Commonwealth of Pennsylvania Rev. 133C579
Version Date: October 19, 2022
What User Data is Collected- Non-Personal and Personal Identifying
“Non-Personal-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personal-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most mobile app operators, we may gather from users of the mobile app Non-Personal-Identifying Information of the sort that Web browsers, depending on their settings, may make available. We do not collect user’s Internet Protocol (IP) address, geographical location date, operating system, or the locations of other apps or data the user views right before arriving at, while navigating and immediately after leaving the mobile app. We analyze Non-Personal identifying Information gathered from users of the mobile app to help us better understand how the mobile app is being used.
What User Data is Shared
We may release the Non-Personal-Identifying Information gathered from mobile app users in the aggregate, such as by publishing a report on trends in the usage of the mobile app. Data collected will be retained no more than two years after users account indicate that users have not accessed the application for 12 consecutive months. We will not share email address or any other personal identifying information with any third party.
The following personal data (“information”) collected from users is limited to:
· Email address. User email address is collected for the express purpose of restoring lost or forgotten passwords.
The following non personal data (“information”) that is collected is limited to:
· Username – non personal identifier
· Generation – users are asked to identify the generation they belong to.
· Industry – users asked to identify which industry best captures their work experiences.
· Expertise – users are asked to enter up to three areas of expertise.
· Country – users are asked to identify their home country.
How user data is accessed and stored
We collect the information from users. The email and non-personal identifying user data stored on an encrypted database in an encrypted AWS cloud server. The data is accessed through an administrative portal that is restricted to a primary and backup administrator only.
How user data is used
User email is restricted to restoring lost or forgotten passwords. Non-personal identifying information (generation, industry, expertise, and country) are used by users to form a filter to narrow their search of potential mentors.
We will not share any personal identifying information to third party advertising companies or their affiliates. We will not provide users’ email information to third party advertisers or marketing companies, so that those third parties may directly contact them about additional products and services.
• Mobile Device. If you use a mobile device to access the Website or download any of our applications, we do not collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and IP address.
• Geo-Location Information. Although users are asked to enter their country of origin, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services.
• Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
As defined above, Personal-Identifying Information is information that can be directly associated with a specific person. We may collect a range of Non-Personal-Identifying Information from and about app users. Much of the Non-Personal-Identifying Information collected by us about users is information provided by users themselves when registering for our app. That information may include each user’s sign-on username, industry, expertise, country, and generation. Users of the app are under no obligation to provide us with Personal-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain app features.
BY REGISTERING WITH OR USING THE APP YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONAL-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONAL-IDENTIFYING INFORMATION” SECTION.
We may disclose Personal-Identifying Information under the following circumstances:
· Third-Party Service Providers. We may share your Personal-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include troubleshooting app performance, web software performance, or phone performance using the app
You may at any time review or change your Personal-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below.
We take the security of your Personal-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protecting all information on the app as is necessary. However, you are responsible for maintaining the confidentiality of your Personal-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personal-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personal-Identifying Information through the mobile app represents to us that he or she is 13 years of age or older. If we learn that Personal-Identifying Information has been collected from a user under 13 years of age on or through the mobile app, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the mobile app or has otherwise transferred Personal-Identifying Information to the mobile app, please contact us using our contact information below to have that child's account terminated and information deleted.
California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personal-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personal Identifying Information that was shared and the names and addresses of all third parties with which we shared Personal-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
All users are protected per the recent GDPR guidance. These rights include the following rights: to be informed, access to user data, user data deletion, restricted data processing, data portability, objection, and the right to not be exposed to profiling of any kind or be subject to automated decision making.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
Attn: Data Protection Officer
David L. Cain, Thirty2give Virtual Mentoring Email: David@thirty2give.com.