Last Updated: July 2019
1. Collection and Use of Personal Information
A. What Information Does Technovation Collect From You?
To enhance your experience on the Websites, we collect the following information (“Personal Information”) that you provide to us. Although you may visit some pages on our website without providing all of the Personal Information listed below, you must provide certain information to take advantage of particular features, such as sharing your projects, receiving feedback from our mentors & judges, receiving badges & certificates, and participating in project competitions.
The Websites collect the following Personal Information:
- City, state, and region of residence
- E-Mail address
- A username that you create
- Telephone number
- Date of birth
- IP address
- Parents’ names and e-mail addresses (for minors)
- User-submitted photos and video
Additionally, when you access the Websites using a mobile device, we may collect the following additional information:
- Unique identification number associated with your device (“Device ID”)
- Mobile carrier
- Device type and manufacturer
- Telephone number
- Depending on your mobile device settings, your geographical location data, including GPS coordinates or similar information regarding the location of your mobile device
We collect this information from you when you register on the Websites or request products or services that the Websites offer. You may be asked to provide information if you participate in any sweepstakes, contests, or surveys, or if you post or access any content on message boards, chat rooms, or blogs operated by Technovation and its programs. We may also collect this information when you post materials as part of a project submission.
The Websites may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Websites. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Websites.
B. Purposes of Information Collection
Our purpose in collecting your Personal Information is to provide you with our services. Specifically, we use your Personal Information to accomplish the following legitimate purposes:
- Communicating with you regarding our programs, features, and services available through the Websites.
- Sharing our curriculum.
- Helping you participate in projects and competitions as part of our program.
- Helping students and mentors build healthy relationships to carry out team exercises and competitions, including connecting students and mentors using third-party communication services such as e-mail, hangouts, and slack.
- Communicating with you regarding products, features, and services that are offered by our affiliates and business partners.
- Issuing e-mail newsletters on other topics we think may be of interest, such as programs offered by Technovation, internships, and/or scholarships.
- Troubleshooting and website administration.
- Complying with a legal obligation where necessary, such as being compelled to share Personal Information by a law enforcement or government agency.
C. Consent for Collection and Use of Personal Information
1. Consent by Adults (Aged 16 and over)
- For all website users who provide us with Personal Information, you may opt-out from our services completely at any time. If you do so, we shall remove any Personal Information that we have collected from you based on your consent.
Please allow up to 10 business days for us to process your request. After opting out, you may still receive e-mail messages about the status of your account, to resolve technical issues, or to confirm a renewed membership.
2. Parental Consent for Minors (Aged under 16)
Parents can provide consent by email, fax, or postal mail for their children to provide personally identifiable information to us. The parental consent enables children under 16 to access the Websites, Technovation Services or participate in Technovation’s programs or activities. Parental Consent forms are emailed to parents when students create Technovation Family accounts or enroll in Technovation Girls. Alternatively, consent forms can be downloaded for Technovation Families and Technovation Girls. Upon receipt of the parental consent form, Technovation will unlock student accounts, and students will be eligible to participate in our programs.
To provide consent by fax or postal mail, parents should fill out the parental consent form, sign it and send it to Technovation at:
700 El Camino Real Suite 120
Menlo Park, CA 94025
with subject line: Parental Consent for [Name of Child]
with subject line: Parental Consent for [Name of Child]
II. Your Privacy-Related Rights
A. Your EU Privacy Rights
Residents of the EU have certain rights afforded to them by the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”).
1. Transfers out of the European Economic Area
2. Your EU legal rights
You have the right to:
- Request correction of the Personal Information that we hold about you, where the information is incorrect.
- Request deletion of your Personal Information. As noted above, this may involve ending further participation in Technovation’s programs.
- Object to us using your Personal Information. You may object on grounds that you feel it impacts your fundamental rights and freedoms, or on grounds that we are using your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms.
- Request restriction of our use of your Personal Information. You may make this request (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Information to you or a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of these rights, please contact us at [email protected] We may need to request additional information from you to help us confirm your identity. We try to respond to all legitimate requests within one month. It may take us longer to respond to your request if your request is particularly complex or if you have made multiple requests. In that case, we will notify you and keep you updated on the status of your request.
B. Your California Privacy Rights
If you reside in California, you may request information about our disclosures of your Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us by e-mail at [email protected]
Within thirty days of receiving such a request, we will provide a list of the categories of personally identifiable information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than as specified in the above paragraph.
C. Other Privacy Rights
The following provisions apply to all users of the Websites, regardless of location.
1. Data Retention
We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for; namely, to provide you with the benefits of participating in our programs. Periodically, and at least once every four years, we delete Personal Information of persons who no longer participate, retaining only enough Personal Information to ensure that persons who have opted out of Technovation communications are not opted back in to receive such communications.
2. Data Breach Notification
In the event of any suspected data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so. For EU data subjects, we shall notify the competent supervisory authority of any data breach that is likely to result in a risk to the rights and freedoms of natural persons within 72 hours of the breach, or else accompany our notification with reasons for the delay. This notification shall describe the nature of the Personal Information at risk, including the categories and approximate number of data subjects concerned, the name and contact details of the data protection officer, the likely consequences of the breach, and the measures taken to address the breach. We will also notify you without undue delay of any data breach that is likely to result in a high risk to your rights and freedoms.
To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of all Personal Information, including that of child users, we have put in place physical, electronic, and administrative procedures to protect the Personal Information we collect online. No data transmission over the Internet, however, can be guaranteed to be completely secure. While we strive to protect your Personal Information, Technovation cannot completely ensure or warrant the security of personally identifiable information you provide to us.
If we learn of a data security incident that compromises or appears to compromise your Personal Information, we will notify you according to the applicable data privacy regulations in force where you are located.
V. School Privacy
In some circumstances, we may permit a school to register students to our service for the purpose of providing educational services. Because Technovation provides the Websites to schools to benefit and enhance the school’s curriculum, Iridescent relies on the school to obtain and provide appropriate consent, if needed, to collect Personal Information of students.
VI. Third-Party Links
VII. Privacy By Design Standard
As we carry out all of our operations and programs, we are committed to protecting the privacy of your Personal Information. To this end, no project or program shall be implemented without consideration of the risks to data privacy, and implementation of any necessary measures to protect your privacy rights.
VIII. Implementation and Sanctions
Any violation of this policy by a member of Technovation may result in administrative and/or disciplinary action by Technovation (including monetary penalties, suspension or termination). These sanctions will be applied subject to local legislation.
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