Privacy and Cookies Policy (Effective Date: 12/15/13, Last Updated: 5/22/18)

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 Limited, a Hong Kong 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, 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 the personally identifiable information or personal data ("Personal Information") that we obtain through your use of the General Assembly website accessible at www.generalassemb.ly (the "Site") and General Assembly’s online and offline products, including the cloud-based MyGA assessment and learning platform also accessible through the Site (the "Platform") and our class-based instructional products that are delivered through a variety of modalities, both in-person and online (together, the "Services"), and makes you aware of 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 Enterprise Agreement entered into between your employer or prospective employer and General Assembly, and in accordance with that agreement, your employer or prospective employer remains 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 or prospective employer, please contact your employer or prospective employer.
  • If you access and use the Platform or other Services in connection with an Enterprise Agreement entered into between your employer or prospective employer and General Assembly, or any parent, subsidiary, or affiliate thereof, and in accordance with that agreement, your employer or prospective employer is not designated as the data controller with respect to any of your Personal Information, then 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 this Privacy Policy, and (for non-EU residents) you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with General Assembly or the Site or Service will be in accordance with the Terms of Service.

THE CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS

Personal Information includes any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (i.e., anonymized or aggregated data).

The categories of Personal Information about you that we may collect, use, store, and transfer include the following, some of which constitute Personal Information only when combined with personal identifiers:

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.

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.

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 your interests, preferences, website browsing history, demographic information such as age, gender, or education level, and feedback and survey responses.

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

AGGREGATED AND ANONYMIZED, NON-IDENTIFIABLE DATA

We also collect, use, and share aggregated and anonymous data such as statistical or demographic data for a variety of 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.

Aggregated or anonymized data may be derived from your Personal Information but is not considered to be Personal Information under applicable privacy laws as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated or anonymized data with your Personal Information in such a way that 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 Notice.

We reserve the right to use anonymous or aggregated data for any purpose, including, but not limited to, those set forth above. We may also disclose such anonymous aggregate information to our partners or third-party service providers, excluding any Personal Information, except as otherwise provided in this Privacy Policy.

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 or prospective 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 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

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 that are run by us or by the third-party organizations with which we partner.

 

Automated Technologies or Interactions

As you interact with our Site and/or Services, we also collect technical data such as anonymous 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.

COOKIES, AUTOMATIC DATA COLLECTION AND 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 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. We may also receive Personal Information about you from various third parties and public sources.

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 login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

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

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

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 “Advanced”.
  • Under ''Privacy and Security,'' click ''Content settings'' then “Cookies”.
  • 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 Fox:

  • From the menu bar, choose “Firefox” then “Preferences”.
  • Click on the “Privacy” tab on the menu bar.
  • Select the appropriate settings in the “Tracking” menu.
  • Click on “remove individual cookies” and make the appropriate selections.

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 the legal bases and legitimate business interests on which we rely to do so where appropriate.

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, 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 for our legitimate business interest to obtain a payment due to us for Services
To facilitate and deliver the Services
  • Identity Data
  • Contact Data
  • Assessment Data
Necessary (i) to provide the Services to you, (ii) for the performance of a contract with you, 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, (ii) for our legitimate business interest in being able to provide the Services to you, 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, (ii) for our legitimate business interest in being able to provide the Services to you, 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, (ii) for our legitimate business interest in being able to provide the Services to you, 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, (ii) for our legitimate business interest in being able to provide the Services to you, 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 and 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 constantly 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 and (ii) for our legitimate business interests in (a) being able to provide the Services to you, (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 and (ii) for our legitimate business interests in (a) being able to provide the Services to you, (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 to 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 and Communications Data
Necessary (i) for the performance of a contract with you and (ii) for our legitimate business interests in for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 and Communications Data
Necessary for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 and 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 and Communications Data
Necessary for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 request 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 it. Where you do provide it we will use 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.

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. 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 hello@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.

NOTICE TO CALIFORNIA RESIDENTS

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

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

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

HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

Vendors and Third-Party Service Providers. We may share any information we receive, including your Personal Information, with vendors and third-party service providers, including Instructors, retained in connection with the provision of the Site or Services. This includes 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 companies in our group) 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 with these third-party service providers.

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.

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.

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 process, 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 give a specific consent by emailing us at privacy@ga.co.

SECURITY OF YOUR INFORMATION

We have implemented appropriate physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. 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 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 and 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 for the privacy policies or practices of such third parties. You should review the privacy policy carefully for any third-party website that you visit.

DATA TRANSFERS 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.

TRANSFERS OF PERSONAL INFORMATION TO THE UNITED STATES: OUR COMMITMENT TO THE PRIVACY SHIELD

If you are located in the United Kingdom, 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 (Revised UK law), General Assembly Space, Limited is the data controller with respect to any information collected by it in the United Kingdom and then transferred to General Assembly Space, Inc. in the United States.

General Assembly Space Inc adheres to the U.S.-EU and Swiss-U.S. Privacy Shield Principles, which can be found at https://www.privacyshield.gov. General Assembly Space, Inc. is committed to complying with the Privacy Shield principles, including those regarding collection, use, retention, notice, choice, onward transfer, and security, for all Personal Information received from individuals in the European Union and Switzerland in reliance on the Privacy Shield. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield principles, the Privacy Shield principles shall govern. To learn more about the Privacy Shield Framework, 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 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, 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.

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

Under the General Data Protection Regulation 2016/679 (the GDPR) data subjects located in the EU have the right under certain circumstances:

  • 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: Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent without detriment at any time;
  • To request that we delete any of your Personal Information held by us.

 

To exercise any of the rights outlined above, please email us at privacy@ga.co.

You will not have to pay a fee to access your Personal Information (or to 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, 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 that 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.

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 AND PRACTICES

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

CONTACT INFORMATION

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

Legal Department

General Assembly

902 Broadway, 4th Floor

Email address: privacy@ga.co

PRIVACY AND COOKIES POLICY

 

Effective Date: December 15, 2013

 

Last Updated: May 22, 2018

 

TABLE OF CONTENTS

 

  • INTRODUCTION
  • PURPOSE OF THIS PRIVACY POLICY
  • APPLICATION OF THIS PRIVACY POLICY
  • THE CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS
  • AGGREGATED AND ANONYMIZED, NON-IDENTIFIABLE DATA
  • FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION
  • HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION
  • COOKIES, AUTOMATIC DATA COLLECTION AND RELATED TECHNOLOGIES
  • PURPOSES FOR WHICH GENERAL ASSEMBLY USES YOUR INFORMATION
  • CHANGE OF PURPOSE
  • NOTICE TO JOB APPLICANTS
  • HOW TO OPT OUT OF FUTURE COMMUNICATIONS
  • NOTICE TO CALIFORNIA RESIDENTS
  • HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION
  • SECURITY OF YOUR INFORMATION
  • CHILDREN'S PRIVACY
  • EXTERNAL LINKS
  • DATA TRANSFERS TO THE UNITED STATES
  • TRANSERS OF PERSONAL INFORMATION TO THE UNITED STATES: OUR COMMITMENT TO THE PRIVACY SHIELD
  • DATA RETENTION
  • YOUR LEGAL RIGHTS
  • UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
  • CHANGES TO OUR PRIVACY POLICY AND 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 Limited, a Hong Kong 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, and any parent, subsidiary or affiliate of any of the forgoing.

 

 

PURPOSE OF THIS PRIVACY POLICY

 

This Privacy Policy explains how General Assembly may collect and use the personally identifiable information or personal data ("Personal Information") that we obtain through your use of the General Assembly website accessible at www.generalassemb.ly (the “Site”) and General Assembly’s online and offline products, including the cloud-based MyGA assessment and learning platform also accessible through the Site (the “Platform”) and our class-based instructional products that are delivered through a variety of modalities, both in-person and online (together, the “Services”), and makes you aware of 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 Enterprise Agreement entered into between your employer or prospective employer and General Assembly, and in accordance with that agreement, your employer or prospective employer remains 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 or prospective employer, please contact your employer or prospective employer.

 

  • If you access and use the Platform or other Services in connection with an Enterprise Agreement entered into between your employer or prospective employer and General Assembly, or any parent, subsidiary or affiliate thereof, and in accordance with that agreement, your employer or prospective employer is not designated as the data controller with respect to any of your Personal Information, then 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 this Privacy Policy, and (for non-EU residents) you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with General Assembly or the Site or Service will be in accordance with the Terms of Service.

 

 

THE CATEGORIES OF PERSONAL INFORMATION GENERAL ASSEMBLY COLLECTS

 

Personal Information includes any information about an individual from which that individual can be identified.  It does not include data where the identity has been removed (i.e., anonymized or aggregated data).

 

The categories of Personal Information about you that we may collect, use, store and transfer include the following, some of which constitute Personal Information only when combined with personal identifiers:

 

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, log in/user ID and password details, marital status, title, data of birth and gender, social security number where required for reporting purposes.

 

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

 

Technical Data: Includes internet protocol (IP) address, your log in 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.

 

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 your interests, preferences, website browsing history, demographic information such as age, gender, education level, feedback and survey responses.

 

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

 

 

AGGREGATED AND ANONYMIZED, NON-IDENTIFIABLE DATA

 

We also collect, use and share aggregated and anonymous data such as statistical or demographic data for a variety of 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.

 

Aggregated or anonymized data may be derived from your Personal Information but is not considered to be Personal Information under applicable privacy laws as it does not directly or indirectly reveal your identity.  However, if we combine or connect aggregated or anonymized data with your Personal Information in such a way that 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 Notice.

 

We reserve the right to use anonymous or aggregated data for any purpose, including, but not limited to, those set forth above. We may also disclose such anonymous aggregate information to our partners or third-party service providers, excluding any Personal Information, except as otherwise provided in this Privacy Policy.

 

 

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 or prospective 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 provision of the Services, but we will notify you in advance of such cancelation if this is the case.

 

 

HOW GENERAL ASSEMBLY COLLECTS YOUR INFORMATION

 

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, though 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 that are run by us or by the third party organizations that we partner with.

 

Automated Technologies or Interactions

 

As you interact with our Site and/or Services, we also collect technical data such as anonymous 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.

 

 

COOKIES, AUTOMATIC DATA COLLECTION AND 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 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. We may also receive Personal Information about you from various third parties and public sources.

 

Cookies are small text files that include a unique reference code placed on a visitors' device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our Site or 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 login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

 

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

 

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

 

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 or block flash cookies using your browser setting, however information on how to do this is available from the Adobe website at: http://www.adobe.com/products/flashplayer/security.

 

 

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:

  1. From the menu bar, choose “Tools” then “Internet Options”
  2. Click on the “Privacy” tab
  3. Select the appropriate settings

 

Google Chrome:

  1. From the menu bar, choose “Chrome” then “Preferences”
  2. On the “Settings” page, scroll down and click “Advanced”
  3. Under ''Privacy and Security,'' click ''Content settings'' then “Cookies”
  4. Select the appropriate settings

 

Safari:

  1. From the menu bar, choose “Chrome” then “Preferences”
  2. From the “Preferences” box, choose the “Privacy” tab in the menu bar
  3. Select the appropriate settings in the “Website tracking” menu
  4. Click on “Manage Website Data” and make the appropriate selections

 

Mozilla Fox:

  1. From the menu bar, choose “Firefox” then “Preferences”
  2. Click on the “Privacy” tab on the menu bar
  3. Select the appropriate settings in the “Tracking” menu
  4. Click on “remove individual cookies” and make the appropriate selections

 

 

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 the legal bases and legitimate business interests on which we rely to do so where appropriate.

 

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.  Where more than one ground has been set out in the table below 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 and (ii) 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 for our legitimate business interest to obtain a payment due to us for Services

To facilitate and deliver the Services

 

  • Identity Data
  • Contact Data
  • Assessment Data

Necessary (i) to provide the Services to you, (ii) for the performance of a contract with you and (ii) 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, (ii) for our legitimate business interest in being able to provide the Services to you, and (iii) to provide an excellent customer experience to you during the course of the Services

 

  1. 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, (ii) for our legitimate business interest in being able to provide the Services to you, and (iii) to provide an excellent customer experience to you during the course of the Services

 

  1. 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, (ii) for our legitimate business interest in being able to provide the Services to you, and (iii) to provide an excellent customer experience to you during the course of the Services

 

  1. 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, (ii) for our legitimate business interest in being able to provide the Services to you, and (iii) to provide an excellent customer experience to you during the course of the Services

 

  1. 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

 

  1. Asking you to complete a review or take a survey

 

  • Identity data
  • Contact data
  • Marketing and 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 constantly 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 and (ii) for our legitimate business interests in (a) being able to provide the Services to you, (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, system review)

 

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

Necessary (i) for the performance of a contract with you and (ii) for our legitimate business interests in (a) being able to provide the Services to you, (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 to 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 and Communications Data

Necessary (i) for the performance of a contract with you and (ii) for our legitimate business interests in for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 and Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 and 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 and Communications Data

Necessary for our legitimate business interests in continuing to develop and offer new and improved Services to you 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 request 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 it.  Where you do provide it we will use 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.

 

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. 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 hello@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.

 

 

NOTICE TO CALIFORNIA RESIDENTS

 

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

 

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

 

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

 

 

HOW GENERAL ASSEMBLY MAY SHARE YOUR INFORMATION

 

Vendors and Third-Party Service Providers.  We may share any information we receive, including your Personal Information, with vendors and third-party service providers, including Instructors, retained in connection with the provision of the Site or Services. This includes those providing website and data hosting services, such as Amazon Web Services and Heroku, fulfilment services, distributing any communications we send and supporting or updating marketing lists, such as Sailthru and Salesforce, facilitating feedback on our services and providing IT support services from time to time. These organizations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) 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 with these third-party service providers. 

 

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.

 

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.

 

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 website 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 process, 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 give a specific consent by emailing us at privacy@ga.co.

 

 

SECURITY OF YOUR INFORMATION

 

We have implemented appropriate physical, technical and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. 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 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 and 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 for the privacy policies or practices of such third parties. You should review the privacy policy carefully for any third party website that you visit.

 

 

DATA TRANSFERS 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.

 

 

TRANSERS OF PERSONAL INFORMATION TO THE UNITED STATES: OUR COMMITMENT TO THE PRIVACY SHIELD

 

If you are located in the United Kingdom, 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 (Revised UK law), General Assembly Space, Limited is the data controller with respect to any information collected by it in the United Kingdom and then transferred to General Assembly Space, Inc. in the United States.

 

General Assembly Space Inc adheres to the U.S.-EU and Swiss-U.S. Privacy Shield Principles, which can be found here: https://www.privacyshield.gov. General Assembly Space, Inc. is committed to complying with the Privacy Shield principles, including those regarding collection, use, retention, notice, choice, onward transfer, and security, for all Personal Information received from individuals in the European Union and Switzerland in reliance on the Privacy Shield. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield principles, the Privacy Shield principles shall govern. To learn more about the Privacy Shield Framework, 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 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, 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.

 

 

DATA RETENTION

 

We will only keep your Personal Information for as long as necessary to fulfil 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

 

Under the General Data Protection Regulation 2016/679 (the GDPR) data subjects located in the EU have the right under certain circumstances:

 

  • 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: where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent without detriment at any time.
  • To request that we delete any of your Personal Information held by us.

 

To exercise any of the rights outlined above, please email us at privacy@ga.co.

 

You will not have to pay a fee to access your Personal Information (or to 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, 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 that 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.

 

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 AND PRACTICES

 

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

 

 

CONTACT INFORMATION

 

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

 

Legal Department

General Assembly

902 Broadway, 4th Floor

New York, New York, 10010

 

Email address: privacy@ga.co