Great Minds® Privacy Policy

Last updated: September 5, 2024

Great Minds PBC (collectively, “Great Minds”) seek to ensure that all students in America’s public schools, regardless of their circumstances, receive a content-rich education in the full range of the liberal arts and sciences, including English, mathematics, history, the arts, science, and foreign languages. Great Minds does this by working with teachers, scholars, and schools to create curricula and instructional materials, conduct research, and promote policies that support a comprehensive and high-quality education.

We are so grateful that you have given Great Minds your trust and have chosen to join us in this crucial work. Keeping your trust through the protection of your and your students’ privacy is of utmost importance to us.

This Privacy Policy explains the types of information that Great Minds collects or obtains from you or your student in connection with the use of our online products and services, why we collect it, and how we will use, share, and protect this information. This Privacy Policy also covers Great Minds’ treatment of any personal information about our users that Schools, our partners, or other third-party services might share with us. We will collect, use, and share personal information only in accordance with the terms of this Privacy Policy.

This Privacy Policy applies to the Great Minds Corporate Website, www.greatminds.org (the “Great Minds Website”), as well as any products or services offered by Great Minds and our subsidiaries or affiliates, and Great Minds’ digital portals, services, and applications, www.digital.greatminds.org (collectively, “Great Minds Digital Platforms”). The Great Minds Website and Great Minds Digital Platforms are available to Schools to use as part of their selected educational curriculum.

By visiting the Great Minds Website and Great Minds Digital Platforms or by using Great Minds products or services, you agree to the terms of this Privacy Policy.

I. Types of Information Collected

Personal Information

When you download products from, or use services or products on the Great Minds Website or any other Great Minds Digital Platforms, we ask you or your School to create an account and provide certain personal information, which may include your first and last name and password, email address, teacher ID number, student first and last name, student ID number, state, affiliated school and district name, class section, grade, your role (e.g., parent, teacher, school administrator, etc.), student assessment scores, and other information that can identify you or your student. Great Minds may collect and store this personal information.

If you decide to create a Great Minds Digital Platforms account through or otherwise grant access to a third-party social networking or integrated service (an “Integrated Service”), such as Clever or similar single sign-on services, Great Minds may also collect personal information that is already associated with your Integrated Service account. You may also have the option of sharing additional information with Great Minds through an Integrated Service as controlled through your settings on that Integrated Service.

We may ask you for personal information at other times, such as when you contact our technical support team, send us an email, complete a user survey, or otherwise communicate with Great Minds. Great Minds may collect and store this information as well.

Please note that we use our best commercial efforts and take multiple steps to avoid the collection of personal information when we believe the Great Minds Website is being used by students under 13.

Educational Records

When the Great Minds Website or Great Minds Digital Platforms are used as part of a School's educational curriculum, student personal information that is (i) provided to Great Minds by a School or by a student, authorized by his or her School, or (ii) collected by Great Minds during the provision of products or services to a School, may include information defined as “educational records” by the Family Educational Rights and Privacy Act (“FERPA”) or other information protected by similar student data privacy laws. We call this information “Student Records.

Our collection and use of Student Records is governed by our contracts with the Schools, by our Privacy Policy, and by applicable privacy laws. For example, we work with Schools to help protect personal information in Student Records, as required by the FERPA, and to protect the personal information of students under 13 consistent with the Children’s Online Privacy Protection Act (“COPPA”).

Website Usage Information 

When you use the Great Minds Website or Great Minds Digital Platforms, certain personal information is automatically collected, such as website usage information associated with your device. Website usage information is personal information that includes, but is not limited to, your internet service provider, IP address, browser type, operating system version, location (city), language settings, and the domain name from which you accessed the Great Minds Website or Great Minds Digital Platforms. It may also include information such as the date and time you accessed the Great Minds Website or Great Minds Digital Platforms, how much time you spent on the Great Minds Website or Great Minds Digital Platforms, the pages you visited, your use of hyperlinks within the Great Minds Website or Great Minds Digital Platforms, and other “click-stream” data.

Video Hosting Platforms

We sometimes use video content from video hosting Platforms on the Great Minds Website or Great Minds Digital Platforms. These video hosting Platforms incorporate tracking technologies that may be present in the video hosting Platforms’ videos embedded on the Great Minds Website or Great Minds Digital Platforms, which may collect personal information from your browser when you view the video. This personal information is collected directly and automatically by the video hosting Platforms and its partners, and Great Minds does not participate in these data transmissions. Great Minds does not provide any personal information, such as usernames, to any video hosting Platforms.

II. How Great Minds May Use Your Information

Product Customization, Improvement & Marketing

We may use your email address to send you information regarding your student’s account or Great Minds products that you purchase or download. We also may use your email address to send you a newsletter and other communications from which you may unsubscribe at any time.

We may use the personal information we obtain to permit Schools and their authorized users, such as teachers and school administrators, to interact with students, review their work, provide feedback, and tailor our products and services; for analytic purposes to understand how our curricula, products, and services are used in order to improve them; and to provide reports to School customers, such as the progress of a particular school district, school, or class.

We may use aggregate data regarding test scores or personal information of school administrators or teachers we acquire through data brokers for our School-targeted marketing or sales efforts.

Cookies

We may use cookies on the Great Minds Website and Great Minds Digital Platforms to provide better technical support, for promotional purposes, and to track website usage. A "cookie" is a small data file that may be sent by a website or application and stored on the hard drive of your computer. A cookie stores information about your browser that allows the website or application to recognize your browser when you return, and to remember your preferences.

By using the Great Minds Website or Great Minds Digital Platforms, you agree to the use of cookies. You may reject cookies in your web browser settings, but by doing so, you may not be able to use all the features on the website or application. To learn more about browser cookies, including how to manage or delete them, check the “Help,” “Tools,” or similar section of your browser.

Analytics Data

We may use third-party tools such as Google Analytics or Pendo to collect analytics data to help us measure traffic and usage trends for the Great Minds Website or Great Minds Digital Platforms. This data helps us to understand more about the demographics of our users, or permits us to recognize and contact you across multiple devices.

You can learn more about Google's practices at http://www.google.com/policies/privacy/partners. You can view Google's currently available opt-out options at https://tools.google.com/dlpage/gaoptout. More info about Pendo security and privacy can be found at https://support.pendo.io/hc/en-us/articles/360031862372-Security-and-Privacy.

III. How Great Minds May Share Your Information

Great Minds engages subprocessors to perform functions to create and maintain the Great Minds Website and the Great Minds Digital Platforms and process certain of your personal information. For example, certain subprocessors are used to host the Great Minds Website.

Great Minds also engages third parties to perform certain business-related functions for us. For example, we sometimes hire third parties for mailing information, maintaining databases, hosting services, providing cloud-based services, processing payments, facilitating student assessments, providing rostering services, and generally to support our operations.

When we employ another company to provide services to support Great Minds, we provide them only with the information that they need to perform their specific function. Our subprocessors and third-party providers are legally obligated to keep your or your student’s personal information confidential. Our subprocessors and third-party providers also are required to maintain reasonable security practices, to use the information only for the purpose that we prescribe, and to prevent disclosure of the information to unauthorized parties.

Please see the link for the subprocessors and third parties to whom Great Minds provides personal information collected on the Great Minds Website and Great Minds Digital Platforms at https://greatminds.org/legal/notice-of-subprocessors. 

Great Minds does not sell to or share with any third parties any student personal information collected on the Great Minds Digital Platforms.

Great Minds may also share personal identifiable information collected by the Great Minds Website or Great Minds Digital Platforms under the following circumstances:

  • When we believe in good faith that disclosure of the information is necessary to protect our rights and those of others, to protect your safety or the safety of others, to investigate fraud, to respond to a government, judicial, or other legal request, or otherwise to comply with the law.
  • In the event that Great Minds is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of our assets, your or your student’s personal information may be transferred or disclosed in connection with such business transaction. If the transaction involves the transfer of Student Records, we will require the new owner to continue to honor the terms provided in this Privacy Policy, or we will provide you or the School with notice and an opportunity to opt out of the transfer of Student Records by deleting Student Records before the transfer occurs.

Anonymized or Aggregate Data

Great Minds may use data that have been anonymized and/or aggregated for to help us better understand how our Great Minds Website, Great Minds Digital Platforms, curricula, products, and services are used and to improve our curricula, products, and services.

In certain occasions, Great Minds may share anonymized and/or aggregated data with third-party providers or business partners to improve our curricula, products, and services. If we disclose information to authorized third-party providers or business partners to conduct research on online education or assist in understanding the usage, viewing, and demographic patterns for certain programs, content, services, promotions, and/or functionality of the Great Minds Website, Great Minds Digital Platforms, or Great Minds products and services, such data will be aggregated and/or anonymized to reasonably avoid identification of a specific individual.

IV. How Great Minds Secures And Protects Your Information

We maintain multiple, reasonable security measures to safeguard your information and protect it from loss, theft, misuse, or alteration. These measures include encryption, two-factor authentication, regular software security updates, periodic system and risk assessments, prompt remediation of identified security vulnerabilities, and other industry best practices for network and physical security. We don’t store any credit card information that you provide; that information is collected and processed by a third party that is compliant with the Payment Card Industry Data Security Standard.

Once we receive a transmission of your or your student’s information, Great Minds makes commercially reasonable efforts to ensure the security of our systems that process and store such information. When you enter sensitive information, we encrypt the transmission of that information by using secure socket layer technology (SSL) or similar technologies. However, no data transmissions over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that is transmitted or otherwise provided to us through the Great Minds Website, Great Minds Digital Platforms, or products or services, and you transmit such information at your own risk.

You are responsible for maintaining the strict confidentiality of Great Minds account passwords and for any activity that occurs under your account credentials, whether or not authorized by you. Please notify us of any unauthorized use of your or your student’s account or any suspected breach of security. We will comply with all applicable laws in the event of an unauthorized disclosure of personal information.

V. Your Privacy Rights

If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:

  • The right to access your personal information (including a data portability request);
  • The right to correct or amend any personal information we have on file about you;
  • The right to delete your personal information;
  • The right to limit the use of your “sensitive” personal information;
  • The right to opt-out of the sale or “sharing” of your personal information;
  • The right to opt-out of the use of your personal information for targeted advertising purposes;
  • The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);  
  • The right to restrict or opt-out of the use of your personal information for certain automated decision-making (including profiling in furtherance of decisions that produce legal or similarly significant effects);
  • The right to revoke your consent (to the extent applicable);
  • The right to confirm whether personal information about you is being processed; and
  • The right to obtain a list of specific third parties (or categories of third parties) to which we have disclosed your personal information or any personal information.

To exercise any of the rights listed above, please contact us via email at privacy@greatminds.org. Additionally, you may exercise your privacy rights by visiting https://app.sixfifty.com/request-easy/2345-9839/questions/5328929.

We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. We will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to privacy@greatminds.org with the subject line “Appeal of Decision Related to Privacy Rights Request.”

Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you. We will review the information provided and may request additional information to ensure we are interacting with the correct individual. If you have a password-protected online account with us, you may be required to log in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

After submitting your request, you will receive a follow-up email outlining the estimated amount of time it will take to complete your request and giving further instructions. That email may also include a link you must click on in order to verify your identity. If you do not click on that link, we will be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.

You may designate an authorized agent to make a request on your behalf. We accept documentation of your designation in the form of a valid power of attorney and/or a written authorization signed by you and the authorized agent. You may submit evidence of your designation of an authorized agent in writing to Great Minds PBC, Attn: Privacy Request, 55 M Street SE, Suite 301, Washington, DC 20003, USA. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

If you have implemented an opt-out preference signal on the Great Minds Website (sometimes known as a global privacy control) through your browser or device, we will treat that opt-out preference signal as a valid request to exercise the opt-out rights available to you under your jurisdiction’s privacy law(s). Once we recognize the opt-out preference signal, we will automatically apply your right to opt-out to the browser or device through which we recognize the signal. We respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized). To learn more about opt-out preference signals, please visit https://globalprivacycontrol.org/.

Students provided access to Great Minds Digital Platforms are unable to opt-out.   Great Minds agrees to not sell student personal information and to only share student personal information in limited instances through the obligations of data privacy agreements with each School district.

VI. How to Deactivate Your Account; Data Retention Policy

You may deactivate your Great Minds Website account at any time by contacting us at our Contact page. Following deactivation of your account, we will retain your account information for a period of up to six months in case you decide to reactivate your account during that period. However, you may request deletion of such account information earlier by contacting us at https://greatminds.org/contact. During the six months that the account is inactive following deactivation, we will not use or share your personal account information for any purpose.

If you don’t reactivate the account during that six-month period, we will anonymize and aggregate your information, meaning that we will remove all personal identifiers such as your or your student’s first and last name and email address. We retain aggregated, anonymized information for some of the purposes described above.

We may not be able to delete data in all instances, such as information retained in technical support logs and other business records. We will not be required to delete any information that has been anonymized or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual.

If you are a parent or legal guardian of a student for whom a School has created an account with a Great Minds Digital Platforms, please contact the School directly regarding deactivation of the account. Unless we receive a deletion request, we will retain your information for as long as your or your student’s account is active or as is reasonably useful for operational purposes or in compliance with applicable state law regarding Student Records. For example, we may retain certain data as necessary to prevent fraud or future abuse, for record keeping or other legitimate business purposes, or if required by law. We may also retain information that has been anonymized or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.

VII. How Great Minds Will Notify You of Changes to This Privacy Policy

We may occasionally update this Privacy Policy; you can see when we last updated this policy by checking the “Last Updated” date at the top of this page. We won’t reduce your rights under this Privacy Policy without your express consent. If we make any significant changes to this Privacy Policy, we will provide prominent notice by posting a statement on the Great Minds Website and the Great Minds Digital Platforms log-in pages and, if you have a Great Minds Website.

We encourage you to review this Privacy Policy from time to time to stay informed about how we collect, use, and disclose personal information. If you don’t agree with the changes to this Privacy Policy, you may deactivate your account, as discussed in Section VI above, or request your School deactivate your student’s account. By continuing to use the Great Minds Website, the Great Minds Digital Platforms your Great Minds account(s), or any Great Minds products or services after revisions to the Privacy Policy have become effective, you accept and agree to the then current version of the Privacy Policy.

VIII. Links to Other Sites

The Great Minds Website and Great Minds Digital Platforms may link to, and may be linked by, websites operated by other entities or individuals. Some of these websites may be cobranded with our name or logo. This Privacy Policy does not apply to, and we cannot always control the activities of, such third-party websites. You should consult the respective privacy policies of those third-party websites.

IX. How to Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Great Minds PBC

Attention: Privacy
55 M Street SE
Suite 301
Washington, DC 20003

You may also contact Great Minds at 202-223-1854 or privacy@greatminds.org.

X. CCPA Privacy Notice 

Last updated: September 5, 2024

Information for California Residents

This CCPA Privacy Notice applies to certain California residents (“Consumers”) from whom we collect personal information as a business under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”), including by the California Privacy Rights Act (“CPRA”).

For the purposes of this CCPA Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.

Personal Information does not include information that is

  • lawfully made available from government records,
  • deidentified or aggregate information, or
  • otherwise excluded from the scope of the CCPA.

“Consumer” does not include a natural person acting as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, or contractor of Great Minds PBC to the extent such person’s Personal Information is collected within the context of the person acting in such role. Persons acting in those roles should review the applicable Employee/Job Applicant Privacy Notice made available by Great Minds PBC.

California Consumers’ Rights and Choices

If you are a Consumer, the CCPA provides you with certain rights regarding your Personal Information, including the right to know about Personal Information collected, disclosed, or sold; the right to request that we delete Personal Information that we have collected from you; the right to update or correct your Personal Information; the right to opt-out of the sale or sharing of your Personal Information; the right to limit our use of your sensitive Personal Information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also view our Privacy Policy (see above) to learn more about how we protect your information.

In addition, if you are a Consumer, you may

  • opt out of receiving marketing communications from us; however, you may still receive administrative communications regarding our services; and
  • opt out of the use of your Personal Information for certain targeted or behavioral advertising purposes, as outlined above in this Policy.

The below outlines Great Minds’ collection and disclosure of Personal Information in the preceding 12 months from the date this CCPA Privacy Notice was last reviewed.

Collection of Personal Information

Great Minds Website may have collected the following categories of Personal Information about you over the past 12 months:

  • Identifiers such as name, postal address, cookie IDs, IP address, email address, or other similar identifiers;
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, student information signature, address, telephone number, fax number, education, or employment;
  • Internet or other similar network activity such as access history and information on your interaction with the Great Minds Website or Great Minds Digital Platforms;
  • Professional or employment-related information such as role or school district information; and/or
  • Non-public education information (per FERPA (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) such as grade level or school attended.

Great Minds Digital Platforms may have collected the following categories of Personal Information about your student over the past 12 months:

  • Identifiers such as name, grade, school, school identification number, role and sometimes email address; and
  • Data generated from use of the Great Minds Digital Platforms activity such as assessment results and information on interaction with the Great Minds Digital Platforms.

Sources of Personal Information

In the preceding 12 months since this CCPA Privacy Notice was last reviewed, we have collected Personal Information from the following categories of sources: directly from you (e.g., account information you complete or products and services you purchase), indirectly from you when using our services or visiting the Great Minds Website or Great Minds Digital Platforms, and from data brokers.

Use of Personal Information

Personal Information may be used for the purposes disclosed to Consumers at the time of collection in our general Privacy Policy (see above) and for the purposes of providing our services, communicating with Consumers, and developing and—only with respect to information collected through the Great Minds Website— providing marketing materials. Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.

Disclosure of Personal Information

We have disclosed for a business purpose, “shared,” or “sold” the Personal Information collected through the Great Minds Website as described in “Collection of Personal Information,” above, with third-party advertising networks, government entities, and third-party operating systems and Platforms in the previous 12 months for the purposes described in our Privacy Policy.

Great Minds does not share or sell any Personal Information collected within the Great Minds Digital Platforms.

Your Privacy Rights

If we maintain Personal Information about you that is subject to the CCPA, you may exercise certain rights in connection with this data if you are a Consumer. You may exercise these rights using any of the methods described in the “Exercising Your Privacy Rights” section, below, as applicable.

Right to Know

Consumers have the right to request that we disclose certain information about our collection and use of your Personal Information over the past twelve months (“Right to Know”). Once we receive and confirm your verifiable request, we will disclose to you:

  • The categories of Personal Information we collected about you;
  • The categories of sources for the Personal Information we collected about you;
  • The categories of Personal Information that we have sold or disclosed for a business or commercial purpose and, for each category identified, the categories of third parties to which we sold or disclosed that particular category of Personal Information;
  • Our business or commercial purposes for collecting or selling Personal Information;
  • The categories of third parties with whom we shared your Personal Information; and
  • The specific pieces of Personal Information we collected about you (i.e., a data portability request).

Right to Delete

Consumers have the right to request that we delete the Personal Information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers / contractors to delete) your Personal Information from our records, unless an exception applies.

Right to Correct

Consumers have the right to correct or amend the Personal Information we have on file (“Right to Correct”). Once we receive and confirm your verifiable request, we will correct your Personal Information in our records with the updated information that you provide to us.

Right to Opt-Out of Sale or Sharing

The CCPA provides Consumers with the right to opt-out of the “sale” or “sharing” of their Personal Information (“Right to Opt Out”). If you wish to opt-out of the sale or sharing of your Personal Information, please use one of the methods described in the “Exercising Your Privacy Rights” section, below.

We do not have actual knowledge that we sell or share the Personal Information of Consumers under the age of 16 collected from the Great Minds Website.

We do not sell or share student Personal Information collected from the use of the Great Minds Digital Platforms.

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides Consumers with the right to limit the use of their sensitive Personal Information to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations (“Right to Limit”).

We do not collect sensitive Personal Information and thus do not use your sensitive Personal Information for any purposes outside of those permitted by § 7027(m).

Right to Nondiscrimination

The CCPA provides Consumers with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA.

Great Minds will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • deny you use of the Great Minds Website or Great Minds Digital Platforms; or
  • provide you a different level or quality of services.

Exercising Your Privacy Rights

If you are a Consumer, you can request to exercise your Right to Know, Right to Delete, Right to Opt-Out of Sale or Sharing privacy rights under the CCPA by visiting https://app.sixfifty.com/request-easy/2345-9839/questions/5328929.

Alternatively, you may exercise these rights by calling 202-223-1854 or by emailing us at privacy@greatminds.org.

As explained above, the Right to Limit is not applicable to our use of your Personal Information, as we do not collect sensitive Personal Information.

Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).

We will review the information provided and may request additional information to ensure we are interacting with the correct Consumer. If you have a password-protected online account with us, you may be required to log in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

After submitting your request online, you will receive a follow-up email outlining the estimated amount of time it will take to complete your request and giving further instructions. That email may also include a link you must click on in order to verify your identity. If you do not click on that link, we will be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.

By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or re-identify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.

We generally will aim to avoid requesting additional information from you for the purposes of verification. However, if we cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, we may consider any of the following factors, alone or in combination, in requesting additional information:

  • The type, sensitivity, and value of the Personal Information collected and maintained about the Consumer, as applicable law requires a more stringent verification process for sensitive or valuable Personal Information;
  • The risk of harm to the Consumer posed by any unauthorized access or deletion;
  • The likelihood that fraudulent or malicious actors would seek the Personal Information;
  • Whether the Personal Information to be provided by the Consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
  • The manner in which we interact with the Consumer;
  • Available technology for verification; or
  • Other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this CCPA Privacy Notice.

If your request is regarding household information, the same verification steps above may be required before we can provide you with aggregate household information. In addition, if you do not have a password-protected online account with us, for us to process a request for access to or deletion of specific pieces of information regarding your household, we may need all members of the household to make the request, and we may need to individually verify each household member and that each member making the request is currently a member of the house.

We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

Authorized Agent Requests

You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a written authorization signed by you and the authorized agent. You may submit evidence of your designation of an authorized agent in writing to Great Minds PBC, Attn: Privacy Request, 55 M Street SE, Suite 301, Washington, DC 20003, USA.

We may require verification of your authorized agent in addition to the information for verification above for Consumers and households.

Opt-Out Preference Signals

If you decline tracking of your information, Great Minds implements an opt-out preference signal on the Great Minds Website (sometimes known as a global privacy control) through your browser or device, and will treat that opt-out preference signal as a valid request to exercise your Right to Opt Out. Once we recognize the opt-out preference signal, we will automatically apply your right to opt-out of sale and sharing to the browser or device through which we recognize the signal. We respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized). To learn more about opt-out preference signals, please visit https://globalprivacycontrol.org/.

Great Minds does not sell or share users Personal Information except as outlined in this Privacy Policy.

Denial of Deletion Requests

We may deny your deletion request if retaining the information is necessary for Great Minds or our service providers to do the following:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  3. Debug products to identify and repair errors that impair existing intended functionality;
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546);
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  7. Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us;
  8. Comply with a legal obligation; and/or
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Children

The Great Minds Website is not directed to children. The Great Minds Digital Platforms are only to be used by a student under 16 with authorization by the student’s parent, legal guardian, or School. Great Minds does not knowingly collect Personal Information from children under the age of 16 without authorization by the student’s parent, legal guardian, or School. We never sell the Personal Information of any student. If you learn that a child has provided us with Personal Information without parent, legal guardian, or School authorization, you may contact us through the Contact Us section below.

Notice of Financial Incentive

Great Minds does not offer financial incentives to Consumers based upon the collection or retention of a Consumer’s Personal Information.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this CCPA Privacy Notice was last updated is identified at the beginning of the CCPA Privacy Notice. You are responsible for periodically visiting the Great Minds Website and this CCPA Privacy Notice to check for any changes.

Contact Us

If you have any questions or concerns regarding this CCPA Privacy Notice, contact privacy@greatminds.org.