to and use of our Products for so long as your account is active or as needed to provide you with the Products. 

Personal Information of Learners in our care as a result of a contract with an Authorized Institution will be deleted when no longer necessary to provide the Services for which it was provided or within 90 days of termination or expiration of the contract. At any time, an Authorized Institution may request to delete their Learner’s Personal Information, and we will comply with such requests within 10 days. 

We retain the Personal Information that we collect via your access to and use of our Website. The submitted contact information will be used for promotional purposes, and you may opt-out at any time by clicking on the “unsubscribe” link found in the footer of every email that we send or by contacting us at info@hatsandladders.com. Registration for product demos, webinars, newsletters, and other promotional offerings including sales demos are not intended for minors.

We will also retain and use Personal Information collected via our Products and Website as necessary to comply with our legal obligations, resolve disputes, and enforce our agreement with the Authorized Institution.

We also create, retain, use, and share aggregated, de-identified information (for example, aggregate data about the potential careers Learners mark as “favorites”) for as long as necessary, in our discretion, to provide our Products, operate and improve our Products, demonstrate the efficacy of our Products, including in our marketing, and for other legally permissible purposes. 

How You May Review or Delete Your Personal Information

You may review the profile that you have developed in Hats & Ladders at any time by logging into your account. Authorized Institutions, Administrators, and Learners who are not affiliated with an Authorized Institution may request to access, change, or delete Personal Information or to close the account by submitting a Help Desk Request. 

Learners or parents of Learners using the Products under the authority of an Authorized Institution that is an education institution, should contact your institution to request access to, change, or delete the Learner’s Personal Information or close their account. We will work directly with the Authorized Institution to facilitate your request.

Opt-Out Policy

We may send you emails with information about our products that may be of interest. You may opt out of receiving these email messages from us by clicking on the “unsubscribe” link found in the footer of every email that we send or by contacting us at info@hatsandladders.com. Please note, however, that even if you have opted out of marketing emails, we may still send you service-related messages.

We do not send marketing emails to student Learners.

Links to Other Websites and Embedded Content

In certain of our Products, we include links to other websites and embed other websites’ video players and content. This Privacy Policy does not apply to third-party websites, video players, and content. We do not control the activities of third-party websites or embedded content or their privacy practices. The fact that we link to a website is not an endorsement of or representation of an affiliation with that website. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. 

Security

Hats & Ladders retains the information we collect on data servers using industry-standard protocols and technology. Hats & Ladders makes reasonable efforts to secure Personal Information in our care against unauthorized access and corruption. These efforts include the employment of physical, administrative, and technical safeguards based on currently available technology and practices. However, the internet is not perfectly secure, and we are not responsible for security incidents not reasonably within our control.

International Visitors

Our Products are operated and managed on servers located within the United States. 

User Privacy Rights

Certain US state laws provide their residents with certain rights related to their Personal Information. These rights include:

  • Right to Know and Access Personal Information: You may access Personal Information we maintain about you or your child under the age of 13 and request to receive it in a machine-readable copy to allow you to transfer it to another party without hindrance. 
  • Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you or your child under the age of 13.
  • Deletion of Personal Information: You may ask us to delete the Personal Information we maintain about you or your child under the age of 13 by using the methods provided below.

We do not engage in activities that would be considered a “sale” of Personal Information under US state privacy laws.

To help prevent unauthorized access to your Personal Information, we are required by law to verify your identity before fulfilling certain rights requests. Please also note that the rights above are subject to certain exemptions. As a result, depending on the scope and nature of the requests and applicable law, we may not be able to grant the rights in whole or in part. Where we are unable to fulfill your request in whole or in part, we will explain that in our response to you.

When authorized by law, you may be allowed to use an authorized agent to exercise the above privacy rights on your behalf. If you are an authorized agent acting on behalf of a state resident to communicate with us or to exercise a privacy right, you must be able to demonstrate that you have the necessary authorization and access to act on behalf of the resident. If you are an authorized agent trying to exercise rights on behalf of visitor to our Website, please contact us at the contact information below with supporting verification information required under applicable state law.

How To Exercise Your Rights

If you access or use the Products in connection with an Authorized Institution that is an education institution, you may exercise your rights by making a request to the education institution. We will work with them as necessary to respond to your request.  

For all others, to exercise your rights, you may Submit a Request at help.hatsandladders.com. Please explain what right(s) you would like to exercise and how you have interacted with us.

We will comply with your rights within the time frame required by applicable law. We don’t discriminate or otherwise penalize anyone for exercising their rights under this Privacy Policy.

Changes and Updates to this Privacy Policy

Hats & Ladders may modify or revise this Privacy Policy from time to time. If we make non-material changes, we will provide notice of the updated Privacy Policy as required by applicable law. If we make material changes, we will provide notice and request consent as required by applicable law. The “last updated” date at the top of this Privacy Policy indicates when it was last revised. 

The chart below includes a description of data that we may no longer collect, but have collected over the past 12 months. 

Categories of Personal Information Collected in Past 12 Months

From Administrators, we may collect, store, use and disclose:

  • No changes

From Learners, we may collect, store, use and disclose:

  • No changes

For additional details, see “Personal Information that We Collect,” above.

We Collect Your Personal Information from These Sources

  • Directly from you
  • From our customers

Our Purposes for Collecting Your Personal Information

We collect your Personal Information to provide the Services and for the following purposes:   Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;   Debugging to identify and repair errors that impair existing intended functionality;  Providing customer service;       Maintaining the quality of our service and to improve, upgrade, or enhance our service;

For additional details, see “How We Use Your Personal Information,” above.

Third Parties With Whom we Share Your Personal Information

We disclose the categories of Personal Information described above to service providers who support us in delivering the Services, as described above.

 

Contacting Hats & Ladders

Please contact Hats & Ladders with any questions or comments about this Privacy Policy by

email at info@hatsandladders.com, or Submit a Request at https://help.hatsandladders.com or by mail at: Hats & Ladders, 27 West 20th Street, #501, New York, NY 10011.