Coach Privacy Policy

Last updated: April 18, 2024

CareerVillage, Inc. (hereinafter referred to as “CareerVillage”, “us”, “we”, or “our”), a United States 501(c)(3) nonprofit organization, has created this Privacy Policy to apply to all users of Coach and this website https://www.app.aicareercoach.org/, along with any associated software applications and digital assets (collectively, our “Services”).

CareerVillage’s mission is to democratize access to career advice and information for underserved individuals. The CareerVillage.org Network (the “Network”) is a set of internet sites and applications designed to support that mission. The Coach site is part of the Network. Without users like you, pursuing our mission would not be possible, and it’s for that reason that we want you to feel confident and comfortable with how we are protecting and using your Personal Information (defined below).

We are publishing this Privacy Policy to help you understand what Personal Information we collect, how we use that information, and what options we offer you to access, update, and control it. This Privacy Policy only covers information collected through your use of the Services – it does not apply to information that may be collected by other means such as information you provide to us in the employment context. If you haven’t yet, please also take a moment to review our Terms and Conditions. If you have any questions, please let us know by emailing us at hello@careervillage.org.

By using the Services and providing us with your Personal Information, you acknowledge and agree to the practices described in this Privacy Policy and the Terms and Conditions referenced above and to the updates to these policies posted here from time to time.

Depending on where you live, you may be entitled to certain individual rights with respect to your Personal Information. Please see the Notice to Residents of Certain States below for more information related to privacy rights that may be applicable to you.

Thanks so much!

- The CareerVillage Team

I. Types of Information

We may collect the following categories of information about you which are described in more detail below: (A) Personal Information you provide to us; (B) Sensitive Personal Information; (C) information we may automatically collect about you; and (D) information we may receive from third parties. All of the information listed in (A)-(D) above, are detailed below, and hereinafter referred to as “Information.”

A. Personal Information you provide to us

In using our Services, you may provide us with Personal Information, including, without limitation:

  • Individual identifiers such as name, username, birth date, gender, and contact information such as mailing address, phone number, and email address;

  • Educational information such as educational background, school information, degrees obtained, year of graduation, languages, and academic qualifications;

  • Communications with us, preferences, and other Personal Information you provide to us such as any messages, opinions and in-app career readiness survey feedback, and your user preferences; and

  • Additional Personal Information that you include in your input to the Services or as otherwise described to you at the point of collection or pursuant to your consent.

B. Sensitive Personal Information

We may need to collect or process the following categories of Sensitive Personal Information when you use our Services:

  • Racial, ethnic, or national origin information;

  • Sexual orientation information;

  • Status as transgender or nonbinary; and

  • Citizenship or immigration status

When required by applicable law, CareerVillage will collect consent prior to processing certain categories of Sensitive Personal Information.

C. Information we may automatically collect about you

Our Services may automatically collect the following categories of usage and technical information about you:

  • Information related to the devices or browsers you use to access or interact with our Services, such as: IP addresses, geolocation information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, and unique numbers or codes in cookies;

  • Information related to the ways in which you interact with our Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, and other similar information; and

  • Other data, such as search criteria and results, email opens, and clicks on links in emails.

i. Cookies and technologies used to collect information about you

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this information by using certain technologies, such as cookies, web beacons, pixels, software developer kits, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.  

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. 

  • Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Personal Information either directly to us or to a third party authorized by us to collect Personal Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

  • Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.

D. Information we may receive from third parties

We may collect additional Personal Information about you from third-party websites, social media platforms, and/or sources providing publicly available information to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.

This Privacy Policy only applies to Personal Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the Personal Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

E. Information you give to other people

This Privacy Policy only applies to Personal Information collected by us. It does not apply to the practices of companies that we don’t own or control, or employees that we don’t manage. The Services contain links to third-party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites’ responsibility to protect any information you give them, so we can’t be held liable for their wrongful use of your Personal Information.

II. How We Use Your Information

A. Use and Purpose of Processing Your Personal Information

We use and process your Information for things that may include, but are not limited to, the following:

  • To provide you with the Services and information you request.

  • To allow you to efficiently register for and access our Services.

  • To communicate with you about our Services and our organization, for example, by using your email address to email you.

  • To help Educators find and connect with their Learners or fellow Educators (this applies to you if you’re using the dashboard, cohort, or cohort invite code features). We show Educators the full names and contact information for the Learners who have used their invite codes.

  • To comply with policies, audits, the DMCA, or other applicable laws.

  • To transfer information to others as described in this policy.

  • To analyze trends in the use of the Services, in order to evaluate our impact and/or improve.

  • To provide aggregated analytics for business purposes and business intelligence to coalition/service partners, including educational institutions.

  • For general or targeted marketing and advertising purposes, including sending you promotional material, or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted out of receiving such communications.

  • To fulfill contracts that we have with you.

  • To comply with our Terms and Conditions.

  • For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent.

We may also use Personal Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Use and Purpose of Processing Your Sensitive Personal Information

We do not collect, use, or disclose sensitive Information beyond the purposes authorized by the applicable law.  Accordingly, we only use and disclose sensitive Information as reasonably necessary and proportionate:  (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) with our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

C. Email communications

We may send you emails to tell you about new features, to solicit your feedback, or just keep you up to date with what’s going on with our organization and our Services. If we do send you information that you did not expressly request, we will provide you with a way to request that you don’t get any similar notices (opt-out).

If you do not wish to receive email from us, please click ‘unsubscribe’ at the bottom of the email. However, please note that you will continue to receive all system emails (e.g. password reset emails) and legal notices (e.g. updates to our policies) from us.

D. Social network accounts you connect

When you connect accounts with other social networks including LinkedIn, Facebook, and X (formerly Twitter) to your account on our services, we may use the information we gather from those services, such as your name and contact information, to setup your account enable login, and improve your experience on our Services. We do not control how social networks use your Information, and you should review the privacy policies of such social networks for more information about their practices.

III. Sharing Your Personal Information

A. Learner and Educator Personal Information

If you are a learner using the Services based on a direct agreement between us and your school, administrators and educators at your school may see the Information you share with us.  If you are an educator using the Services based on a direct agreement between us and your educational agency, other educators at your educational agency may see your Information. This allows every educator in the educational agency to contact and coordinate with any other educator in that educational agency.

B. Disclosure for legal and administrative reasons

We may disclose your Personal Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the Service users; (v) to enforce or apply our Terms and Conditions; and (vi) to verify the identity of the user of our Services.

C. Business transfers

Your Personal Information may be transferred or otherwise conveyed to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.

D. Disclosure to third-party service providers

We may disclose your Personal Information to third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Personal Information only as necessary to provide these services to us. Where possible, we may aggregate Personal Information we collect so third parties do not have access to your identifiable Personal Information to identify you individually.

E. Sharing with Organizations

When you use the Services through an organization that has a direct agreement with us (“Organization”) to provide the Services to you, any Information you share with us may be viewable by that Organization.

F. Sharing with researchers

On occasion we work with researchers to analyze the impact of our programs. Prior to providing any agents or partners with any Personal Information, we will obtain assurances that they will safeguard it in accordance with this policy. We will also anonymize any Personal Information we provide to researchers or seek your opt-in permission if required to disclose any Information to researchers.

G. Sharing with your consent

We may share Personal Information consistent with this Privacy Policy with your consent.

We do not sell, rent or trade your personal data.

Nothing more to say on that :)

IV. Opting Out of Direct Marketing by Third Parties

To exercise choices regarding the marketing information you receive, you may review the following links:

  1. You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

  2. You may opt out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

V. How Long We Retain Personal Data

We retain Personal Information for as long as necessary to fulfill the purposes for which we collect or receive the Personal Information, except if required otherwise by applicable law. Typically, we will retain most of the Personal Information for the duration of your use of the Services, until you have deleted your account, unless a longer applicable statutory retention period applies. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information.

VI. Notice to Residents of Certain U.S. States

Residents of certain U.S. states may have rights and choices regarding their Personal Information. To the extent any data protection law applies to our collection of your Personal Information, this supplemental section of our Privacy Policy outlines the individual rights you may be entitled to and how to exercise those rights.

1. Rights under applicable data protection laws.

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.

  • Right to know and access.  You may have the right to request that we confirm whether we process your Personal Information, and to request information about our collection and use of your Personal Information, including whether we sell your Personal Information. You also have the right to request access to Personal Information we may process about you. 

  • Right to data portability: Subject to certain exceptions, you may have the right to request and obtain a copy of your Personal Information that you previously provided to us in a portable format. In addition, to the extent technically feasible, you may have the right to obtain your Personal Information in a readily usable format that allows you to transmit the Personal Information to another data controller without hindrance.

  • Right to request correction of inaccuracies.  To the extent that we may maintain inaccurate Personal Information, you may have the right to request that we correct such inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. 

  • Right to request deletion: You may have the right to request that we delete certain Personal Information or records provided by or obtained about you, with certain exceptions and limitations as allowed under law. 

  • Right to opt out of the sale of Personal Information, targeted advertising, and profiling. You may have the right to opt out of the processing of your Personal Information for the purpose of selling your Personal Information, for targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, to the extent we engage in such processing activities.  As noted elsewhere in this policy, we do not sell your Personal Information.

  • Right to obtain a list of the categories of third parties to which Personal Information has been disclosed: You may have the right to obtain a list of the categories of third parties to which we have disclosed your Personal Information.

  • Right to obtain a list of specific third parties to which Personal Information has been disclosed: At our option, you may have the right to obtain a list of specific third parties, other than natural persons, to which we have disclosed your Personal information.

  • Right to non-discrimination: You may have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying Services, charging different prices or rates for Services, or providing a different level of quality of Services.

  • Right to appeal.  You may have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeal request via the information in the Contact section below. Within the certain timeframe of receipt of your appeal, as proscribed by the applicable law, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Attorney General or applicable authority in your state, which we will help you identify.

2. Exercising your data subject rights

To exercise any of the rights described above, please submit a verifiable request to us via the methods described below. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information, or an authorized representative; and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Personal Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Personal Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. Only you or your authorized agent may make a verifiable request related to your Personal Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

Email us: help@aicareercoach.org 

Write us: CareerVillage, Inc.

Attn: Privacy

1475 Columbia Ct.

Palo Alto, CA 94304

VII. Information Security

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your information on our services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Information.

VIII. Where Is My Data Stored?

Our Services are primarily used by individuals located inside the United States, and we maintain significant operations in the United States. As such, the Services collect Personal Information and process and store that Personal Information in databases located in the United States. Our third-party service providers may also store Personal Information in the EU when providing services to us. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer Personal Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any Personal Information you consent to the transfer of such Personal Information to the United States.

IX. Links

We are not responsible for the practices employed by websites linked to or from our Services, nor the information or content contained therein. Please remember that when you use a link to go from our Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our Services, is subject to that website's own rules and policies.

X. Children’s Information

The Services are intended only for users over the age of thirteen (13). If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Personal Information, we will take steps to comply with any applicable legal requirement to remove such Personal Information. Contact us if you believe that we have mistakenly or unintentionally collected Personal Information from a child under the age of thirteen (13).

XI. Difficulty Accessing Our Privacy Policy

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. Changes

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Last Updated” date and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes. In some cases, we may provide you with more prominent notice (such as by adding a statement to our homepage or sending you an email notification).

XIII. Terms

If you haven’t yet, please also take a moment to review our Terms and Conditions.

XIII. Contact

If you have any concerns or complaints about how you think we’ve handled your personal information, please let us know by emailing us at help@aicareercoach.org or by mail at:

CareerVillage, Inc.
Attn: Privacy
1475 Columbia Ct.
Palo Alto, CA 94304

We hope you enjoy using our services!