Admissions Login Course Login Talent Community GALVANIZE PRIVACY POLICY Effective Date – 1/1/20 Last Updated – 12/04/19 This privacy policy (“Privacy Policy" or “Policy”) is intended to be read along with the Galvanize, Inc. Terms of Service. The terms “Galvanize,” “we,” and “us” include Galvanize, Inc., a Delaware corporation and any parent, subsidiary or affiliate of the forgoing. This Policy provides information about our collection, use and sharing of the personally identifiable information or personal data ("Personal Information") that we obtain through your use of the Galvanize & Hack Reactor websites (“Websites”); the software applications made available by us for use on or through computers and mobile devices (“Apps”); through social media properties (“Social Media”); through email messages that we send to you (“Emails”); through filling out forms on one of our Websites (“Submitted Forms”); through interactions with our advertising or applications that we serve on third-party websites and services (“Served Ads”) and through services we provide to our users and clients (“Client Services.”) Collectively, we refer to the Websites, the Apps, our Social Media, Emails, Submitted Forms and Client Services as the “Services.” This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties. This includes any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, including without limitation; Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media. This Policy informs you of the rights you have to access and control the use of your Personal Information. By engaging with the Services, you acknowledge that you have fully read and understood this Privacy Policy. By using the Services, you are authorizing us to collect and process data, including Personal Information, in accordance with this Privacy Policy. Please read this Policy carefully. If you do not agree with this Policy, please do not provide any Personal Information to us. What Types of Information Does Galvanize Collect? Personal Information means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identifier has been removed. Galvanize may collect, process, store and transfer different types of information about users. Certain types of data that we collect constitute Personal Information only when combined with personal identifiers. Identity & Demographic Data This includes information that we use to identify or communicate with you as a user of the Services. This may include first & last name, gender, date of birth, user credentials and passwords and other similar data. Under certain circumstances, we may request and collect sensitive Personal Information like social security number and demographic information like gender, ethnicity and sexual orientation where required for certain aspects of the Services. Contact Information This includes mailing or billing addresses, email address, telephone number and mobile phone number and social media handles or screennames. Technical Usage Data Includes information specifying the internet protocol (IP) address used to access the Services, data about your computer, web-browser, operating system, physical location, and other technical data about the devices you use to access the Services. Payment Data We use third-party payment processors for most financial transactions, however we may collect payment information for processing of payments under specific circumstances. Performance Data Academic performance and progress-tracking data collected to assess your performance in Galvanize’s educational programs. Marketing and Communications Data Includes information about your interests, preferences, website browsing history, demographic information such as age, gender, education level, feedback and survey responses and your marketing and communications preferences. Anonymized Data In addition to Personal Information, we sometimes collect, aggregate and process anonymous data for a variety of purposes. Anonymous data is data that is unable to be linked to an identifiable person. We may use anonymous data to analyze and improve the content and functionality of the Services, to analyze market trends, to effectively target our marketing efforts; to gather demographic information about our users or for any lawful purpose whatsoever. Galvanize may also disclose such anonymous data to partners or service providers, as set forth in this Privacy Policy. If at any time anonymized data that we collect from you is combined with your Personal Information such that it becomes possible to directly or indirectly identify you, we treat the combined data as Personal Information and limit its use as set forth in this Privacy Policy. How Does Galvanize Collect Personal Information? We directly collect Personal Information from you when you: Contact us directly to request information about the Services; Create an account on the Website or register to use the Services; Apply to attend educational programs or any other Services on the Website or third-party websites; Register for events or workshops offered by us or any third-party organizations that we partner with. Provide information in response to surveys, promotional messaging and event solicitations; Submit inquiries regarding the Services, speaking or communicating with our admissions or enrollment team members, or requesting access information from us, including newsletters or other marketing materials; Engage with us on various social media channels such as Reddit, LinkedIn, Facebook and Twitter. In many instances, our legal and regulatory obligations require us to collect certain Personal Information from you. Any failure or refusal to provide that information may preclude us from providing access to the Services, or otherwise prevent us from entering into contractual arrangements with you. We automatically collect data from you when you interact with the Website or Services, by collecting anonymous usage statistics about your computer, software or browsing behavior. We utilize cookies, server logs, and other similar technologies to collect technical data. Please review our Cookie Policy for more information about cookies. For What Purposes Does Galvanize Use My Personal Information? We have listed below the different ways that we may use your Personal Information, along with the lawful basis for processing and the legitimate business interests that require processing. We will only use your Personal Information for the purposes for which we collected it. In some instances, we may have several lawful purposes for processing your Personal Information. Feel free to contact us at privacy@galvanize.com if you would like additional information about our processing of your Personal Information. In order for Galvanize to do the following; We may process the following types of Data; This is the lawful basis for our processing of that Data; Provide you with access to the Websites; creating and maintain an online account for you to register and use the Services. Demographic Data Identity Data Data processing is necessary for us to enter into a contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interest in providing you with the Services. To deliver the Services to you. Demographic Data Identity Data Performance Data Data processing is necessary for us to perform under the terms of a contract with you, for us to comply with our legal and regulatory obligations, and our legitimate interest in delivering the Services. To facilitate, collect and process your payments, fees and charges for the Services. Identity & Demographic Data Contact Information Payment Data Data processing is necessary for us to enter into or perform under the terms of a contract with you; for us to comply with our legal and regulatory obligations, and for our legitimate interest in providing you with the Services. To improve the Services and to provide high-levels of customer service. Contact Information Technical & Usage Data Anonymized Data Data processing is necessary for the performance of our contract with you and for our legitimate business interests in; assuring proper technical functionality, high-levels of customer service and usability to meet the needs and demands of our customers. Keep you informed about changes to policies related to our Services including this Privacy Policy. Contact Information Identity & Demographic Data Marketing & Communications Data Data processing is necessary for us to comply with our legal and regulatory obligations under the relevant privacy laws and regulations, and for our legitimate interest in delivering the best levels of service to you. To recommend additional Services to you and provide updates to existing Services. Contact Information Identity & Demographic Data Marketing & Communications Data Technical & Usage Data Anonymized Data Performance Data Data processing is necessary for us to perform under the terms of our contract with you and for our legitimate interest in delivering high levels of customer service. Properly administer and protect the Services through data integrity testing, system analysis and troubleshooting. Contact Information Identity & Demographic Data Marketing & Communications Data Technical Usage Data Data processing is necessary for the performance of our contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interests in providing network security in connection with the Services, improved functionality and customer service. To service you as a customer, including responding to inquiries, providing relevant information about the Services, promotions or other opportunities that you request or agree to receive, through electronic means or other marketing channels. Contact Information Identity & Demographic Data Marketing & Communications Data Technical & Usage Data Anonymized Data Performance Data Data processing is necessary for us to enter into a contract with you and for the continued provision of the Services, and our legitimate business interests in offering better Services to you and in continuing to cultivate our customer relationships. How Does Galvanize Share Your Information? Galvanize does not share user information, including Personal Information, with third-parties except in the following situations. Affiliates and Service Providers: Galvanize may share Personal Information with our third-party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, Services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, event coordination and other services related to delivering the Services. We also may share your Personal Information with our affiliates and providers for the purposes stated in this Privacy Policy. Additionally, we may share Personal Information for other reasons if we determine that the sharing is necessary to support the legitimate business interests stated in this Privacy Policy. Government, Regulatory and Law Enforcement: Galvanize may share your Personal Information to comply with any court order, law or legal process, including to respond to any law enforcement or requests from regulators. Additionally, we may share your Personal Information as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Galvanize, our customers or others. Sharing on Social Media & Messaging: By using the Services, you may choose to share Personal Information on message boards, chat-applications, profile pages, blogs and other similar services including, without limitation, our Social Media. Please note that any information you post or disclose through these services may become public and may be available to other users and/or the general public. The use or processing of the Personal Information by such services will be governed by their privacy policies. 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 transfer as part of such a transaction as one of the transferred assets as permitted by law and/or contract. With Your Consent: There may be circumstances where you consent to share Personal Information with third-parties for reasons outside of this Privacy Policy, such as attending a co-sponsored event at one of our campuses. How Can I Change My Marketing Preferences? If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at privacy@galvanize.com. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing- related emails from us, we may still send you important administrative messages, from which you cannot opt-out. How Does Galvanize Protect 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. Payment transactions are conducted through our PCI compliant secure payment solutions providers. We cannot and do not guarantee the security of any information transmitted over the Internet. Once we receive your Personal Information, we take steps that we believe are commercially reasonable to limit access to your Personal Information to only those employees and service providers whom we determine need access to the Personal Information to provide the requested products, services, offers or opportunities that may be of interest to you. However, even after we receive your Personal Information, we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed as a result of a breach of our commercially reasonable efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your Personal Information is completely secure and safe from such risks. Where you’ve created a password to access the Services, you are responsible for keeping this password confidential. Please do not share your password with anyone. Any transmission of Personal Information is at your own risk. If you have reason to believe that any interaction you have with us is no longer secure, please immediately inform us by emailing us at privacy@galvanize.com How long does Galvanize retain Personal Information? We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: The circumstances under which we enter into an ongoing relationship with you and provide the Services to you; The length of time we have an ongoing relationship with you and provide you with the Services; The potential risk of harm from unauthorized use or disclosure of your Personal Information; Whether there is a jurisdictional legal obligation to which we are subject (for example, certain laws require us to retain enrollment records for a certain period of time); or Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). Additional information about data retention policies is available on request by emailing us at privacy@galvanize.com Notice to EU Citizens Galvanize and the Services are operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including Personal Information, will be transferred to and processed and stored in the United States. For users located in the EU, the General Data Protection Regulation (“GDPR”) governs the rights of data subjects, and the obligations of data controllers and processors. If you access or use the Services in your individual capacity, Galvanize is the “data controller” under EU privacy law and any processing of Personal Information shall be in accordance with this Privacy Policy. Galvanize sometimes contracts with Enterprise organizations to provide Services to employees or other organizations or individuals. If your access or use of the Services is related to a contractual engagement between us and your employer, or any other third-party, that third party shall be considered the “data controller” under EU privacy law and any processing of Personal Information shall be governed by the terms of the third-party engagement. Users located in the EU have certain rights under the GDPR. These rights include the right under certain circumstances to receive, correct, restrict or object to the processing of your Personal Information, including the right to object to marketing. Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent at any time. You may also request that we delete your Personal Information; however, we may only do so if permitted by applicable law. To exercise any of the rights outlined above, please contact us at 1-720-640-6022 or privacy@galvanize.com or use this form. You will not be charged for any reasonable requests under the Privacy Policy however we may request that you pay a reasonable fee for any request deemed by Galvanize to be excessive, unduly burdensome, repetitive or brought in bad faith. We also may refuse to comply with your request in these circumstances. We will do our best to process your request within thirty (30) days, but we may require up to an additional thirty (30) days for processing and will notify you -- the data subject -- accordingly. Additionally, we may need to request specific information from you to confirm your identity before processing your request. If we are unable to satisfactorily resolve your request and you are located in the EU, you may contact your local data protection authority for further information about your rights and our obligations in relation to your Personal Information, as well as assistance with any complaints about our processing of your Personal Information. 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. California residents may, at any time, request disclosure or erasure of the categories and specific pieces of their personal information we have collected, as well as opt out of the selling of their information to third parties, by contacting us at (720) 640-6022, privacy@galvanize.com, or using this form. We will do our best to process your request expeditiously, but we may require up to forty-five (45) days. Additionally, we may need to request specific information from you to confirm your identity before processing your request. Requests for Information under FERPA If you independently enroll in an educational program offered by Galvanize or any of its affiliates; you may have limited rights in addition to this Policy, under the U.S. Federal Family Educational Rights and Privacy Act (“FERPA”). You will have the right to limit access to certain directory information about you, as defined in FERPA. You may request to access or limit access to your directory information by contacting us at (720) 640-6022 or privacy@galvanize.com. Children’s Privacy Our Services are not intended for children under sixteen (16) years of age. If you are under the age of sixteen, please do not use the Services or provide any Personal Information via a Website or App, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under sixteen without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under sixteen, please contact us at (720) 640-6022 or privacy@galvanize.com. Updates to Your Information We want to ensure that the Personal Information we hold about you is accurate and up to date. We ask that you 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 Services. If you require assistance or have questions about unsubscribing from email or other communications, please email us at (720) 640-6022 or privacy@galvanize.com. Changes to This Policy It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by e-mail to the e-mail address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Websites and this privacy policy to check for any changes. Contacting Us Galvanize Inc., located at 1644 Platte Street, Denver, CO, 80202 is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us. You can reach us at privacy@galvanize.com or at: Galvanize, Inc. Attn: Privacy / Data Compliance 1644 Platte Street Denver, CO, 80202 If you have any questions about this Policy, please contact us by e-mail at privacy@galvanize.com. 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