Privacy Policy

Last Revised: October 3, 2016

Girls Who Code Inc. (“GWC” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of Personal Information (defined below) we receive from users on our proprietary software app for mobile devices (the “App”). The App is also referred to herein as the “Services”.

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the App. You are advised to consult this Privacy Policy regularly for any changes. This Privacy Policy forms a part of the GWC Terms of Service (the “Terms”). By using the Services, you are accepting the practices described in this Privacy Policy and the Terms. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the Terms.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer or mobile device, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

1. Overview Our mission is to create a vibrant network for the Girls Who Code alumni community and other GWC stakeholders. We accomplish this by using the resources available on our Service and also through collaborating with our users. This may involve the collecting, processing, storing and sharing of Personal Information (defined below). We want to ensure that this is done in a responsible, transparent and secure environment that fosters your trust and confidence.

2. Information Collection and Use

2.1 Background Our primary goals in collecting information are to provide, operate and improve our Services, features, and Community Content; to provide user and other support, including to our third-party partners; and to enable users to enjoy and easily navigate the Services and to carry out other purposes that are disclosed to you and to which you consent.

GWC may allow you the opportunity to contribute Member Content. We do this so that we can provide and enhance the Services with additional functionality, and for other purposes as described in this Privacy Policy. You always have the option to revoke your consent to our further collecting of information by deleting our app from your device.

We (and our service providers on our behalf) collect certain information from your mobile device, including but not limited to the following:

2.2. Device and Usage Information May include (i) information specific to your mobile device (e.g., make, model, operating system, device identifier and similar information); (ii) information about your use of features, functions, or notifications on the device, IP address;

2.3. Personally Identifiable Information By “Personal Information”, we mean information about you that can be used to contact or identify you or someone else. Personal Information includes, but is not limited to, your name, phone number, pictures of you, your email address and your postal address. We use the Personal Information you provide mainly to (a) provide the Services and administer your inquiries; (b) improve the Services and provide any related customization or maintenance services thereto; (c) personalize your experience and customize content; and (d) identify and authenticate your access to the Services.

We may also use your Personal Information to contact you with notifications, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or, where applicable, update your “Settings” information.

In order to access the Services and to post any Member Content on the Services, you must register to create an account (“Account”) and become a Member. During the registration process, you will be required to provide certain Personal Information including the email address GWC has on file for you.

 

You hereby consent to our access to, collection of, and transmission of Personal Information about you that we obtain and use in accordance with this Privacy Policy.

2.4 Non-Identifying Information We may also collect other information that you provide as part of the personalization of your Account (which include individual preferences, but could also include, without limitation, zip code (on its own), age and gender) and your use of the App (“Non-Identifying Information”).

The App may periodically determine or estimate the approximate geographic location of the mobile device on which the App is installed (“Location Data”). You should be able to adjust the settings on your mobile device to prevent our collection of Location Data by disabling Wi-Fi or Bluetooth functionality or disabling the location services feature on your device.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).

2.5 Log Data When you visit the Services, our servers and/or service providers automatically record information that your device sends (“Log Data”). This Log Data may include information such as your Internet Protocol (“IP”) address, browser type, pages of our App that you visit, the time spent on those pages, information you search for on our App, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for technical administration of the Services, to comply with legal requirements on data retention, to increase functionality and user-friendliness of the Services, and to better tailor them to our visitors’ needs. For example, some information is collected so that when you visit the App again, it will recognize you and potentially serve information appropriate to your interests. We also use this information to verify that users of the App meet the criteria required to process their requests.

 

2.6 Use of Aggregate and Non-Identifying Information We may combine and transmit your Personal Information with Non-Identifying Information and aggregate it with information collected from other Members to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how you use our Services. We may also use and transmit the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions. 

We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. We may use a reputable third party to present or serve advertisements that you may see on the App .The use of these technologies by these third party ad servers is subject to their own privacy policies and is not covered by our Privacy Policy. In any event, any aggregated information shared in these contexts will not contain your Personal Information.

3. Data Retention We will retain your information for as long as the application is installed on your mobile device or as needed to provide you service. If you remove the application, we will remove your information and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. Cookies A cookie is a small data file that we transfer to your device’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Services. Second, we utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage by Members and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services. 

5. Web Beacons We also use “web beacons”, “pixel tags”, “clear GIFs” or similar means (individually or collectively “Web Beacons”) on our Services. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible to users. Web Beacons allow us to count the number of users who have visited certain pages of the Services to deliver branded services and to generate statistics about how our Services are used.

6. Phishing Identity theft and the practice currently known as “phishing” are of great concern to GWC. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login information, or identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

 7. Service Providers We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform services related to the Services (including without limitation, maintenance services, database management, analytics and improvement of the Service features) or to assist us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

8. Compliance with Laws and Law Enforcement GWC reserves the right to cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas and Court Orders), to protect the property and rights of GWC or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

9. Business Transfers GWC may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

10. Changing or Deleting Your Information All Members may review, update, correct or delete certain Personal Information in their Accounts by contacting us at loop@girlswhocode.com .

11. Backup Copies Some removed and deleted information may persist in backup copies for a limited time for our internal business purposes but will not be available to others. However, in most cases deletion is permanent and if you request information to be removed, it may not be restored later. 

12. Security GWC is concerned with safeguarding your information. Information provided to GWC via the Services is encrypted using industry standard secure socket layer (SSL) technology. GWC also uses certain techniques to hash passwords and does not store passwords in a non-hashed form. GWC also ensures that passwords may only be reset via secure pages of the Services. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on via the App in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. 

13. International Transfer Your information may be transferred to, and maintained on, computers located outside of your state, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, GWC transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer and you expressly consent to be governed by New York law for these purposes.

14. Links to Other Websites Our Services may contain links to other websites. The fact that GWC Content or Member Content may link to a website or that we may present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your device, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

15. California

15.1 Our California Do Not Track Notice GWC does not currently respond or take any action with respect to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time when a consumer uses the Services.

15.2 California Privacy Rights California Civil Code Section 1798.83 permits customers of GWC who are California residents to request certain information regarding its disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to loop@girlswhocode.com. Please note that we are only required to respond to one request per customer each year. 

15.3 Deletion of Content from California Residents If you are a California resident under the age of 18, and a registered user, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to loop@girlswhocode.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

16. Our Policy Toward Children We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA requires that online operators never knowingly request Personal Information from anyone under the age of 13 without requesting verifiable parental consent. The Service is not structured to attract children under the age of 13 years. In accordance with COPPA, we do not knowingly collect any Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at loop@girlswhocode.com.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at loop@girlswhocode.com or at:

Girls Who Code Inc.
28 West 23rd Street, 4th Floor
New York, NY 10010

Copyright Girls Who Code Inc. © 2016