Hats & Ladders Privacy Policy (November 1, 2019)

This updated Privacy Policy went into effect on November 1, 2019.

This Privacy Policy applies to the Hats & Ladders websites, web applications, and related curricular materials (the “Products”) and governs data collection and usage. The Products are owned and operated by Hats & Ladders, Inc. (“Hats & Ladders”). By using our Products, you (“you,” or “User”) explicitly accept the collection and use of your data as described in this Privacy Policy. In addition, if you use Hats & Ladders through a school or other organizational sponsor that has contracted with Hats & Ladders to use the Products (“Authorized Institution”), that Authorized Institution may also have obtained your consent (or your parent’s or legal guardian’s consent) to the collection and use of your data as described in this Privacy Policy.

Hats & Ladders provides digital educational planning and counseling tools that enable Users to learn about themselves and connect to academic and career-related resources, information, activities, and pathways. The collection of information from our Users is inherent in the experience we provide.

Hats & Ladders is committed to ensuring the privacy of Users, including the teachers, advocates, administrators, counselors, and other professionals who support use of our Products in school or beyond school settings (“Administrators”).

To revoke your consent, please contact us at the addresses at the bottom of this Privacy Policy. If you do revoke your consent, your account and personally identifiable information will be deleted.

The Information that We Collect or Use

This is how we handle the data we gather when individual Users or Administrators use our Products (“Service Data”).

We collect information about you when you use our Products. Depending on the Products you use, we may collect:

• Your contact information such as email address, and the first name and last name associated with that email address
• Your month and year of birth, grade level, gender, and zip code
• Information relevant to college and career counseling, including information about your interests, academic preferences or aptitudes, in-school and extracurricular activities, personal values, obstacles you face, skills, and other career-related preferences and goals
• Information about your use of and interaction with the Products, such as the pages you view, the links you click, and other actions you take
• Technical information from your browser or device, such as your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, device and operating system, and the dates and times that you visit our Products
• Information about your academic or career-related activities or projects, including photographs or recordings of activities or projects
• Your group code, which is assigned by Hats & Ladders to associate you with your cohort 
• Administrators’ names, titles, and curricular responsibilities
• Information about Administrators’ use or administration of, or interaction with, our Products

How We Collect Information

Directly from You and Your Institution

When a school or other institution uses our Products, they may provide information about Users (including students, teachers, and administrators) to assist us in setting up the Products. We also collect information directly from Users when they create an account and as they use the Products.

Information You Share Through an Integrated Service

If you decide to share information with Hats & Ladders through a third-party social networking or integrated service (an “Integrated Service”), such as Facebook, you are giving Hats & Ladders the permission to use, share, and store that information consistent with this Privacy Policy.

Correspondence and Information Requests

Users may submit comments, questions, and other correspondence, and make requests for information about our Products. Personal information submitted in connection with such correspondence and requests is treated consistent with this Privacy Policy. For correspondence received from children we believe are under the age of 13, we will not disclose their information, and we will not contact them using the provided personal information without their parent’s or guardian’s consent or as otherwise permitted by law.

Information You Provide Automatically

As you navigate through and interact with our Products, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Products, including traffic data, logs, and other communication data and the resources that you access and use on the website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

Like most websites, we may send one or more cookies – small text files containing a string of alphanumeric characters – to the device by which you access our Products. Cookies collect and retain information about User activities on a website. Their use enables us to provide a more personalized experience to visitors.

Certain types of cookies disappear automatically after you close your browser. Others remain after you close your browser, though you may remove them at any time by modifying your browser’s cookie settings. Certain Hats & Ladders Products may not work properly without cookies.

When and How We Retain, Use, and Share the Information

How We Retain Information

Hats & Ladders retains the information we collect on data servers using industry standard protocols and technology. Hats & Ladders makes reasonable efforts to secure the information Users send to us against unauthorized access and corruption. These efforts include employment of physical, administrative, and technical safeguards based on currently available technology and practices.

Hats & Ladders will retain your personally identifiable information for so long as your account is active or as needed to provide you the Products. We retain your information that is not personally identifiable (for example, aggregate data about the potential careers Users mark as “favorites”) for as long as necessary, in our discretion, to provide our services, operate and improve our Products, and foster a positive, relevant, and personalized User experience. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this agreement.

How We Use Information

We use the information we collect to provide our services, operate and improve our Products, and foster a positive, relevant, and personalized User experience.

Our Products include the display of personalized content relating to a User’s career experience and interests. As a User, by logging into Hats & Ladders and managing your profile, you have consented for us to use your information in the following ways:

• To create your personalized map of interests, skills, academic preferences or aptitudes, personal values, obstacles you face, 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 access to special content or opportunities (including third party-sponsored content or opportunities) that align to your choices.

How We Share Information

Hats & Ladders does not rent or sell personal information that we collect to third parties.

Except as directed by the User or (if applicable) the Authorized Institution and except in the other specific cases noted below, Hats & Ladders does not disclose data that is identifiable to an individual to third parties other than our contractors and agents directly involved in the development and delivery of our Products. These contractors and agents who help us manage delivery of our Products and related information handling activities are required to use these data only as needed to perform the specific services they provide and not for any other purpose. We also do not use, and do not permit our contractors and agents to use, individual Users’ profiles for non-educational purposes, without the consent of the User or (if applicable) Authorized Institution.

Hats & Ladders contracts with the service providers below to assist us in providing the Products. Each service provider is contractually required to use these data only as needed to perform the specific services they provide, or as required by law. Where applicable, a link to each company’s privacy policy is provided below.

• Airtable for group code and content management
• Amazon Web Services for hosting services and data management
• Chartio (owned by Atlassian), for reporting
• Community Software Solutions, for data management in certain NYC programs
• Google for User authentication, communication and work management
• Grassroots Technologies, for technology consulting
• NYC.gov, for User authentication in certain NYC programs
• Panoply, for data storage
• Vimeo to host video content
• Wrike for project management
• YouTube to host video content
• Zendesk for help desk management

Sharing with Authorized Institutions and their Administrators

We provide Authorized Institutions and Administrators with private User names, passwords, or other identification credentials to access applicable Products and Service Data. These identification credentials allow Administrators to track Users’ progress and assignment completion.

Sharing in Promotional Materials

We may sometimes post correspondence or materials from Users on our website or in other promotional or informational materials. These materials may include User comments, testimonials, and contest results. When we post such material, we limit associated identity information to the applicable school/sponsoring organization, state/city/city neighborhood, and age or grade of User. We will not identify the author of such correspondence using personal information provided unless we obtain the User’s consent to do so.

Sharing with Third Parties Who Help Provide our Products and Services

Like many websites and apps, Hats & Ladders uses Google Analytics to analyze how people use our Products. We share aggregate information about the use of Hats & Ladders with Google for that purpose. Google uses the information we share to deliver and improve its services, including advertising. For more information, including opt-out options, please see Google’s policies (www.google.com/policies/privacy/partners/).

Hats & Ladders may also use other third-party service providers, such as YouTube to host videos, Google reCAPTCHA to detect misuse of our site forms, and Google Sign In (via OpenID Connect) as a secure authentication system. We may allow these third-party service providers to place and read their own cookies and similar technologies to collect information through the Products. This information is collected directly and automatically by these third parties, and Hats & Ladders does not participate in these data collections or transmissions.

Sharing Anonymous Aggregate Data for Research and Analysis

Hats & Ladders may also perform internal research and analysis on aggregated and anonymous Service Data to assess the effectiveness of the Products and make improvements. We may share aggregated and anonymous Service Data to authorized business partners to conduct research on educational technology or to assist in understanding the usage, viewing, or functionality of certain Products. Hats & Ladders may also publish results of research and analysis of aggregated and anonymous Service Data.

Sharing in Certain Special Cases

Hats & Ladders may disclose Service Data or website usage information (except those that constitute “education records” under FERPA) if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena or warrant, or administrative request. In some cases, we may make such disclosures without first providing notice to applicable Users.

Hats & Ladders may disclose FERPA-protected education records if required to do so by a judicial order or lawfully issued subpoena. Except as prohibited by a court order, before disclosing any student records in response to such an order, we will first make a reasonable effort to notify the student’s parent (or the student, where eligible) so that they may seek protective action.

Where permitted by law, Hats & Ladders may also disclose information as we believe in good faith is appropriate or necessary to take precautions against liability; to protect Hats & Ladders from fraudulent, abusive, or unlawful use of Products; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Products delivery; or to protect the rights, property, or personal safety of Hats & Ladders, our Users, or others.

In the event that Hats & Ladders is acquired by or merged with a third-party entity, and as permitted by law, we may transfer Service Data, and other information that we have collected, as part of such merger, acquisition, sale, or other change of control. In that event, we will display a notice on hatsandladders.com and the Hats & Ladders web-based application notifying you of the acquisition or merger. If you object to the transfer of your personally identifiable data to the acquiring or merging third party entity, you may close your account and your personally identifiable information will be deleted.

How You May Review and Change Your Information

You may review or reset the profile that you have developed in Hats & Ladders at any time by logging into your account.

You (or for Users under the age of majority, your parent or legal guardian) may also contact us using the information provided below to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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, such as the YouTube video player. Some of these websites, such as our Facebook page, may be co-branded with our name or logo. However, we cannot necessarily control the activities of third-party websites or embedded content. This Privacy Policy does not apply to such external links and embedded content, and we make no representations concerning the privacy policies followed by linked websites. We urge parents and Administrators to learn more about protecting children on the Internet by visiting the following site: ConnectSafely.org.

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

Hats & Ladders does not solicit and does not knowingly acquire, store, or use personal information relating to children who are less than 13 years of age without verifiable parental consent. As provided for by COPPA, Hats & Ladders relies on Authorized Institutions to obtain parental consent for the online collection of personal information from children who use Hats & Ladders through those Authorized Institutions. If Hats & Ladders learns that personal information of persons less than 13 years of age has been collected without parental consent, then Hats & Ladders will take appropriate steps to delete this information from our systems.

International Visitors

Our Products are operated and managed on servers located within the United States. If you choose to use our Products from a member state of the European Economic Area or another region of the world with laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring your personal information outside of those regions to the United States and that, by providing your personal information to Hats & Ladders, or through the Products, you consent to that transfer.

If you are a resident of a member state of the European Economic Area and believe that Hats & Ladders has not addressed your concerns regarding the use of your personal information in a satisfactory manner, you may report your complaint to your country’s supervisory authority.

Closing Your Account

If you would like to close your account, please contact us by email at info@hatsandladders.com or by phone at 920-574-9828. We will send you an email to confirm that your personally identifiable information has been deleted. We will respond to information access requests within 30 days. If we require additional time, we will acknowledge receipt of your request within 30 days and promptly supplement our response within the time period required by applicable law.

Changes and Updates to this Privacy Policy

Hats & Ladders may modify or revise this Privacy Policy from time to time. We may make non-material changes without advance notice. In the event there are material changes in the way we treat your personally identifiable information, or in the Privacy Policy document itself, we will display a notice on hatsandladders.com and the Hats & Ladders web-based application. If you object to any of the changes to our terms, and you no longer wish to use Hats & Ladders, you may close your account. Authorized Institutions that currently license Hats & Ladders will be notified by email of material changes to how we collect and use their Users’ personal information. If you object to any of the changes, and you no longer wish to use Hats & Ladders, you may close your account.

Contacting Hats & Ladders

Please contact Hats & Ladders with any questions or comments about this Privacy Policy by email at info@hatsandladders.com, by phone at 920-574-9828, or by mail at: Hats & Ladders, 27 West 20th Street, #501, New York, NY 10011.