Great Minds PBC US Privacy Notice

Great Minds PBC (hereinafter “Great Minds”or “we”) values the privacy of individuals who use the Great Minds Website and Great Minds Digital Platform and related services (collectively, our “Services”). This Privacy Notice explains how we collect, use, and share the information of US residents who use our Services (“Users,” ”you,” or “your”). By using our Services, you agree to the collection, use, disclosure, and processing of your information as described by this Privacy Notice. 

We collect Personal Data from US residents and comply with the consumer privacy laws of California, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia (“US Privacy Law”). For the purposes of this Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

• Publicly available information;
• Deidentified or aggregated data; or
• Information otherwise excluded from the scope of US Privacy Law.

This Privacy Notice provides the following information to US residents:

• Categories of Personal Data we collect;
• Purposes for which we use Personal Data;
• Categories of Personal Data we share with third parties;
• Categories of third parties with which we share Personal Data; and
• How US residents can exercise their rights under US Privacy Law:
  • The rights to access, correct, or delete Personal Data;
  • The right to obtain a portable copy of Personal Data;
  • The right to limit the use of sensitive Personal Data in certain circumstances;
  • The rights to opt out of targeted advertising, sales of Personal Data, or profiling; and
  • The right to appeal our decisions about your requests.

Categories of Non-Sensitive Personal Data We Collect

The table below outlines the non-sensitive categories of Personal Data Great Minds collects about US residents, what we use that data for, and whether and how it is shared with third parties.

We collect Non-Sensitive Personal Data: 

• Directly from our users
• From data brokers (“data brokers” are companies engaged in the business of buying or collecting Personal Data and selling it to other businesses)

Categories of Sensitive Personal Data We Collect 

The table below outlines the categories of Sensitive Personal Data Great Minds collects about US residents, what we use that data for, and whether and how it is shared with third parties. Great Minds obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Law. US residents that have given Great Minds consent to process their Sensitive Personal Data may withdraw that consent by visiting https://app.sixfifty.com/request-easy/2345-9839/questions/5328929 or calling our toll-free number at 202-223-1854.

We collect Sensitive Personal Data: 

• Directly from our users

How We Use the Information We Collect

In addition to the purposes listed above, we may use the information we collect:

• To provide, maintain, improve, and enhance our Services
• To understand and analyze how you use our Services and develop new products, services, features, and functionality
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide User support
• For marketing and advertising purposes on the Great Minds Website only, including developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you
• To detect and prevent fraud, and respond to trust and safety issues that may arise
• For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency
• For other purposes for which we provide specific notice at the time the information is collected

How We Share the Information We Collect

We share and/or sell Personal Data with the following categories of third parties:

Subprocessors. We may share any information we collect with subprocessors retained in connection with the provision of the Great Minds Website and Great Minds Digital Platform. These companies are only permitted to use this information on our behalf and according to our instructions. Our subprocessors are not permitted to use your information for their own purposes.

Our Business Partners. We may share relevant information about you with our business partners to provide you with exclusive offers for products and services that may interest you.

We may also share your Personal Data with other parties for the following reasons:

As Required by Law. We may share your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. In particular, we may share relevant information with the appropriate third parties if you post any illegal, threatening, or objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or in which we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the same general provisions of this Privacy Notice.

Consent. We may also share your information with your permission.

For more information on how we share the information we collect, see the table of information shared by the Great Minds Website with our subprocessors and third parties [link] and information shared by the Great Minds Digital Platform with subprocessors. [link] 

Your Rights and Choices

Our Communications.

From time to time, you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages necessary to service User accounts after opting out of receiving promotional messages from us.

Cookies. 

Most web browsers allow you to manage cookies through the browser settings. To find out more about cookies used on the Great Minds Website, you can visit www.aboutcookies.org or www.allaboutcookies.org.

Our Partners. 

To inquire about your choices regarding our business partners generally, contact us at privacy@greatminds.org.

Your Rights. 

US residents have the following rights under US Privacy Law:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data; 
• The right to limit the use of Sensitive Personal Data in certain circumstances;
• The rights to opt out of targeted advertising, sales of personal data, or profiling; 
• The right not to receive discriminatory treatment for exercising your privacy rights; and
• The right to appeal our decisions about your requests if you disagree with them.

Exercising Your Rights.

If you are a US resident, you can submit a request to exercise your personal data rights under by visiting https://app.sixfifty.com/request-easy/2345-9839/questions/5328929 or calling us at 202-223-1854. Great Minds also processes opt-out requests sent by Universal Opt-Out Mechanisms (also referred to as “Opt-Out Preference Signals”) frictionlessly in compliance with US Privacy Law. You can send an Opt-Out Preference Signal for our business to process frictionlessly by visiting our website using a device or browser that broadcasts commonly used and recognized Opt-Out Preference Signals. We will apply the Opt-Out Preference Signals we receive to the browser or device that sent the signal. Please be aware that we do not accept or process rights requests submitted through other means.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to the email address we have on file with a link to complete the verification process. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. 

We will respond to your rights request within 45 days (or within 15 days when required by US Privacy Law), and in certain cases we may inform you that we will need an additional 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay acting on your request until we can appropriately verify your identity and the request as authentic. Also note that each of your rights are subject to certain exceptions that may permit or require us not to process your request.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.

Authorized Agents. 

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by using the method(s) described above. We may require verification of your authorized agent’s authority in addition to the information we require for verification of your identity. 

Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising

US Privacy Law gives US residents the right to direct a business that “sells” their Personal Data or shares it for targeted advertising purposes to stop selling and/or sharing their Personal Data at any time. As used here, “selling” means exchanging Personal Data with a third party for money or anything of value, and targeted advertising is the practice of displaying advertisements to a person that are selected based on that person’s activities over time and across non-affiliated websites or applications. In certain situations, and as detailed more fully above, we sell and/or share for targeted advertising Personal Data with third parties. You can opt out of the sale and/or sharing of your Personal Data for targeted advertising purposes by visiting https://app.sixfifty.com/request-easy/2345-9839/questions/5328929 or calling us at 202-223-1854.

Notice of Right to Limit the Use of Sensitive Personal Data

You have the right to limit some uses of Sensitive Personal Data. In general, you may direct companies not to use your Sensitive Personal Data except as necessary to provide goods or services you have requested or to further certain other exempt purposes. 

However, we only use Sensitive Personal Data for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes is specified in California Code of Regulations, Title 11, Section 7027(m). 

Children’s Data

We do not knowingly sell or share for targeted advertising the Personal Data of US residents under 16 years of age. 

We comply with the Children’s Online Privacy Protection Act (COPPA) and the Family Educational Rights and Privacy Act (FERPA), in addition to US Privacy Law, with respect to any Personal Data we collect or use from children under the age of 13 on the Great Minds Digital Platform.

Third-Party Content

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using administrative, technological, and physical safeguards designed to improve the security of the information we maintain and protect it from accidental loss, unauthorized access or use, or any other inappropriate or unlawful processing. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By using our Services, you consent to the transfer, storage, and processing of your information as described in this Privacy Notice.

Changes to this Privacy Notice

We will post any adjustments to the Privacy Notice on this page, and the revised version will be effective when it is posted. If we make material changes, we may notify you by posting a notification on the homepage of the Great Minds Website and the Great Minds Digital Platform. We encourage you to read this Privacy Notice periodically to stay up to date about our privacy practices.

Contact Us

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@greatminds.org.

Last updated: September 03, 2024