Flatiron School Privacy Policy

Effective Date: April 7, 2021

Flatiron School LLC and our affiliates (collectively, “Flatiron School,” “Flatiron,” “we,” “us,” or “our”) care about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how Flatiron School collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), or other services that refer to or link to this Policy, as well as any offline products, programs, courses, and services (collectively our “Services”).

Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.

1. INTRODUCTION

References to “Personal Information” means data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.

References to “Services” in this Policy include the services provided by us. 

2. INFORMATION WE COLLECT

The Personal Information that we collect and our use of that information depends on your relationship with us and the requirements of applicable law as described below.

We collect information:

  • that you provide to us directly, including via written or oral communications with our staff, applications or other forms;

  • that your school or company provides to us;

  • about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies. For more information about these technologies, please see the section “Navigational Information” below;

  • if you opt in to certain features or depending on your device settings, we will obtain geo-location data and information about your contacts; and

  • that we obtain from other sources.

2.1 INFORMATION COLLECTED FROM YOU

Except as otherwise described in this Policy, Flatiron School only collects Personal Information from you or others based on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:

  • Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;

  • Verification Information, including a photo ID or government issued identification, date of birth, proof of eligibility, employment, income, and social security numbers when required;

  • Demographic Information, including your gender, race, age, and education level;

  • Account Information, including your username and password; 

  • Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;

  • Program Information, including student records, student performance information, student projects and work, information regarding your job search, job search parameters, applications, interview contacts, and other information about your use of the Services;

  • Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;

  • Communications, and any other information that you share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through automated chatbots, or similar technology, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services;

  • Device and Navigational Information, including information about your computer or device and Internet or other electronic network activity information. 

  • Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, and other details such as photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. 

2.2 NAVIGATIONAL INFORMATION

In addition to information that you choose to submit to us, Flatiron and/or our service providers may automatically collect and/or store certain information (“Navigational Information”) when you visit or interact with our websites, landing pages, and other web-portals (the “Site”). This Navigational Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Navigational Information may include:

  • your IP address or other unique identifier (“Device Identifier”);

  • your Device browser, operating system and mobile network information;

  • the areas within our Site that you visit and your activities there, including remembering you and your preferences;

  • your general location; and

  • certain other Device data, including the time of day you visit our Site, among other information.

We may use various methods and technologies to collect and/or store Navigational Information, such as:

  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some (but not all) instances can be blocked by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options. Please note that these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, visit www.adobe.com. Please understand that if you disable or remove any type of cookie, some parts of our Site may not function properly.

  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages. Web beacons may be used by us for a number of purposes, including to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter. The embedded script does not collect your Personal Information.

  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

  • Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to coming to the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.

2.3 INFORMATION COLLECTED ABOUT YOU

Social Media. Flatiron School collects Personal Information to enable you to use online social media resources, including the use of our learning management system. If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.

Third-Party Sources. We may obtain Personal Information about you from your company, school, or other organization associated with your use of the Services. We also may receive Personal Information about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.

Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Flatiron School may enable you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools store information on mobile or other devices. These tools transmit Personal Information to Flatiron School to enable you to access your user accounts and to enable us to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.

3. PURPOSES FOR USE OF PERSONAL INFORMATION

How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:

  • provide you with our products and Services, including online and offline events, and other materials you request;

  • protect against fraud, abuse, or harm and otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);

  • respond to or fulfill customer service requests;

  • analyze, better tailor, and improve our products and Services;

  • contact you about our Services, promotions, and sweepstakes, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you; 

  • share information and other materials with you about third-party programs we think may be of interest to you; and

  • comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, regulatory reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

Applicants.  If you are an applicant, the Personal Information we use includes:

  • Contact Information and Professional Information so that we may identify you and contact you, including about your application, to respond to inquiries or troubleshooting requests and to deliver notifications and other operational communications, and review your application;

  • Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity, and otherwise provide a Secure Environment (generally to meet our legal obligations or our legitimate interests);

  • Payment Information, Financing Information, and Scholarship Information, where appropriate, to process a transaction that you have requested or applied for, including your purchase or financing of the Services (generally, to meet our contractual obligations to you); and

  • Other Personal Information and Communications to tailor our marketing to you and provide you with the Services, including, but not limited to (i) assessing your application, including your preferred class dates, how you plan to support yourself financially during the course, your availability, why you want to learn with us, what you hope to do upon completion of the program, and how you heard about us; (ii) connecting you with the community, social media channels, apps, and websites; (iii) providing Services that you request through our booking and sign-in tools; and (iv) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services.

Students.  If you are a student, the Personal Information we use includes:

  • Contact Information and Professional Information so that we may identify you and contact you, including to respond to inquiries or troubleshooting requests and to deliver notifications and other operational communications, enroll you in our Services, or provide you with a digital or physical access badge;

  • Contact Information and Professional Information, Account Information, Program Information, and other academic information, such as your progress and performance in programs and courses, your engagement with the Services, your portfolio, and any disciplinary data; to provide you with the Services, tailor Services to you, and connect you with the community; 

  • Contact Information, Verification Information, Payment Information, Program Information, and Demographic Information, where appropriate, to process a transaction that you have requested or applied for, including your purchase or financing of the Services (generally, to meet our contractual obligations to you);

  • Contact Information, Verification Information, Demographic Information, Payment Information, and Program Information, each where appropriate, for internal reporting purposes and educational regulatory reporting requirements; 

  • Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity, and otherwise provide a Secure Environment (generally to meet our legal obligations or to meet our legitimate interests); and

  • Other Personal Information to provide you with the Services, including, but not limited to (i) providing you with relevant courses and other training programs; (ii) connecting you with the community, social media channels, apps, and websites; (iii) providing Services that you request; (iv) connecting you with prospective employers and other relevant opportunities, and (v) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services.

Guests and Other Website Visitors.  If you are a visitor or guest who visits a facility in connection with the Services, except as otherwise specified in this Policy, we use the following Personal Information for the following purposes:

  • Your name and email address, whether provided by you or your host, to identify you and provide you with a digital or physical access badge;

  • Contact Information so that we may identify you and contact you, including to respond to inquiries that we receive from you;

  • Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity and the purpose of your visit, and otherwise provide a Secure Environment (generally, to meet our legal obligations or to meet our legitimate interests);

  • Other Personal Information to provide the Services, including, but not limited to (i) providing you with online and offline events; (ii) connecting you with the community, social media channels, apps, and websites; (iii) providing Services that you request through our Services; and (iv) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services. This personal information may vary depending on the length of your visit or the Services that you access.

Mentors, Alumni, and University Students. If you are a mentor, alumnus, or university student, in addition to the Personal Information we use about guests, the Personal Information we use includes:

  • Professional Information to provide and tailor the Services and connect you with the community; and 

  • Contact Information, Account Information, Professional Information, and Program Information, in order to provide you with alumni services. 

Clients and Hiring Managers. If you are a client or hiring manager, in addition to the Personal Information we use about guests, the Personal Information we use includes:

  • Professional Information and Communications to provide and tailor the Services, engage you as a client, and connect you with the community.

All. Whether you are an applicant, student, guest, or other end user, mentor, alumnus, client, or hiring manager, we also use your Device and Navigational Information and Other Personal Information to prepare aggregate use statistics, analyze, provide, better tailor, and improve our products and Services, tailor and provide you promotions and advertising, both on and off the Services, otherwise enhance your engagement with us, and as otherwise described in this Privacy Policy.

LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others a Secure Environment, and analyzing, improving, and better tailoring our products and Services.

We also generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third-party websites, and in providing promotions or sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.

4. SHARING OF PERSONAL INFORMATION

As described in this Policy, we disclose your Personal Information within Flatiron School and its affiliates, to our community, to our service providers and advertisers, and to other end users in order to provide our Services and to improve ways of working in our community. 

Within Flatiron School. We may share your Personal Information across Flatiron School and its affiliates depending on where you are located and the Services that you use. Flatiron School uses your information in accordance with this Policy.

Our Community. Our Services include online and offline communities, forums, networks, and other features through which you may share information and connect with others. This includes:

  • Our Services may make networks, chat rooms, forums, and/or other groups available to users. Remember that anyone can read, collect, or use your postings on a network or forum or in a chat room or group and we cannot be responsible for any unauthorized third party’s use of information that you publicly disclose online.

  • We foster our community by creating profiles for students or permitting students to create their own profiles on networks or forums. Typically, such a profile contains your name and other information you provide or add to your profile (content, comments, photos, etc.). Depending on the Services you use, this profile might be created automatically and be accessible to other users of the network or forum. You can also share your profile with a broader audience (e.g., via social media).

  • Our Services may include courses, programs, workshops, or other events that are recorded or streamed. If you participate, your name and image may appear in the recording or streamed video. 

Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.

Financing Products. When you enter into an agreement with Flatiron School to obtain a financing product or financial assistance, we may share your Personal Information to maintain or service your account(s) (including referrals to debt collectors, when appropriate), protect against fraud, unauthorized transactions, claims, or other liability, report to consumer reporting agencies, undertake a proposed or actual exchange or sale of all or a portion of our business or accounts, comply with subpoenas or other judicial process or regulatory requirements, or as otherwise required or permitted by law. You generally do not have the right to limit our sharing of this Personal Information. 

Financial Partners. When you engage a third party to finance your participation in Flatiron School or provide tuition assistance, you are entering into a relationship with a third party for a financial product or service. As described in our Privacy Policy, we are not responsible for the data collection, privacy, and information sharing policies and procedures of any such third parties. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information.

Scholarship Providers. If you apply for a scholarship and/or receive a scholarship through Flatiron School or a third-party scholarship provider, we may share your Personal Information with the third-party scholarship provider in order to administer the scholarship or meet reporting requirements. 

Employer Partners. As part of our Services, we may connect you with prospective employers or employment opportunities. Typically, the information we share about you would consist of your resume, LinkedIn profile, and GitHub profile.

Program Partners. If you utilize the Services through your employer, university, or other organization, we may share your Personal Information with such third party in order to meet the requirements of the partnership.  Please review their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information.

Jobs Report. As part of our annual outcomes report, we will share your Personal Information with the third party we engage to review and examine our data and statements included in the report. 

Research / Survey Solicitations.  From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.

When Required by Law and as Necessary to Provide and Protect Our Services.  There may be instances when we disclose your Personal Information to other parties:

  • to provide you with the Services that you or your company/school request;

  • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;

  • to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;

  • to comply with education regulatory requirements or requests; 

  • to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or

  • to protect our rights, property, and safety or that of any of the Flatiron School family of companies, business partners, members, or employees; and

  • where otherwise required by law.

We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.

Corporate Transactions.  We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.

With Your Consent.  We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.

4.1 THIRD PARTY SERVICES & ADVERTISING

We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:

  • Third-parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.

  • Advertising providers help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.

  • Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.

We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). For more information on these types of tracking tools, please see the section on Navigational Information above. We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-Flatiron related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance (EDAA) to learn more. Canadian users may also visit the Digital Advertising Alliance of Canada. 

Additionally, California residents may exercise their rights as described below in the section “Exercising California Privacy Rights”.

4.2 SOCIAL MEDIA

We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and video with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results.

While we will not edit comments, we may delete a comment from our page on a social media site if it, for example, does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language, or if it is a personal attack or hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.

5. RIGHTS IN YOUR INFORMATION

We will process such requests in accordance with local laws. To protect your privacy, Flatiron School will take steps to verify your identity before granting access or making any changes to your Personal Information. The California Privacy Rights section below provides additional information for California residents.

6. SENSITIVE PERSONAL INFORMATION

Where you have consented to Flatiron School’s use of “sensitive” Personal Information (e.g., Personal Information relating to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you) (“Sensitive Personal Information”), you may withdraw that consent, in accordance with applicable law.

Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Data for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Flatiron will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, Flatiron School will comply with the law or contract.

7. EMAIL AND TELEPHONE COMMUNICATIONS

Opting-Out of Marketing Communications.  We provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt out of those communications, e.g., communications regarding updates to our Terms of Use or this Policy. If you no longer desire to be contacted by us, you must terminate your relationship with Flatiron School and can no longer use our Services.

Collaboration. We may partner with other organizations to run events or programs. The Personal Information and other information that you provide to sign up or participate in that event or program will be available to that organization, and you may receive emails or other communications from it after the event. Please refer to that organization’s privacy policy for information on how to opt-out of its communications.

Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.

8. COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE

Where Flatiron School engages in interest-based advertising, we endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, Flatiron School’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.

8. LOCATION OF PROCESSING

Flatiron School is headquartered in the United States, and as a consequence your Personal Information will be processed in a country that may have privacy protections less stringent than your country of residence. In accordance with applicable law, we implement measures to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below.

9. RETENTION

Flatiron School will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended as determined by our records retention program.

When determining how long this retention period will last, we take into account the length of time Personal Information is required to:

  • Continue to develop, tailor, upgrade, and improve our Services;

  • Maintain business records for analysis and/or audit purposes;

  • Comply with record retention requirements under the law;

  • Defend or bring any existing or potential legal claims; or

  • Address any complaints regarding the Services.

10. INFORMATION SECURITY

The security of all Personal Information provided to Flatiron School is important to us. Flatiron School takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. To protect this Personal Information from unauthorized access and use, we use security measures that comply with law and are consistent with industry standards.

11. OTHER RIGHTS AND IMPORTANT INFORMATION

11.1 CCTV

Our campuses have CCTV installed to meet our legitimate business interests in protecting the safety of our employees, students, and guests and their property. These recordings may be accessed by Flatiron School or the landlord for any of our campuses and facilities. This CCTV footage may be made available to third parties authorized by Flatiron School or our applicable landlord.  These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are generally retained for a limited period of time, but may be kept longer where Flatiron School or our applicable landlord determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.

11.2 COLLECTION OF INFORMATION FROM CHILDREN

Our online Services are not directed at children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13, except as permitted under applicable law. If we become aware that a child under has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.

11.3 THIRD PARTIES

This Privacy Policy does not apply to services not provided by Flatiron School. We may display advertisements and other content from third parties or partners that link to third-party websites that we do not own or operate. We provide links to these third-party sites as a convenience to you. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms. Additionally, third parties may sell goods or offer services at our facilities or in combination with our Services. We are not responsible for those third parties’ services or their privacy practices.

11.4 CHANGES TO THIS POLICY

Any information that is collected via the Services is covered by the Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion.

If we make any material changes to this Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, as required by applicable law, and we will update the “Effective Date” below to indicate when those changes will become effective.

11.5 QUESTIONS OR COMMENTS

Personal Information is controlled by Flatiron School LLC. If you have any questions or comments regarding our Policy, please contact us at legal@flatironschool.com.

Legal TeamFlatiron School LLC18 W 18th Street, 7th FloorNew York, New York 10011

Flatiron School will address your concerns and attempt to resolve any privacy issues in a timely manner.

Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.

13. CALIFORNIA PRIVACY RIGHTS

California “Shine the Light” Law. Cal. Civ. Code §1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to studentservices@flatironschool.com or write us at the address noted above in the “Questions or Comments” section.

Do Not Track. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.

Minor California Residents. California residents who are registered users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at legal@flatironschool.com. In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.

California Privacy Law. California's Civil Code section 1798.100 et seq. provides residents of California a number of rights as they relate to Personal Information. These are the “right to know”, the “right to delete”, and the “right to opt-out”.

Right to Know. You may request Flatiron School provide you the specific pieces of personal information that Flatiron School has about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that Flatiron School sold or disclosed for a business purpose about you; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information. Please note that much of the information you can make a request for is already contained in this Policy. Should you wish to exercise this right, please see the section below which explains how to do so. If you do not have an account with Flatiron School, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

Right to Delete. California law gives residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if Flatiron School has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Flatiron School; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. If you do not have an account with Flatiron School, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

Right to Opt-Out. While we do not sell your personal information in the traditional sense, Flatiron School does sell your Personal Information to third parties as defined by applicable California law. This is because we share Personal Information with third parties for marketing purposes and permit our marketing partners to collect data directly from you. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request by using the mechanisms noted below under “Exercising California Privacy Rights”. 

Also, as Flatiron School engages in interest-based advertising, we endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, Flatiron School’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.

Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

Designating an Authorized Agent. California law permits California residents to designate an agent to manage their rights under California law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising California Privacy Rights”. Note that If you do not have an account or are not enrolled with Flatiron School, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.

Non-discrimination. California law does not permit Flatiron School to discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising California Privacy Rights. If you are a California resident and would like to exercise any of your rights you may do so by emailing us at studentservices@ flatironschool.com, or calling +1 (800) 555-1212. You may also contact us by using the contact particulars noted in the “Questions & Comments” section above.