You can read General Assembly's Privacy and Cookies Policy in the following ways:

  • Click through each section of the policy using the accordion links below.
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Privacy & Cookies Policy (Effective Date: December 15, 2013, Last Updated: August 15, 2021)

INTRODUCTION

 

This privacy policy (“Privacy Policy") is incorporated by reference into the General Assembly Terms of Service. 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 Australia Pty Ltd., an Australian proprietary limited company, General Assembly Space Academy Pte. Ltd, a Singapore private limited company, General Assembly Space Inc., an Ontario corporation, Bitmaker Labs Inc., an Ontario corporation, General Assembly France SAS, a société par actions simplifiée (SAS), General Assembly For Education LLC, a Saudi Arabian limited liability company, and any parent, subsidiary, or affiliate of any of the foregoing.

 

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy explains how General Assembly may collect and use Personal Information that we obtain through your use of the General Assembly website accessible at www.generalassemb.ly (the “Site”); social media pages or handles;  General Assembly’s online and offline products, courses, workshops, and events, including the cloud-based myGA assessment and learning platform also accessible through the Site (the “Platform”); our instructional products that are delivered through a variety of modalities, both in-person and online; and any accompanying services you are eligible to receive such as participation in GA’s Outcomes and Social Impact programs and support services (together, the “Services”). This Privacy Policy also provides you with notice about how and why your Personal Information will be used and the rights you have to access and control the use of your Personal Information.

APPLICATION OF THIS PRIVACY POLICY

 

By engaging with the Site and Services, you acknowledge that you have read and understood this Privacy Policy.

For users based in the EU and the UK, we are required to describe our role and our responsibility for Personal Information.

  • If you access and use the Site and/or the Services in your individual capacity, we are the “data controller” under EU privacy law.

 

  • If you access and use the Platform or any of the other Services in connection with an agreement entered into between your former, current, or  prospective employer (referred to herein as “Employer”) and General Assembly (the “Enterprise Agreement”), and in accordance with that Enterprise Agreement, your Employer remains the data controller for certain Personal Information you may be required to disclose in connection with your use of the Platform or other Services, the terms of that Enterprise Agreement shall apply with respect to the processing of the Personal Information set forth therein. In these instances, we act as a “data processor” under EU privacy law, meaning that we process your Personal Information to provide a service to your Employer and do so at their direction. If you have any questions about specific privacy practices in connection with your use of the Platform or other Services through your Employer, please contact your Employer.

 

  • If you access and use the Platform or other Services in connection with an Enterprise Agreement entered into between your Employer and General Assembly, or any parent, subsidiary, or affiliate thereof, and in accordance with that agreement, your Employer is not designated as the data controller with respect to any of your Personal Information, General Assembly will be the data controller.

 

By using the Site or the Services, you are authorizing us to gather and retain data related to the provision of the Site and Services in accordance with our Terms of Service. Those Terms of Service require you (for non-EU residents) to 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 Service or the Enterprise Agreement, as applicable. 

 

CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS

 

We collect the following categories of Personal Information:

Identity Data: Information we use to identify you, authenticate you as an authorized user of the Services, communicate with you, and record any transactions you make. This includes first name, maiden name, last name, login/user ID and password details, marital status, title, date of birth and gender, and social security number where required for reporting purposes. Identity data may also include your image if you participate in a course, class, workshop, or event that is recorded and you appear in the recording, or if you provide us with a picture of yourself and consent to our use of your picture on our Site or Services. 

Contact Data: Includes billing address, postal address, email address, telephone number, and mobile phone number.

Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site and Services.

Usage Data: Includes information about how you use the Site and Services. 

Transaction Data: Includes details of the Services for which you have previously registered and/or in which you have been enrolled.

Financial Data: In limited circumstances, we may collect payment information for processing of payments, but this information generally is collected and processed directly by our payment services providers. We may also ask you for your banking information in limited circumstances where we need to make a payment to you. Such bank information may include, but is not limited to, your bank account number, routing transit number, credit card, or other bank account details. 

Assessment Data: Information on your aptitude in certain technology-based subject areas and your performance on General Assembly’s capabilities and learning-needs assessments.

Profile Data: Includes, if applicable and, in most cases, only when you choose to provide such information to us as part of the Services, your interests; preferences; social media account(s); demographic information, including but not limited to age, gender, race; education level; resume information; professional portfolio link; economic information or employment status; criminal history; immigration status; disability or accommodation information; and feedback and survey responses.  Profile Data may also include information that you provide to us voluntarily throughout your journey as a GA student.

Marketing and Communications Data: Includes your preferences with respect to receiving marketing from us and/or our third-party partners and your communication preferences.

 

DE-IDENTIFIED DATA

 

We also collect, use, and share de-identified data such as statistical or demographic data for various purposes. We may use this type of data to analyze trends with respect to skills, jobs, employment, and the workforce generally; to administer, analyze, and improve the content and functionality of the Site and Services; for marketing; and to gather demographic information about our user base as a whole. We utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of the Site or Services experience.

If we combine or connect de-identified data with your Personal Information in such a way that it can directly or indirectly identify you, we treat the combined data as Personal Information and only use it in accordance with the terms of this Privacy Policy.

We reserve the right to use de-identified data for any purpose, including, but not limited to, those set forth above. We may also disclose such data to our Enterprise clients, partners or third-party service providers, except as otherwise provided in this Privacy Policy.

 

FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION

Where we are required to collect certain Personal Information by law or under the terms of a contract with you or your Employer, and you fail to provide that data when requested, we may not be able to perform under the respective contract and may not be able to provide access to or use of the Services. In the situation where we have already entered into a contract with you, we may be required to cancel the provision of the Services, but we will notify you in advance of such cancellation if this is the case.

HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Site, Platform, and Services together and with our business records. We may use and share information that we de-identify at our discretion.

Direct Interaction

We collect your Personal Information when you:

  • Create an account on the Site or register to use the Services;

  • Register or apply for a Course, Class, Workshop, or any other Services on the Site, through any of the Services or via 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 Services 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 Services, 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 run by us or by the third-party organizations with which we partner.

  • Submit information to inquire about or apply for a job with us.

 

Automated Technologies or Interactions

As you interact with our Site and/or Services, we also collect technical data such as usage statistics about your equipment, browsing actions, and patterns. We collect this information by using cookies, server logs, and other similar technology. See below for more information on our use of cookies.

 

Third-Party Sources

We may also receive Personal Information about you from various third parties and public sources.

 

COOKIES, AUTOMATIC DATA COLLECTION, & RELATED TECHNOLOGIES

 

When you visit the Site or use the Services, 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 browsing history, 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 Services from, and your operating system.

Cookies are small text files that include a unique reference code placed on a visitor’s 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 Services and will last for longer. Some cookies are necessary to enable you to move around the Site and use the Services, 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 Services. We use this information to make improvements to the Site and our Services and to enhance your overall experience. Other cookies, called “functionality cookies,” allow the Site and Services to remember choices you make, such as your user name when you log in 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 and service providers, 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 and service providers to serve interest-based advertisements when you visit our Site and other websites, and our third-party vendors and service providers will combine it with other information from your visits to other websites and apps to learn more about your interests. 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 pages of the following industry organizations: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Without these cookies, advertisements you encounter will be less relevant to you and to your interests. Exercising these options will not prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.

“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.

 

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/.

A complete list of our cookies is accessible at https://generalassemb.ly/rolling-cookies-policy.  

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 Services, or within the body of our newsletters so we or third parties can understand which parts of the Site and Services 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 Flash cookies using your browser settings; however, information on how to do this is available from the Adobe website at http://www.adobe.com/products/flashplayer/security.

 

Disabling Cookies

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. The effect of disabling cookies depends on which cookies you disable, but please note that if you do that, the Site and Services may not work properly, and you may not be able to take full advantage of the Site or our Services. 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.

Details on how to review your cookie settings and disable cookies on the most popular browsers are set forth below:

Microsoft Internet Explorer:

  • From the menu bar, choose “Tools” then “Internet Options.”

  • Click on the “Privacy” tab.

  • Select the appropriate settings.

 

Google Chrome:

  • From the menu bar, choose “Chrome” then “Preferences.”

  • On the “Settings” page, scroll down and click “Privacy and Security.”

  • Under “Privacy and Security,” click “Cookies and other site data.” 

  • Select the appropriate settings.

 

Safari:

  • From the menu bar, choose “Safari” then “Preferences.”

  • From the “Preferences” box, choose the “Privacy” tab in the menu bar.

  • Select the appropriate settings in the “Website tracking” menu.

  • Click on “Manage Website Data” and make the appropriate selections.

 

Mozilla Firefox:

  • From the menu bar, choose “Options” then “Privacy and Security.”

  • Scroll down to Cookies and Site Data.

  • Select the appropriate settings.

 

PURPOSES FOR WHICH GENERAL ASSEMBLY USES YOUR INFORMATION

 

We have set forth below the ways in which we may use your Personal Information, along with our lawful bases for each use. We may use your consent as our lawful basis of processing, and if we do, we will ask you for it at the time we collect your Personal Information.

Please note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information.  Please contact us if you need more information about the specific legal ground on which we are relying to process your Personal Information:

Purpose/Activity

Type of Data

Lawful Basis for Processing

To identify you and your account and to enable you to register to use the Services.

  • Identity Data
  • Contact Data
  • Assessment Data

Necessary (i) to allow you to access the Services, (ii) for the performance of a contract with you, your Employer, or our partners and service providers, and (iii) for our legitimate business interest in being able to provide the Services to you.

To manage and process payments, fees, and charges for the Services.

  • Identity Data
  • Contact Data
  • Financial Data

Necessary (i) for the
performance of a contract
with you, your Employer, or
our partners and service
providers and (ii) for our
legitimate business interest
to obtain payments due to us
for Services.

To facilitate and deliver the Services.

  • Identity Data
  • Contact Data
  • Assessment Data
  • Profile Data
  • Financial Data

Necessary (i) to provide the Services to you and/or your Employer, as applicable, (ii) for the performance of a contract with you, your Employer, or our partners and service providers, and (iii) for our legitimate business interest in being able to provide the Services to you.

To manage our relationship with you, including:
 

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Notifying you about any changes to our Services, timetables for the Services, requirements for the Services, and any technical requirements.
  • Identity Data
  • Contact Data
  • Profile Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Providing you with feedback on your participation and performance in the Services.
  • Identity Data
  • Contact Data
  • Profiles Data
  • Usage Data
  • Assessment Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Reviewing and scoring your Assessments and course work and certifying your completion of the relevant Services.
  • Identity Data
  • Contact Data
  • Assessment Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Notifying you of any changes to this or any other policy.
  • Identity Data
  • Contact Data

Necessary for our compliance with our legal obligations under applicable data privacy laws.

  • Asking you to complete a review or take a survey. 
  • Identity Data
  • Contact Data
  • Marketing & Communications Data

Necessary for our legitimate business interests (i) in keeping our records updated, (ii) understanding how customers use and rate our Services, (iii) providing you an excellent customer experience during the course of the Services, and (iv) ensuring we continuously improve our Services to meet the needs and demands of our clients and students.

To provide our Site and its content to you and to enhance users’ experience.

  • Identity Data
  • Technical Data
  • Profile Data
  • Usage Data

Necessary for our legitimate business interest in being able to provide the Site and Services to you and to improve the Site and Services to best meet your needs and use.

To improve the functionality of the Site or Services and to provide related customer service.

  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers and (ii) for our legitimate business interests in (a) being able to provide the Services to you and/or your Employer, as applicable, (b) providing administration and IT services and network security in connection with the Services, (c) providing you an excellent customer experience during the course of the Services, and (d) ensuring we constantly improve our Services to meet the needs and demands of our clients and students.

To administer and protect the Site and Services (including troubleshooting, data analysis, testing, and system review).

  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, and (ii) for our legitimate business interests in (a) being able to provide the Services to you and/or your Employer, as applicable, (b) providing administration and IT services and network security in connection with the Services, (c) providing you an excellent customer experience during the course of the Services, and (d) ensuring we constantly improve our Services to meet the needs and demands of our clients and students.

To respond to your communications and send you information that you request or agree to receive, via regular or electronic mail, text message, or other marketing channels.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers and (ii) for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

To make suggestions and recommendations to you about other courses and services that may be of interest to you.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

To allow you to partake in a competition or promotion.

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing & Communications Data

Necessary for our legitimate business interest in encouraging users to visit the Site and use the Services and in the general promotion of our business.

 

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.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

 

 

CHANGE OF PURPOSE

We will only use your Personal Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at privacy@ga.co. If we need to use your Personal Information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do this.

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. We do not require your details of race or ethnic origin or your disability status, and it will not affect your application in any way if you do not provide such information. Where you do provide such information, we will use that information only as permitted by law for the purposes of diversity and equal opportunity monitoring. 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 and where applicable law allows. 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.

For more information about the Personal Information we may collect from job applicants and the purposes for which we use that information, please refer to the relevant job posting on the Careers’ page of our Site, including, if applicable, any privacy notices included therein.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

If you are located outside of the United States, please note that the Personal Information that you submit will be transferred to, processed, and stored in the United States (and may also be stored in the relevant jurisdiction(s), as required by applicable law, 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, if such consent is permitted by applicable law. For more information about the transfer of Personal Information to the United States, please refer to the section of this Privacy Policy entitled “Transfers of Personal Information to 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 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 no.marketing@ga.co

Please note that if you have registered an account on the Site or Services or are registered for a Course, opting out of receiving marketing messages will not apply to Personal Information provided to us as a result of signing up to use our Site or Services, and we reserve the right to send you certain communications relating to your account, your registration, and your use of the Site and Services, such as messages relating to account management, customer service, and system maintenance. These transactional account messages will thus be unaffected if you choose to opt out of marketing communications.  

 

HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

Vendors and Third-Party Service Providers: We may share any information we receive, including your Personal Information, with vendors or service providers, including Instructors, retained in connection with the provision of the Site or Services. This includes, but is not limited to, those providing website and data hosting services (e.g., Amazon Web Services and Heroku), distributing communications and supporting or updating marketing lists (e.g., Sailthru and Salesforce), facilitating feedback on our services (e.g., Survey Monkey); and providing IT support services from time to time. These organizations (which may include third-party suppliers, agents, subcontractors, and/or other affiliates) will only use your information to the extent necessary to perform their support functions. In addition, where necessary, we have entered into Data Processing Agreements or service provider agreements with these third-party service providers, which require the service providers to both keep that information confidential and not use it for any purpose except to the extent necessary to perform their support functions.

Payment Transactions: 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. You will be providing debit or credit card information directly to our payment solutions provider that operates a secure server to process payment details, encrypting your credit/debit card information, and authorizing payment. Information that you supply to our payment solutions provider is not stored by us or within our control and is subject to our payment solutions provider's own privacy policy and terms and conditions.

Enterprise and Partnership Agreements: If you access and use the Platform or any of the other Services in connection with an Enterprise Agreement or other agreement between GA and a third-party with whom we partner to provide you the Services, we may share your Personal Information with your Employer or our partner in accordance with the terms of that Enterprise Agreement or partnership agreement, as applicable. The use of your Personal Information by such organizations will be governed by their privacy policies.

Outcomes Partners: If you sign-up to participate in our Outcomes program, we may share your Personal Information with our third-party hiring partners for purposes of highlighting your profile for a particular role at the hiring partner.  These organizations will use your Personal Information for purposes of determining your eligibility or suitability for available roles. The use of information by such organizations will be governed by their privacy policies. 

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 Services may be displayed publicly. Other users of the Site or Services 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 Services, and we are not responsible for the use of any Personal Information by third parties that you publicly post on the Site or Services. If you participate in a course, class, workshop, or event that is recorded and you appear in the recording, your image may be visible to other participants of that course, class, workshop, or event. 

Social Networking and Other Websites: The Site or Services may allow you to post information to social networking websites. We do not share your information with such social networking websites unless you direct the Site or Services 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 processes, such as a court order, warrant or subpoena; respond to your requests; enforce our policies related to our Site or Services, 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 a legal 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 one of the transferred assets 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. You may withdraw consent to disclosures where you have previously given specific consent by emailing us at privacy@ga.co.

 

 

SECURITY OF YOUR INFORMATION

 

We have implemented physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. In addition, we limit access to your Personal Information to only those employees, agents, contractors, and other third parties who need to have access to such information for the operation of our business, including the operation of the Site and Services. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality.

As noted above, 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 Services, 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 Services like message boards. The information you share in public areas may be viewed by any user of the Site or the Services.

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

 

 

CHILDREN'S PRIVACY

Our Site and the Services are not intended for nor directed toward children under the age of 16, and we do not knowingly collect personal information from children under 16 years of age. If you believe that your child under the age of 16 may have provided us with Personal Information without your consent, you may alert us at privacy@ga.co. If we learn that we have inadvertently collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child's account.

EXTERNAL LINKS

The Site or Services may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over these third parties, and we are not responsible for the content of such websites or the privacy policies or practices of such third parties. You should carefully review the privacy policy of any such third-party website that you visit.

TRANSFERS OF PERSONAL INFORMATION TO THE UNITED STATES

 

The Site and the Services 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 and processed and stored in the United States. 

For purposes of the Data Protection Act 1998, the General Data Protection Regulation 2016/679 (the GDPR) and any corresponding or equivalent national implementing law or regulations, if you are located in the United Kingdom, 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.  If you are located in France, General Assembly France SAS is the data controller with respect to any information collected by it in France and then transferred to General Assembly Space, Inc. in the United States.  

All transfers of Personal Information from the European Economic Area, the United Kingdom, or Switzerland to the United States are done pursuant to the European Commission’s standard contractual clauses or, when possible, the binding corporate rules of our third-party vendors, suppliers, or service providers, if applicable.  

General Assembly acknowledges that EU and Swiss authorities have invalidated the Privacy Shield, meaning that it is no longer a lawful basis that General Assembly can use to transfer information from the EU or Switzerland to the US. However, we continue to process personal data consistent with the Privacy Shield principles and remain certified to the program, which requires us to make the representations below.

General Assembly complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (the "Privacy Shield Principles") set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information. General Assembly has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Program and to view our certification, please visit https://www.privacyshield.gov/

As part of our participation in the U.S.-EU and Swiss-U.S. Privacy Shield certification programs, we have further committed to refer unresolved Privacy Shield complaints to JAMS. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield or, to file a complaint, visit https://www.jamsadr.com/eu-us-privacy-shield. The services of JAMS are provided at no cost to you.

EU, UK, and Swiss individuals with inquiries or complaints regarding our Privacy Shield practices should first contact us at privacy@ga.co. All emails received will be handled by a representative of our Legal Department. For more information on the dispute resolution process, please contact us at privacy@ga.co. 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). In certain situations, General Assembly Space, Inc. may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. 

General Assembly Space, Inc. is responsible and remains liable for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. General Assembly Space, Inc. complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, UK, and Switzerland, including the onward transfer liability provisions.

You have a legal right to request the Personal Information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend, or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.

Please see elsewhere in this Privacy Policy for more information on types of Personal Information collected, purposes for data collection, types of third parties receiving Personal Information, and purposes of disclosure to such parties and your legal rights.

 

PRIVACY DISCLOSURES FOR SPECIFIC JURISDICTIONS

 

California

Your California Privacy Rights; “Shine the Light” Law

We do not disclose Personal Information about you to third parties 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, or we are required to do so by law.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of Personal Information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
For more information about how we may share your Personal Information, please refer to the section of this Privacy Policy entitled “How General Assembly May Share Your Personal Information.” 

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described in “Purposes for which General Assembly Uses Your Information.”

 

Category

Information Type

Source

We disclose to:

We sell* to:

Identifiers

  • Contact information or personal characteristics (name; email address; postal address; telephone number; image; signature)
  • Social media handles

You; our social media pages; third party subscription service providers

Service Providers Not sold
 
Health Information
  • Health information you volunteer if you apply for a job
You  Service Providers Not sold
 
Financial Information
  • Payment card data
  • Bank account information
  • Credit information
You  Service Providers Not sold
 
Protected Classifications and Other Sensitive Data
  • Date of Birth
  • Gender
  • Race
  • Criminal history 
  • Immigration status 
  • Disability or accommodation information
You  Service Providers Not sold
 
Commercial Information
  • Transaction information 
  • Billing and payment records
  • Order history
  • Obtained services  
You  Service Providers Not sold
 
Geolocation Information
  • Coarse (information that describes location at ZIP code-level or less precision)
You; our analytics and advertising partners Service Providers Advertising partners (coarse location only)
Internet or Electronic Network Activity Information
  • IP address
  • Login data
  • Browser type and version
  • Time zone setting and location
  • Brower plug-in types and versions
  • Operating system and platform
  • Device identifier (e.g., MAC)
  • Advertising identifier (e.g., IDFA, AAID)
  • Information provided in URL string (e.g., search keywords)
  • Cookie or tracking pixel information
  • Information about your interaction with our website, app, email correspondence, or products
  • Browsing history
  • Search history
  • Diagnostic information (e.g., crash logs, performance data)
You; our analytics and advertising partners Service Providers Advertising partners
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
  • Call recordings 
  • Photographs
  • Video
You Service Providers Not sold
 
Professional or Employment-Related Information
  • Current employer
  • Job title
You Service Providers Not sold
 
Education Information
  • Education history
  • Level of education
You Service Providers Not sold
 
Inferences Drawn About You
  • User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (including Assessment Data) 
You; our analytics and advertising partners Service Providers Advertising partners
Content of Communications
  • Contents of phone calls, emails, or text messages (if you contact us through any of those means)
You Service Providers Not sold

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement. 
* The CCPA’s definition of “sell” is very broad and can include certain everyday business activities. In our case, a “sale” occurs between us and our advertising and marketing partners when those partners collect information about your visit to our website. Please rest assured that we do not sell information that directly identifies you—such as your name, email, or address—to third parties.
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 of this Privacy Policy entitled "Cookies, Automatic Data Collection, and Related Technologies."  

For information about your privacy rights, please refer to the section of this Privacy Policy entitled “Your Legal Rights.” 

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. We do not sell personal information under Nevada law.
If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

DATA RETENTION

We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at privacy@ga.co.

 

DATA RETENTION

 

We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at privacy@ga.co.

 

YOUR LEGAL RIGHTS

 

Individuals from different countries or jurisdictions may have different rights. We reserve the ability to limit our response to your request to exercise your rights based on the law that is applicable to you. These rights include your ability: 

  • To opt out of sale of personal information to third parties, if applicable. Your right to opt out does not apply to our sharing of personal information with service providers.
  • To request more information about how we process your Personal Information. 
  • To be provided with a copy of your Personal Information held by us.
  • To request that we correct any of your Personal Information held by us.
  • To request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example).
  • To object to any further processing of your Personal Information, including the right to object to marketing.
  • To request that the Personal Information you have provided be transferred to a third party.
  • To withdraw consent, without detriment, where the basis of the processing of your Personal Information is based on consent.
  • To request that we delete any of your Personal Information held by us unless a legal exception applies.

 

To exercise your rights, please submit your verifiable request here. California residents may also exercise their privacy rights by calling us at 1-833-248-6276.      

You will not have to pay a fee to access your Personal Information (or exercise any other rights). We may, however, charge a fee if we believe your request is excessive, unfounded, or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.

In response to any of the requests outlined above, we may need to request specific information from you to enable us to confirm your identity and to ensure you have the right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that your Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response time.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If your request or concern is not satisfactorily resolved by us, and you are located in the EU or UK, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index en.html) who can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.

 

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

 

It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information you have provided to us through your use of the Site or Services by sending an email to privacy@ga.co.

If you have questions about unsubscribing from email or other communications, you may send an email to privacy@ga.co or no.marketing@ga.co.

Please share any suggestions you may have for improving this Privacy Policy by sending an email to privacy@ga.co

 

CHANGES TO OUR PRIVACY POLICY & 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:

Legal Department
General Assembly
915 Broadway, 3rd Floor
New York, New York, 10010

Email address: privacy@ga.co

 

PRIVACY & COOKIES POLICY 

Effective Date: December 15, 2013 

Last Updated: August 15, 2021

 

TABLE OF CONTENTS

  • INTRODUCTION

  • PURPOSE OF THIS PRIVACY POLICY

  • APPLICATION OF THIS PRIVACY POLICY

  • THE CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS 

  • DE-IDENTIFIED DATA

  • FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION

  • HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION

  • COOKIES, AUTOMATIC DATA COLLECTION, & RELATED TECHNOLOGIES

  • PURPOSES FOR WHICH GENERAL ASSEMBLY USES YOUR INFORMATION

  • CHANGE OF PURPOSE

  • NOTICE TO JOB APPLICANTS

  • HOW TO OPT OUT OF FUTURE COMMUNICATIONS

  • HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

  • SECURITY OF YOUR INFORMATION

  • CHILDREN'S PRIVACY

  • EXTERNAL LINKS

  • TRANSFERS OF PERSONAL INFORMATION TO THE UNITED STATES

  • PRIVACY DISCLOSURES FOR SPECIFIC JURISDICTIONS

  • DATA RETENTION

  • YOUR LEGAL RIGHTS

  • UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

  • CHANGES TO OUR PRIVACY POLICY & PRACTICES

  • CONTACT INFORMATION

 

INTRODUCTION

This privacy policy (“Privacy Policy") is incorporated by reference into the General Assembly Terms of Service. 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 Australia Pty Ltd., an Australian proprietary limited company, General Assembly Space Academy Pte. Ltd, a Singapore private limited company, General Assembly Space Inc., an Ontario corporation, Bitmaker Labs Inc., an Ontario corporation, General Assembly France SAS, a société par actions simplifiée (SAS), General Assembly For Education LLC, a Saudi Arabian limited liability company, and any parent, subsidiary, or affiliate of any of the foregoing.

 

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy explains how General Assembly may collect and use Personal Information that we obtain through your use of the General Assembly website accessible at www.generalassemb.ly (the “Site”); social media pages or handles;  General Assembly’s online and offline products, courses, workshops, and events, including the cloud-based myGA assessment and learning platform also accessible through the Site (the “Platform”); our instructional products that are delivered through a variety of modalities, both in-person and online; and any accompanying services you are eligible to receive such as participation in GA’s Outcomes and Social Impact programs and support services (together, the “Services”). This Privacy Policy also provides you with notice about how and why your Personal Information will be used and the rights you have to access and control the use of your Personal Information.

 

APPLICATION OF THIS PRIVACY POLICY

By engaging with the Site and Services, you acknowledge that you have read and understood this Privacy Policy.

For users based in the EU and the UK, we are required to describe our role and our responsibility for Personal Information.

  • If you access and use the Site and/or the Services in your individual capacity, we are the “data controller” under EU privacy law.

 

  • If you access and use the Platform or any of the other Services in connection with an agreement entered into between your former, current, or  prospective employer (referred to herein as “Employer”) and General Assembly (the “Enterprise Agreement”), and in accordance with that Enterprise Agreement, your Employer remains the data controller for certain Personal Information you may be required to disclose in connection with your use of the Platform or other Services, the terms of that Enterprise Agreement shall apply with respect to the processing of the Personal Information set forth therein. In these instances, we act as a “data processor” under EU privacy law, meaning that we process your Personal Information to provide a service to your Employer and do so at their direction. If you have any questions about specific privacy practices in connection with your use of the Platform or other Services through your Employer, please contact your Employer.

 

  • If you access and use the Platform or other Services in connection with an Enterprise Agreement entered into between your Employer and General Assembly, or any parent, subsidiary, or affiliate thereof, and in accordance with that agreement, your Employer is not designated as the data controller with respect to any of your Personal Information, General Assembly will be the data controller.

 

By using the Site or the Services, you are authorizing us to gather and retain data related to the provision of the Site and Services in accordance with our Terms of Service. Those Terms of Service require you (for non-EU residents) to 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 Service or the Enterprise Agreement, as applicable. 

 

THE CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS 

We collect the following categories of Personal Information:

Identity Data: Information we use to identify you, authenticate you as an authorized user of the Services, communicate with you, and record any transactions you make. This includes first name, maiden name, last name, login/user ID and password details, marital status, title, date of birth and gender, and social security number where required for reporting purposes. Identity data may also include your image if you participate in a course, class, workshop, or event that is recorded and you appear in the recording, or if you provide us with a picture of yourself and consent to our use of your picture on our Site or Services. 

Contact Data: Includes billing address, postal address, email address, telephone number, and mobile phone number.

Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site and Services.

Usage Data: Includes information about how you use the Site and Services. 

Transaction Data: Includes details of the Services for which you have previously registered and/or in which you have been enrolled.

Financial Data: In limited circumstances, we may collect payment information for processing of payments, but this information generally is collected and processed directly by our payment services providers. We may also ask you for your banking information in limited circumstances where we need to make a payment to you. Such bank information may include, but is not limited to, your bank account number, routing transit number, credit card, or other bank account details. 

Assessment Data: Information on your aptitude in certain technology-based subject areas and your performance on General Assembly’s capabilities and learning-needs assessments.

Profile Data: Includes, if applicable and, in most cases, only when you choose to provide such information to us as part of the Services, your interests; preferences; social media account(s); demographic information, including but not limited to age, gender, race; education level; resume information; professional portfolio link; economic information or employment status; criminal history; immigration status; disability or accommodation information; and feedback and survey responses.  Profile Data may also include information that you provide to us voluntarily throughout your journey as a GA student.

Marketing and Communications Data: Includes your preferences with respect to receiving marketing from us and/or our third-party partners and your communication preferences.

 

DE-IDENTIFIED DATA

We also collect, use, and share de-identified data such as statistical or demographic data for various purposes. We may use this type of data to analyze trends with respect to skills, jobs, employment, and the workforce generally; to administer, analyze, and improve the content and functionality of the Site and Services; for marketing; and to gather demographic information about our user base as a whole. We utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of the Site or Services experience.

If we combine or connect de-identified data with your Personal Information in such a way that it can directly or indirectly identify you, we treat the combined data as Personal Information and only use it in accordance with the terms of this Privacy Policy.

We reserve the right to use de-identified data for any purpose, including, but not limited to, those set forth above. We may also disclose such data to our Enterprise clients, partners or third-party service providers, except as otherwise provided in this Privacy Policy.

 

FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION

Where we are required to collect certain Personal Information by law or under the terms of a contract with you or your Employer, and you fail to provide that data when requested, we may not be able to perform under the respective contract and may not be able to provide access to or use of the Services. In the situation where we have already entered into a contract with you, we may be required to cancel the provision of the Services, but we will notify you in advance of such cancellation if this is the case.

 

HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Site, Platform, and Services together and with our business records. We may use and share information that we de-identify at our discretion.

Direct Interaction

We collect your Personal Information when you:

  • Create an account on the Site or register to use the Services;

  • Register or apply for a Course, Class, Workshop, or any other Services on the Site, through any of the Services or via 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 Services 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 Services, 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 run by us or by the third-party organizations with which we partner.

  • Submit information to inquire about or apply for a job with us.

 

Automated Technologies or Interactions

As you interact with our Site and/or Services, we also collect technical data such as usage statistics about your equipment, browsing actions, and patterns. We collect this information by using cookies, server logs, and other similar technology. See below for more information on our use of cookies.

Third-Party Sources

We may also receive Personal Information about you from various third parties and public sources.

 

COOKIES, AUTOMATIC DATA COLLECTION, & RELATED TECHNOLOGIES

When you visit the Site or use the Services, 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 browsing history, 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 Services from, and your operating system.

Cookies are small text files that include a unique reference code placed on a visitor’s 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 Services and will last for longer. Some cookies are necessary to enable you to move around the Site and use the Services, 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 Services. We use this information to make improvements to the Site and our Services and to enhance your overall experience. Other cookies, called “functionality cookies,” allow the Site and Services to remember choices you make, such as your user name when you log in 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 and service providers, 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 and service providers to serve interest-based advertisements when you visit our Site and other websites, and our third-party vendors and service providers will combine it with other information from your visits to other websites and apps to learn more about your interests. 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 pages of the following industry organizations: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Without these cookies, advertisements you encounter will be less relevant to you and to your interests. Exercising these options will not prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.

“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.

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/.

A complete list of our cookies is accessible at https://generalassemb.ly/rolling-cookies-policy.  

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 Services, or within the body of our newsletters so we or third parties can understand which parts of the Site and Services 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 Flash cookies using your browser settings; however, information on how to do this is available from the Adobe website at http://www.adobe.com/products/flashplayer/security.

 

Disabling Cookies

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. The effect of disabling cookies depends on which cookies you disable, but please note that if you do that, the Site and Services may not work properly, and you may not be able to take full advantage of the Site or our Services. 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.

Details on how to review your cookie settings and disable cookies on the most popular browsers are set forth below:

Microsoft Internet Explorer:

  • From the menu bar, choose “Tools” then “Internet Options.”

  • Click on the “Privacy” tab.

  • Select the appropriate settings.

 

Google Chrome:

  • From the menu bar, choose “Chrome” then “Preferences.”

  • On the “Settings” page, scroll down and click “Privacy and Security.”

  • Under “Privacy and Security,” click “Cookies and other site data.” 

  • Select the appropriate settings.

 

Safari:

  • From the menu bar, choose “Safari” then “Preferences.”

  • From the “Preferences” box, choose the “Privacy” tab in the menu bar.

  • Select the appropriate settings in the “Website tracking” menu.

  • Click on “Manage Website Data” and make the appropriate selections.

 

Mozilla Firefox:

  • From the menu bar, choose “Options” then “Privacy and Security.”

  • Scroll down to Cookies and Site Data.

  • Select the appropriate settings.

 

PURPOSES FOR WHICH GENERAL ASSEMBLY USES YOUR INFORMATION

We have set forth below the ways in which we may use your Personal Information, along with our lawful bases for each use. We may use your consent as our lawful basis of processing, and if we do, we will ask you for it at the time we collect your Personal Information.

Please note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information.  Please contact us if you need more information about the specific legal ground on which we are relying to process your Personal Information:

Purpose/Activity

Type of Data

Lawful Basis for Processing

To identify you and your account and to enable you to register to use the Services.

  • Identity Data
  • Contact Data
  • Assessment Data

Necessary (i) to allow you to access the Services, (ii) for the performance of a contract with you, your Employer, or our partners and service providers, and (iii) for our legitimate business interest in being able to provide the Services to you.

To manage and process payments, fees, and charges for the Services.

  • Identity Data
  • Contact Data
  • Financial Data

Necessary (i) for the
performance of a contract
with you, your Employer, or
our partners and service
providers and (ii) for our
legitimate business interest
to obtain payments due to us
for Services.

To facilitate and deliver the Services.

  • Identity Data
  • Contact Data
  • Assessment Data
  • Profile Data
  • Financial Data

Necessary (i) to provide the Services to you and/or your Employer, as applicable, (ii) for the performance of a contract with you, your Employer, or our partners and service providers, and (iii) for our legitimate business interest in being able to provide the Services to you.

To manage our relationship with you, including:
 

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Notifying you about any changes to our Services, timetables for the Services, requirements for the Services, and any technical requirements.
  • Identity Data
  • Contact Data
  • Profile Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Providing you with feedback on your participation and performance in the Services.
  • Identity Data
  • Contact Data
  • Profiles Data
  • Usage Data
  • Assessment Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Reviewing and scoring your Assessments and course work and certifying your completion of the relevant Services.
  • Identity Data
  • Contact Data
  • Assessment Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, (ii) for our legitimate business interest in being able to provide the Services to you and/or your Employer, as applicable, and (iii) to provide an excellent customer experience to you during the course of the Services.

  • Notifying you of any changes to this or any other policy.
  • Identity Data
  • Contact Data

Necessary for our compliance with our legal obligations under applicable data privacy laws.

  • Asking you to complete a review or take a survey. 
  • Identity Data
  • Contact Data
  • Marketing & Communications Data

Necessary for our legitimate business interests (i) in keeping our records updated, (ii) understanding how customers use and rate our Services, (iii) providing you an excellent customer experience during the course of the Services, and (iv) ensuring we continuously improve our Services to meet the needs and demands of our clients and students.

To provide our Site and its content to you and to enhance users’ experience.

  • Identity Data
  • Technical Data
  • Profile Data
  • Usage Data

Necessary for our legitimate business interest in being able to provide the Site and Services to you and to improve the Site and Services to best meet your needs and use.

To improve the functionality of the Site or Services and to provide related customer service.

  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers and (ii) for our legitimate business interests in (a) being able to provide the Services to you and/or your Employer, as applicable, (b) providing administration and IT services and network security in connection with the Services, (c) providing you an excellent customer experience during the course of the Services, and (d) ensuring we constantly improve our Services to meet the needs and demands of our clients and students.

To administer and protect the Site and Services (including troubleshooting, data analysis, testing, and system review).

  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers, and (ii) for our legitimate business interests in (a) being able to provide the Services to you and/or your Employer, as applicable, (b) providing administration and IT services and network security in connection with the Services, (c) providing you an excellent customer experience during the course of the Services, and (d) ensuring we constantly improve our Services to meet the needs and demands of our clients and students.

To respond to your communications and send you information that you request or agree to receive, via regular or electronic mail, text message, or other marketing channels.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary (i) for the performance of a contract with you, your Employer, or our partners and service providers and (ii) for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

To make suggestions and recommendations to you about other courses and services that may be of interest to you.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

To allow you to partake in a competition or promotion.

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing & Communications Data

Necessary for our legitimate business interest in encouraging users to visit the Site and use the Services and in the general promotion of our business.

 

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.

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing & Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services and in continuing to grow our business.

 

CHANGE OF PURPOSE

We will only use your Personal Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at privacy@ga.co. If we need to use your Personal Information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do this.

 

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. We do not require your details of race or ethnic origin or your disability status, and it will not affect your application in any way if you do not provide such information. Where you do provide such information, we will use that information only as permitted by law for the purposes of diversity and equal opportunity monitoring. 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 and where applicable law allows. 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.

For more information about the Personal Information we may collect from job applicants and the purposes for which we use that information, please refer to the relevant job posting on the Careers’ page of our Site, including, if applicable, any privacy notices included therein.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

If you are located outside of the United States, please note that the Personal Information that you submit will be transferred to, processed, and stored in the United States (and may also be stored in the relevant jurisdiction(s), as required by applicable law, 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, if such consent is permitted by applicable law. For more information about the transfer of Personal Information to the United States, please refer to the section of this Privacy Policy entitled “Transfers of Personal Information to 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 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 no.marketing@ga.co

Please note that if you have registered an account on the Site or Services or are registered for a Course, opting out of receiving marketing messages will not apply to Personal Information provided to us as a result of signing up to use our Site or Services, and we reserve the right to send you certain communications relating to your account, your registration, and your use of the Site and Services, such as messages relating to account management, customer service, and system maintenance. These transactional account messages will thus be unaffected if you choose to opt out of marketing communications.  

 

HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

Vendors and Third-Party Service Providers: We may share any information we receive, including your Personal Information, with vendors or service providers, including Instructors, retained in connection with the provision of the Site or Services. This includes, but is not limited to, those providing website and data hosting services (e.g., Amazon Web Services and Heroku), distributing communications and supporting or updating marketing lists (e.g., Sailthru and Salesforce), facilitating feedback on our services (e.g., Survey Monkey); and providing IT support services from time to time. These organizations (which may include third-party suppliers, agents, subcontractors, and/or other affiliates) will only use your information to the extent necessary to perform their support functions. In addition, where necessary, we have entered into Data Processing Agreements or service provider agreements with these third-party service providers, which require the service providers to both keep that information confidential and not use it for any purpose except to the extent necessary to perform their support functions.

Payment Transactions: 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. You will be providing debit or credit card information directly to our payment solutions provider that operates a secure server to process payment details, encrypting your credit/debit card information, and authorizing payment. Information that you supply to our payment solutions provider is not stored by us or within our control and is subject to our payment solutions provider's own privacy policy and terms and conditions.

Enterprise and Partnership Agreements: If you access and use the Platform or any of the other Services in connection with an Enterprise Agreement or other agreement between GA and a third-party with whom we partner to provide you the Services, we may share your Personal Information with your Employer or our partner in accordance with the terms of that Enterprise Agreement or partnership agreement, as applicable. The use of your Personal Information by such organizations will be governed by their privacy policies.

Outcomes Partners: If you sign-up to participate in our Outcomes program, we may share your Personal Information with our third-party hiring partners for purposes of highlighting your profile for a particular role at the hiring partner.  These organizations will use your Personal Information for purposes of determining your eligibility or suitability for available roles. The use of information by such organizations will be governed by their privacy policies. 

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 Services may be displayed publicly. Other users of the Site or Services 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 Services, and we are not responsible for the use of any Personal Information by third parties that you publicly post on the Site or Services. If you participate in a course, class, workshop, or event that is recorded and you appear in the recording, your image may be visible to other participants of that course, class, workshop, or event. 

Social Networking and Other Websites: The Site or Services may allow you to post information to social networking websites. We do not share your information with such social networking websites unless you direct the Site or Services 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 processes, such as a court order, warrant or subpoena; respond to your requests; enforce our policies related to our Site or Services, 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 a legal 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 one of the transferred assets 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. You may withdraw consent to disclosures where you have previously given specific consent by emailing us at privacy@ga.co.

 

SECURITY OF YOUR INFORMATION

We have implemented physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. In addition, we limit access to your Personal Information to only those employees, agents, contractors, and other third parties who need to have access to such information for the operation of our business, including the operation of the Site and Services. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality.

As noted above, 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 Services, 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 Services like message boards. The information you share in public areas may be viewed by any user of the Site or the Services.

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

 

CHILDREN'S PRIVACY

Our Site and the Services are not intended for nor directed toward children under the age of 16, and we do not knowingly collect personal information from children under 16 years of age. If you believe that your child under the age of 16 may have provided us with Personal Information without your consent, you may alert us at privacy@ga.co. If we learn that we have inadvertently collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child's account.

 

EXTERNAL LINKS

The Site or Services may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over these third parties, and we are not responsible for the content of such websites or the privacy policies or practices of such third parties. You should carefully review the privacy policy of any such third-party website that you visit.

 

TRANSFERS OF PERSONAL INFORMATION TO THE UNITED STATES 

The Site and the Services 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 and processed and stored in the United States. 

For purposes of the Data Protection Act 1998, the General Data Protection Regulation 2016/679 (the GDPR) and any corresponding or equivalent national implementing law or regulations, if you are located in the United Kingdom, 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.  If you are located in France, General Assembly France SAS is the data controller with respect to any information collected by it in France and then transferred to General Assembly Space, Inc. in the United States.  

All transfers of Personal Information from the European Economic Area, the United Kingdom, or Switzerland to the United States are done pursuant to the European Commission’s standard contractual clauses or, when possible, the binding corporate rules of our third-party vendors, suppliers, or service providers, if applicable.  

General Assembly acknowledges that EU and Swiss authorities have invalidated the Privacy Shield, meaning that it is no longer a lawful basis that General Assembly can use to transfer information from the EU or Switzerland to the US. However, we continue to process personal data consistent with the Privacy Shield principles and remain certified to the program, which requires us to make the representations below.

General Assembly complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (the "Privacy Shield Principles") set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information. General Assembly has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Program and to view our certification, please visit https://www.privacyshield.gov/

As part of our participation in the U.S.-EU and Swiss-U.S. Privacy Shield certification programs, we have further committed to refer unresolved Privacy Shield complaints to JAMS. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield or, to file a complaint, visit https://www.jamsadr.com/eu-us-privacy-shield. The services of JAMS are provided at no cost to you.

EU, UK, and Swiss individuals with inquiries or complaints regarding our Privacy Shield practices should first contact us at privacy@ga.co. All emails received will be handled by a representative of our Legal Department. For more information on the dispute resolution process, please contact us at privacy@ga.co. 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). In certain situations, General Assembly Space, Inc. may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. 

General Assembly Space, Inc. is responsible and remains liable for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. General Assembly Space, Inc. complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, UK, and Switzerland, including the onward transfer liability provisions.

You have a legal right to request the Personal Information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend, or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.

Please see elsewhere in this Privacy Policy for more information on types of Personal Information collected, purposes for data collection, types of third parties receiving Personal Information, and purposes of disclosure to such parties and your legal rights.

PRIVACY DISCLOSURES FOR SPECIFIC JURISDICTIONS


California

Your California Privacy Rights; “Shine the Light” Law

We do not disclose Personal Information about you to third parties 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, or we are required to do so by law.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of Personal Information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
For more information about how we may share your Personal Information, please refer to the section of this Privacy Policy entitled “How General Assembly May Share Your Personal Information.” 

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described in “Purposes for which General Assembly Uses Your Information.”

Category

Information Type

Source

We disclose to:

We sell* to:

Identifiers

  • Contact information or personal characteristics (name; email address; postal address; telephone number; image; signature)
  • Social media handles

You; our social media pages; third party subscription service providers

Service Providers Not sold
 
Health Information
  • Health information you volunteer if you apply for a job
You  Service Providers Not sold
 
Financial Information
  • Payment card data
  • Bank account information
  • Credit information
You  Service Providers Not sold
 
Protected Classifications and Other Sensitive Data
  • Date of Birth
  • Gender
  • Race
  • Criminal history 
  • Immigration status 
  • Disability or accommodation information
You  Service Providers Not sold
 
Commercial Information
  • Transaction information 
  • Billing and payment records
  • Order history
  • Obtained services  
You  Service Providers Not sold
 
Geolocation Information
  • Coarse (information that describes location at ZIP code-level or less precision)
You; our analytics and advertising partners Service Providers Advertising partners (coarse location only)
Internet or Electronic Network Activity Information
  • IP address
  • Login data
  • Browser type and version
  • Time zone setting and location
  • Brower plug-in types and versions
  • Operating system and platform
  • Device identifier (e.g., MAC)
  • Advertising identifier (e.g., IDFA, AAID)
  • Information provided in URL string (e.g., search keywords)
  • Cookie or tracking pixel information
  • Information about your interaction with our website, app, email correspondence, or products
  • Browsing history
  • Search history
  • Diagnostic information (e.g., crash logs, performance data)
You; our analytics and advertising partners Service Providers Advertising partners
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
  • Call recordings 
  • Photographs
  • Video
You Service Providers Not sold
 
Professional or Employment-Related Information
  • Current employer
  • Job title
You Service Providers Not sold
 
Education Information
  • Education history
  • Level of education
You Service Providers Not sold
 
Inferences Drawn About You
  • User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (including Assessment Data) 
You; our analytics and advertising partners Service Providers Advertising partners
Content of Communications
  • Contents of phone calls, emails, or text messages (if you contact us through any of those means)
You Service Providers Not sold

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement. 
* The CCPA’s definition of “sell” is very broad and can include certain everyday business activities. In our case, a “sale” occurs between us and our advertising and marketing partners when those partners collect information about your visit to our website. Please rest assured that we do not sell information that directly identifies you—such as your name, email, or address—to third parties.
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 of this Privacy Policy entitled "Cookies, Automatic Data Collection, and Related Technologies."  

For information about your privacy rights, please refer to the section of this Privacy Policy entitled “Your Legal Rights.” 

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. We do not sell personal information under Nevada law.
If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

DATA RETENTION

We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at privacy@ga.co.

 

YOUR LEGAL RIGHTS

Individuals from different countries or jurisdictions may have different rights. We reserve the ability to limit our response to your request to exercise your rights based on the law that is applicable to you. These rights include your ability: 

  • To opt out of sale of personal information to third parties, if applicable. Your right to opt out does not apply to our sharing of personal information with service providers.
  • To request more information about how we process your Personal Information. 
  • To be provided with a copy of your Personal Information held by us.
  • To request that we correct any of your Personal Information held by us.
  • To request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example).
  • To object to any further processing of your Personal Information, including the right to object to marketing.
  • To request that the Personal Information you have provided be transferred to a third party.
  • To withdraw consent, without detriment, where the basis of the processing of your Personal Information is based on consent.
  • To request that we delete any of your Personal Information held by us unless a legal exception applies.

 

To exercise your rights, please submit your verifiable request here. California residents may also exercise their privacy rights by calling us at 1-833-248-6276.      

You will not have to pay a fee to access your Personal Information (or exercise any other rights). We may, however, charge a fee if we believe your request is excessive, unfounded, or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.

In response to any of the requests outlined above, we may need to request specific information from you to enable us to confirm your identity and to ensure you have the right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that your Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response time.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If your request or concern is not satisfactorily resolved by us, and you are located in the EU or UK, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index en.html) who can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.

 

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information you have provided to us through your use of the Site or Services by sending an email to privacy@ga.co.

If you have questions about unsubscribing from email or other communications, you may send an email to privacy@ga.co or no.marketing@ga.co.

Please share any suggestions you may have for improving this Privacy Policy by sending an email to privacy@ga.co

 

CHANGES TO OUR PRIVACY POLICY & 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:

Legal Department
General Assembly
915 Broadway, 3rd Floor
New York, New York, 10010

Email address: privacy@ga.co