GREAT MINDS PRIVACY POLICY

Great Minds^® and 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, why we collect it, and how we will use, share, and protect this information. This Privacy Policy applies to the Great Minds website, www.greatminds.org (the “Great Minds Website”), as well as any products or services offered by Great Minds and our subsidiaries or affiliates (“Great Minds,” “we,” “us,” “our,”) including, but not limited to, Great Minds’ digital portals, services, and applications (collectively, “Great Minds Digital Platforms”).

The Great Minds Website or Great Minds Digital Platforms may be used by schools, school districts, or teachers (collectively referred to as “Schools”) in a classroom setting. When Great Minds enters into a contract with Schools to provide access to the Great Minds Digital Platforms or Great Minds products and services as part of the School's educational curriculum, we may have access to personal information about students, teachers, or school administrators.

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.

PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF PERSONAL INFORMATION FROM STUDENTS IN CONNECTION WITH OUR PRODUCTS AND SERVICES.

This Privacy Policy does not apply to websites, services, or practices of companies that Great Minds doesn’t own or control, such as third-party services accessible through links or other features on the Great Minds Website or Great Minds Digital Platforms. These other sites and services have their own privacy policies, and we encourage you to review them before providing them with personal information.

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. If you do not agree to the terms of this Privacy Policy, please do not use the Great Minds Website, Great Minds Digital Platforms, or Great Minds products or services.

I. INFORMATION COLLECTED BY GREAT MINDS

Information That You Provide

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 email address, teacher ID number, student first and last name, student ID number, state, affiliated school and district name, class section, you or your student’s age and gender, your role (e.g., parent, teacher, school administrator, etc.), student assessment scores, and other information that can identify you or your student.

In addition, 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.

Website Usage Information

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

We use cookies to collect the website usage information described above. 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 us to recognize your browser when you return and to remember your preferences. You may reject cookies, but by doing so, you may not be able to use all the features on the Great Minds Website or Great Minds Digital Platforms. To learn more about browser cookies, including how to manage or delete them, check the “Help,” “Tools,” or similar section of your browser. By using the Great Minds Website or Great Minds Digital Platforms, you agree to the use of cookies.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Great Minds Website or Great Minds Digital Platforms and to understand more about the demographics of our users. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners. You can view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We may use third-party tracking technologies, such as Pendo, to enhance your experience on the Great Minds Digital Platforms. More info about Pendo security and privacy can be found at https://support.pendo.io/hc/en-us/articles/360031862372-Security-and-Privacy.

We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

Information We Derive

We may derive personal information or draw inferences about you or your student based on information Great Minds or our partners collect. For example, we may make inferences about your or your student’s location (e.g., country, state, and city) based on the IP address of the computer used to access the Great Minds Website or Great Minds Digital Platforms.

Information from Integrated Sign-On Services

If you decide to create a Great Minds 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.

Information Provided by Schools

The Great Minds Website and Great Minds Digital Platforms are available to Schools to use as part of their selected educational curriculum. The Great Minds Website and Great Minds Digital Platforms are designed to minimize the collection of personal information from students and to comply with federal and state student data privacy laws. 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.”

Schools may provide us usernames that may identify you, your student, or your devices and other information associated with a class or grade level. Schools, including teachers and other School-authorized personnel, may be able to see information regarding students’ use of the Great Minds Website or Great Minds Digital Platforms in connection with a class and make changes to a student’s username and other information.

When a student account is created by a School, the School is responsible for removal of a student from a class roster or submitting a deletion request when a student’s personal information is no longer required for School purposes.

If a parent or legal guardian accesses the Great Minds Website or Great Minds Digital Platforms on a personal device, the parent or legal guardian may be able to view their student’s personal information (such as username and activities completed) by logging into the student’s account.

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”).

If you (not a School) created a student account directly through the Great Minds Website or the Great Minds Digital Platforms, you remain in control of the personal information that you provide to us. This means that you may contact Great Minds for review, modification, or deletion of your student’s personal information at any time. If, however, your student’s Great Minds Website or Great Minds Digital Platforms account has been created by your student’s School, please contact the School directly if you have any questions about reviewing, modifying, or deleting your student’s personal information.

We do not track our users across third-party websites and do not respond to Do Not Track (DNT) signals. Third-party websites are not able to collect personal information about your or your student’s activity on the Great Minds Website or Great Minds Digital Platforms.

Information from Data Brokers

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.

II. HOW GREAT MINDS MAY USE YOUR INFORMATION

Great Minds Website and Great Minds Digital Platforms Access and Improvements

Information provided to Great Minds upon creation of a student account allows you or your student to log in and store your preferences for communications from us and future use of the Great Minds Website, Great Minds Digital Platforms, and our products and services.

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 through the Great Minds Digital Platforms 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 use your non-personal information and other demographic information in aggregated, anonymized reporting 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. We use aggregated, anonymized Student Data, including site usage, that we collect for the same purposes.

Great Minds may use the personal information collected through tracking technologies on the Great Minds Website to provide better technical support, for promotional purposes, and to track website usage. For example, cookies help us do the following:

1. Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you
2. Remember you so that you do not have to resubmit information when you return to the Great Minds Website
3. Remember your settings on the pages you visit so that we can display your preferred content the next time you visit
4. Customize the function and appearance of the pages you visit based on information relating to your student’s account (e.g., to default you to a particular study level or to remember customized settings for a report)
5. Track website usage for various purposes, including sales, marketing, and billing

For the Great Minds Digital Platforms and services, Great Minds may use cookies but only to track user credential information. This information is used to help diagnose log-in access issues, if needed.

Third-Party Ad Networks

Great Minds uses behavioral tracking cookies on the Great Minds Website. Great Minds also uses third-party ad networks’ tracking technologies to recognize your browser or device and to collect information about your visit to the Great Minds Website. 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.

Great Minds does not display any targeted advertising on any Great Minds Digital Platforms students use, nor does Great Minds intentionally target students in any Great Minds advertising.

Video Hosting Platforms

Great Minds sometimes uses 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, including device identifiers and/or cookie IDs. 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.

III. HOW GREAT MINDS MAY SHARE YOUR INFORMATION

Personal Information

We never sell or rent your or your student’s personal information to third parties for any purpose.

We will share your or your student’s personal information with third parties only in 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.
• When we hire third parties to perform certain business-related functions for us. For example, we sometimes hire third parties for mailing information, maintaining databases, hosting services, processing payments, 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 third-party providers are legally obligated to keep your or your student’s personal information confidential. Our 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.

Anonymized or Aggregate Data

Great Minds may use data that have been anonymized and/or aggregated for product development, research, analytics, and other purposes, including for the purpose of analyzing, improving, or marketing the Great Minds products and services. In certain occasions, Great Minds may share these 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.

When an account is created on the Great Minds Website or Great Minds Digital Platforms, you or your School will be asked to create a password. This password will be used to allow access to your or your student’s account information and, as applicable, certain portions of the Great Minds Website, the Great Minds Digital Platforms, and our products and services. 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. HOW TO CHANGE YOUR INFORMATION OR OPT OUT OF COMMUNICATIONS

You can manage the information you provide.

If you contact us, we will ask you to verify your identity before we provide you with information or make changes to your or your student’s Great Minds account(s). You can contact us at our contact page. If your student was registered with the Great Minds Website or any Great Minds Digital Platform through a School by using an Integrated Service, please contact the School directly regarding changing the information or the School’s compliance with the Integrated Service's terms of use and privacy policies.

You can unsubscribe from email communications.

You also may choose to opt out of our newsletters and other communications (though we hope you’ll stay connected!). To opt out, click on the “unsubscribe” link that appears on Great Minds emails or contact us at our contact page. Please note that you are not permitted to unsubscribe or opt out of non-promotional messages regarding your Great Minds accounts, such as account verification, changes or updates to features of the Great Minds products or services, or technical or security notices.

VI. HOW TO DEACTIVATE YOUR ACCOUNT; DATA RETENTION POLICY

You may deactivate your or your student’s 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 Platform, 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 bottom 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 account, notifying you by email.

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. OUR COLLECTION OF PERSONAL INFORMATION FROM STUDENTS

The Great Minds Website is not directed to children under the age of 13. The Great Minds Digital Platforms may be used by children under age 13 under the authorization of their School to be used in conjunction with the Great Minds curricula. Great Minds does not knowingly collect personal information from children through the Great Minds Website and Great Minds Digital Platforms except as otherwise detailed herein and only then if we have permission from a parent or legal guardian or a written agreement with the student or School allowing us to collect the information.

We may collect from parents, legal guardians or Schools the following types of student personal information: name; grade level; school and school district ids; classes/sections; information and content submitted (e.g., responses to questions, assessments, notes, video or voice recordings).

Subject to any restrictions imposed by applicable law or our agreement with our customer, we use and disclose the personal information we collect from students

• to personalize their experience;
• to permit our customer and authorized users, such as teachers and school administrators, to interact with students, review their work, provide feedback, monitor their progress, and tailor our products and services as appropriate;
• for analytics purposes so that we can understand how our curricula, products, and services are used and to develop and improve them; and
• to provide reports to our customer, such as about the progress of a particular school district, school, or class.

We may also disclose a student’s personal information: (a) as directed by our customer to which the information relates; (b) to our third-party service providers to permit them to provide services to us; (c) as we believe necessary or appropriate (i) to comply with legal process or to respond to requests from government authorities, or (ii) to protect our rights, safety, or property and/or that of our affiliates, our customers, our users, or others; (d) in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

For student-facing Great Minds Digital Platforms and services, Great Minds may use cookies but only to track user credential information. This information is used to help diagnose log-in access issues, if needed.

Subject to any restrictions imposed by applicable law or our agreement with our customer, we may use and disclose student non-personal information for any purpose. See Article III of this Privacy Policy.

If you are the parent or legal guardian of a student and you would like to request access to your student’s personal information on the Great Minds Digital Platforms, request its deletion, or refuse to permit further collection of it, please contact your student’s School.

We are proud supporters of the Student Privacy Pledge. 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 from student educational records, as required by FERPA, and to protect the personal information of students under 13 consistent with COPPA. If you have any questions about reviewing, modifying, or deleting the personal information of a student accessing the Great Minds Website or Great Minds Digital Platform through a School customer agreement, please contact your School directly.

• We collect, maintain, use, and share Student Records only for an authorized educational purpose and as described in our Privacy Policy or as directed by the School, the student, and/or the student's parent or legal guardian.
• We do not disclose Student Records for targeted advertising purposes. We do permit third-party advertising partners to operate on our Great Minds Website for the purpose of analytics. We do not use third-party ad networks on Great Minds Digital Platforms.
• We do not build a personal profile of a student other than in furtherance of an educational purpose or as authorized by a parent or legal guardian.
• We maintain a comprehensive data security program designed to protect the types of Student Records maintained.
• We will clearly and transparently disclose our data policies and practices to our users.
• We will never sell Student Records unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Privacy Policy, or we will provide the School with notice and an opportunity to opt out of the transfer of Student Records by deleting the Student Records before the transfer occurs.
• We will not make any material changes to our Privacy Policy or contractual agreements that relate to the collection or use of Student Records without first giving notice to the School and providing a choice before the Student Records are used in a materially different manner than was disclosed when the information was collected.

IX. 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.

X. 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 1-800-859-1452 or privacy@greatminds.org.

CONTACT US

XI. CCPA PRIVACY NOTICE

Information for California Residents

In addition to our full Privacy Policy at privacy@greatminds.org, 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”).

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 CCPA Limited Privacy Notice made available by Great Minds PBC.

California Consumers’ Rights and Choices

If you are a Consumer, the CCPA may permit you to request information regarding the

• categories of Personal Information (as defined by the CCPA) collected, sold, or disclosed by us;
• purposes for which categories of Personal Information collected by us are used;
• categories of sources from which we collect Personal Information;
• categories of third parties with whom we share Personal Information; and
• specific pieces of Personal Information we have collected about you and in some cases your household.

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;
• opt in to certain financial incentive programs we may offer related to the collection or retention of your Personal Information; and
• request that we and our service providers delete Personal Information we have collected from you, in some circumstances.

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.

Categories of Personal Information

• Identifiers such as name, postal address, Internet Protocol 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, signature, Social Security number, address, telephone number, fax number, education, or employment;
• Protected classification characteristics under California or federal law such as age or gender;
• 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 the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) such as grade level or school attended.

Sharing of Personal Information

We may share such Personal Information 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.

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 privacy@greatminds.org) 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.

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.

Sale of Your Information

We have not sold your Personal Information for the preceding 12 months from the date of the last review of this CCPA Privacy Notice.

Privacy Requests

If you are a Consumer, you can make requests to know what Personal Information we have collected from you in the past 12 months or requests to delete your Personal Information via the following:

• Access My Personal Information: (http://www.requesteasy.com/5dfa66654e2a1d00045c7cdd)
• Delete My Personal Information: (http://www.requesteasy.com/5dfa66654e2a1d00045c7cdd)
• Do Not Sell My Personal Information: (http://www.requesteasy.com/5dfa66654e2a1d00045c7cdd)
• By calling 1-800-859-1452

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.

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.

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.

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.

Non-Discrimination

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.

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 bottom of this page. 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.

Last updated: February 21, 2023