Last Updated and Effective Date: January 1, 2020
Note that we combine the information we collect through all of our websites, mobile applications, and other Services.
The categories of personal information we collect depend on whether you are a customer, user, applicant or visitor, and the requirements of applicable law.
Information You Provide to Us.
Course Applications: When you apply for a Thinkful course, we collect your name, email address, phone number, username, and password and we may ask you to optionally provide demographic or other information such as your gender or gender identity, whether you identify as a racial minority, your age, your eligibility to work in the United States, and your work and education history and career goals.
Profile Creation: You may have the opportunity to create a profile which may include photographs, information about your academic and work history, and your interests and activities.
Registration to become a Thinkful Instructor: When you register to be a Thinkful Instructor, we will collect information from you such as your education and employment history, phone number, photo, country of residence, and information we need to process payments to you, such as your bank account information, social security number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.
Communications with Others on Our Platforms. The Services may allow community members to communicate and collaborate with each other, including some Services that allow community members to engage in one-on-one communication using a video chat or text chat feature. Our servers may record, and we may retain records of the content of any such user-to-user communications.
Payment and Financial Information. We will process your payment information if you purchase products or services through our Services. Note that we do not store payment credit or debit card numbers.
If you utilize the Services in a way that necessitates payment from Thinkful to you (such as offering services for sale through Thinkful or participating in research projects), we may collect additional information from you, such as your bank account information, social security number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Information Collected Automatically or From Others
Automatic Data Collection. We may collect certain information automatically when you use the Services including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet or mobile service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services, including information collected from interactive services (including our e-Reader), such as notes you take and engagement during study sessions.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Embedded Scripts: Embedded scripts are programming code designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services.
Flash & HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
Our uses of these Technologies fall into the following general categories:
Strictly Necessary Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity, improve security, or that allow you to use features on our Services.
Personalization The collection and processing of information about your use of these Services to subsequently personalize advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content you interact with on the Services is used to make inferences about your interests, which inform future selection of advertising and/or content.
Measurement The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the Services. This does not include personalization, the collection of information about your use of these Services to subsequently personalize content and/or advertising for you in other contexts, i.e., on other services, such as websites or apps, over time.
Information storage and access The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
Content selection, delivery, reporting The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether the you took any action related to the content, including for example clicking on content. This does not include personalization, which is the collection and processing of information about your use of these Services to subsequently personalize content and/or advertising for you in other contexts, such as websites or apps, over time.
Ad selection, delivery, reporting The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include personalization, which is the collection and processing of information about your use of these Services to subsequently personalize advertising and/or content for you in other contexts, such as websites or apps, over time.
Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site or you log in to a third party’s service using your Thinkful credentials, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email address or other contact information, profile picture, activities such as test completion and results, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
We use your information for a variety of business purposes, including to:
Fulfil our contract with you and provide you with our Services, such as:
Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Communicating with you about your account, activities on our Services and policy changes;
Undertaking activities to verify or maintain the quality or safety of a service or device;
Processing your financial information and other payment methods for products or Services purchased;
Providing advertising, analytics and marketing services;
Processing transactions and applications; and
Allowing you to register for events.
Analyze and improve our Services pursuant to our legitimate interest, such as:
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
Undertaking research for technological development and demonstration;
Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
Improving, upgrading or enhancing our Services or device;
Developing new products and Services;
Ensuring internal quality control;
Verifying your identity and preventing fraud;
Debugging to identify and repair errors that impair existing intended functionality;
Enforcing our terms and policies; and
Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
Provide you with additional content and Services, such as:
Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
Auditing relating to interactions, transactions and other compliance activities; and
Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
Automated profiling. We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. The Services may offer referral features whereby users may invite friends to use the Services. We will invite the referred individual through a one-time email and will not use this information for other purposes. The referred person may contact us at email@example.com to request that we remove this information from our active database.
Additionally, we may enable you to “like” a product within our Services. If you choose to "like" or "share" content or to otherwise post information from or via the Services to a third-party web site, feature or application, that information may be publicly displayed, and the third-party web site may have access to information about you and your use of our Services.
Testimonials. We display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
Notice Regarding Third-Party Websites. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
APIs and SDKs. We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Except as provided below, we do not share/disclose/sell your personal information. For lists of categories of personal information disclosed for a business purpose or sold for valuable consideration in the last 12 months, please see below.
We do not share your Personal Information with third parties for their marketing purposes without your consent.
We may share non-Personal Information (such as aggregate user statistics, de-identified information, demographic information such as gender, age, education, and work experience), and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.
Sweepstakes, Contests and Promotions: We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Affiliates. We may share personal information with our affiliated companies.
Advertising Partners. Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit the third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
Categories of Information Disclosed for a Business Purpose
In the past 12 months, Thinkful may have disclosed the following categories of information about consumers for a business purpose:
Name and Other Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Purchase History: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Network Activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Professional or Employment-Related Information.
Inferences Drawn from any of the information above to create a profile about a consumer reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Information Disclosed for Valuable Consideration
In the past 12 months, Thinkful may have disclosed the following categories of information about consumers for valuable consideration:
Name and Other Identifiers including Internet protocol address, device ID.
Network Activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Email and Telephone Communications.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
You may be able to opt-in to receiving text messages from Thinkful. You may opt-out by replying "STOP" to one of the text messages received.
We will send you push notifications if you agree to receive them regarding updates on the Services and other items that may be relevant to you.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
To manage Flash LSOs please click here:http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Updating Your Account Information. You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information.
Your Privacy Rights.
In accordance with applicable law, you may have the right to:
Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
Request Deletion of your personal information, subject to certain exceptions prescribed by law.
Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please visit [link to rights portal]. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
CLOSING YOUR ACCOUNT
If you wish to close your account with one of our Services, please send your request to email@example.com indicating which Service(s) you wish to close from the email account that you have registered with Thinkful.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
The Services are not directed to children under 13. Parents or legal guardians (“Parents”) must provide their verified consent for the collection, use, or disclosure of a child's personal information. Thinkful will not collect, use, or disclose any personal information from a child if their parent or guardian does not provide such consent.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Attn: Privacy Questions
55 Prospect St, Suite 201