Flatiron School Privacy Policy

Effective Date: August 5, 2020

Previous policy

Flatiron School 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”), applications (“apps”), 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

Personal Information.  “Personal Information” is 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.

Our Services.  The Services referenced in this Policy include the Services provided by us. 

References to “you.”  In this Policy, “you” means anyone who uses our websites, applications, or other Services. If you are an employee or applicant, the Flatiron Privacy Policy for People Data explains how we use Personal Information in the context of our employment relationship with you. If you are an employee or applicant that uses our Services, this Policy explains how we collect, use, and disclose your Personal Information in the context of your use of our Services.

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 applications or other forms;

  • that your company, host, parent, or guardian 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 our Cookie Policy;

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

  • that we obtain from other sources.

INFORMATION COLLECTED FROM YOU

Flatiron School requests different types of Personal Information from you or others, depending 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, and income;

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

  • 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 intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through automated chatbots, Amazon Echo, other voice assistants, 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 Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:

    • Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, as further set forth in our Cookie Policy, and your offline activity, including information about events you attend.

  • 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 the time and purpose of your visit, 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. We will also process personal information included in content and information that you add to your student profile. References to “Other Personal Information” in this Policy refer to all Personal Information referenced in this Policy.

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, parent or guardian. 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.

  • 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.

  • 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 may 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.

ANONYMOUS, AGGREGATED, AND OTHER INFORMATION

We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.

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. 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; 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, 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 code, 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, provide you with a digital or physical access badge, and connect you with the community;

  • 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);

  • 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);

  • Other academic information, such as your progress and performance in programs and courses, your engagement with the Services, and your portfolio, to provide you with the Services, tailor Services to you, and connect you with the community; 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 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.

Guests and Other End Users.  If you are a visitor or guest who visits a facility in connection with the Services, the Personal Information we use includes:

  • 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. If you are an invited guest, we will use this information to automatically send you an invitation to our platform, and, if unanswered, a one-time follow-up invitation;

  • 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 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. 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.

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, or university student, client, or hiring manager, we also use your Device and Usage 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 EU 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

We disclose your Personal Information in limited circumstances to Flatiron School, our community, our service providers and advertisers, and other end users, in order to provide our Services and to improve ways of working in our community. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.

  • Among Flatiron School. We may share your Personal Information among Flatiron School 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).

  • 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, 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. When you are no longer our customer, we continue to share your Personal Information as described in this Privacy Policy. To protect this Personal Information from unauthorized access and use, we use security measures that comply with law. These measures include computer safeguards and secured files and buildings. 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.

  • 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.

  • Third-Party Advertising Partners.  We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.

  • Other Parties 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 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 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.

  • Other Parties in Connection with a Corporate Transaction.  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.

  • Other Third-Party Partners, 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 PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES

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 our Cookies Policy. 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. Further information in local languages is available at www.aboutads.info or www.youronlinechoices.eu.

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: ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

We value your rights to your data. In accordance with applicable law, you may have the right to (i) request confirmation of whether we store, use, or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information or, as described above, object to those uses; (v) seek correction of inaccurate, untrue, or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by Flatiron School, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at legal@flatironschool.comor one of the physical addresses set out in Section 12.5 below.

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. OPT-OUT

You have the right to opt-out of certain uses and disclosures of your Personal Information as set out in this Policy, and in specific circumstances, for example related to direct marketing.

6.1 GENERAL

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.

6.2 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 do not sell your Personal Information to third parties for their direct marketing purposes. 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.

6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE

Should Flatiron School engage in interest-based advertising, it will 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/.

7. SUPERVISORY AUTHORITY

For customers of our Services in the EU, you may lodge a complaint with a supervisory authority if you believe our processing of your Personal Information infringes applicable law.

8. INTERNATIONAL TRANSFERS

Flatiron Schoolis headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard data protection clauses, 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 in Section 12.5.

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.

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. These measures include computer safeguards and secured files and buildings.

Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Flatiron School strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials with others, and other security best practices.

11. AUTOMATED PROCESSING

In the future, we may use automated processes to help us determine your eligibility for new services or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, or request that we restrict the use of your Personal Information for the purposes of these automated decisions.

12. OTHER RIGHTS AND IMPORTANT INFORMATION

12.1 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.

12.2 COLLECTION OF INFORMATION FROM CHILDREN

Generally, our online Services are not directed to children, and we do not knowingly collect Personal Information from children 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.

12.3 THIRD PARTIES

This Privacy Policy does not apply to services not provided by Flatiron School. We 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.

We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third party and not this Policy. We are not responsible for the data collection, privacy, and information sharing policies and procedures or content of such third-party websites.

12.4 CHANGES TO THIS POLICY IN THE FUTURE

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.

We encourage you to review this Policy periodically to remain informed of how we use and protect your information, and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by Flatiron School.

12.5 QUESTIONS OR COMMENTS

If you reside outside of Europe, your Personal Information is controlled by Flatiron School LLC. If you reside in the United Kingdom, your Personal Information is controlled by Flatiron School UK Limited.

If you have any questions or comments regarding our Policy, please contact us at legal@flatironschool.com.

Legal Team

Flatiron School LLC

18 W 18th Street, 7th Floor

New York, New York 10011

or

Legal TeamFlatiron School UK Limited

c/o Legalinx Limited

1 Fetter Lane

London

England

EC4A 1BR

United Kingdom

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.

Effective Date: August 5, 2020

13. JURISDICTION-SPECIFIC INFORMATION

California Privacy Rights

California residents are entitled to request and obtain certain information about the disclosure of certain categories of their Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes.

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.

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 Consumer Privacy Act (CCPA)

We have tried to explain our privacy practices in full in the other sections of this Privacy Policy. In this section, we supplement those descriptions for California residents by providing a list of categories of personal information as set forth in the CCPA that have been collected or disclosed for a business or commercial purpose during the preceding 12 months, as well as certain other information. Please see the other sections of the Privacy Policy for additional information and context.

Category of Personal Information

Explanation

Identifiers, such as your name, mailing address, phone number, email address, or IP address

We may use this information to respond to your questions, to enable you to participate in our programs (including promotions or sweepstakes), to provide you with online and offline events, to provide our Services, and for other business purposes.

Professional and employment-related information, such as your company name, title, role, or team

We may use this information to provide you with the products and Services you request, and for other business purposes.

Commercial information, such as a record of your purchases

We may use your information to provide you with the Services you have purchased, to identity other products and offers that may be relevant to you, and for other business purposes

Internet and electronic network activity information, such as information about your interactions with our Services

We may use this information to improve our Services, to better understand the visitors who come to our Services and what content is of interest to them, and for other business purposes.

Precise geographic location information, using technologies such as GPS or WiFi

We may use this information to improve the quality, security, and relevance of our Services to our visitors, and for other business purposes.

Other electronic or visual information, including information that you share using the Services (such as videos or photos) or footage captured by CCTV

We may use this information for our business purposes. For example, we use videos or photos that you share to provide the services you ask for on our Services, as part of sweepstakes or other competitions; and we use footage captured by CCTV to provide a Secure Environment.

As discussed in the other sections of our Privacy Policy, we collect this type of information from you, through our interactions with you and others, and from third parties, and we disclose these categories of personal information within Flatiron School, to service providers and third-party advertising partners, and as needed to comply with legal process. Your personal information may also be shared with third parties with whom you interact and third parties that you direct us to share your information with through our Services, and you may learn about your choices for third-party advertising cookies and similar technologies in our Cookie Policy. We do not sell your information to third parties for purposes of California law.

Information about how you may exercise your rights as a California resident can be found by contacting us at the email or address listed above in Section 12.5, “Questions or Comments.” We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

If you have any questions or complaints, you may submit it to us at: legal@flatironschool.com

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at legal@flatironschool.com.