Last Updated: August 25, 2022
WHAT DATA WE COLLECT ABOUT YOU
Account Information. We receive and store any information you knowingly provide to us. Through some requests you make (including but not limited to applying for or nominating someone for our Fellowship program, requesting curricular materials, or joining our mailing list), we may collect personal data such as your name, email address, school, school address, title, and other information about your interests and preferences. Any other information combined with your personal data will be treated together as personal data.
Information Collected Through Your School.
We will add information to your personal data that the school may provide to us in connection with our Site and Services. Formation Ventures understands that it is important that our partner schools comply with the Family Education Rights and Privacy Act (“FERPA”) and related regulations. Certain information collected through your school that may be provided to Formation Ventures that is directly related to a student and maintained by your school, may be considered an education record (“education record”) under FERPA.
INFORMATION COLLECTED AUTOMATICALLY
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Site.
The technologies and information we automatically collect include:
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included in the Services and Site for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of the Services, to monitor how many visitors view the Services.
Information Related to Use of the Services. Our servers may automatically record certain information about how a person uses the Services or Site (“Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, browser type, operating system, the web page that a user was visiting before accessing our Site or the Services, the pages or features of the Services to which a user browsed and the time spent on those pages or features, search terms, the links on the Formation Ventures Site or Services that a user clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our user’s needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how the Services are used.
Information Sent by Your Device. We collect certain information that the device from which you are using the Services and Site (such as, mobile phone, iPad, computer, etc.) sends when you use the Services and Site, like a device identifier, user settings and the operating system of your device, as well as information about your use of the Services and Site.
Location Information. When you use our Site, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize the Services for you.
HOW WE USE YOUR PERSONAL DATA
We use personal data in the following ways:
- Information You Give To Us. We will use personal data:
- to provide you with the information and services that you request from us;
- to provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) where you have consented to this, or where we can otherwise lawfully do so.
- to notify you about changes to the Services;
- to ensure that content from Formation Ventures is presented in the most effective manner for you and for your computer.
- Information Automatically Collected. We will use this personal data:
- to administer Formation Ventures and for internal operations, including troubleshooting, site traffic, data analysis, testing, research, statistical and survey purposes;
- to improve Formation Ventures to ensure that content is presented in the most effective manner;
- as part of our efforts to keep Formation Ventures safe and secure;
- to make suggestions and recommendations to you and other users of Formation Ventures about goods or services that may interest you or them.
Our primary goals in collecting personal data is to provide and improve our Services, to administer your use of the Services, and to enable you to enjoy and easily navigate the Services.
We will use your personal data to:
- administer the Services, communicate with you and provide customer support in relation to the Services.
- resolve disputes, collect fees (if any) and troubleshoot problems.
- customize your experience and otherwise measure and improve the Services.
- send you relevant emails and communications (including keeping you informed about our products, offerings and any promotional offers) that might be of interest to you (If we use your personal data to market to you, you will be able to opt-out of such uses).
- enforce our agreements, terms, conditions, and policies, and send you notices and alerts.
Additionally, we may offer you products and services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
Legal bases under the GDPR, UK GDPR, POPIA or LGPD. If you are in the European Economic Area (EEA), the United Kingdom (UK), South Africa or Brazil, we will collect and use your personal data only if we have one or more legal bases for doing so under the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), the South Africa Protection of Personal Information Act (“POPIA”) or the Brazil General Personal Data Protection Law (“LGPD”). The legal basis depends on your interaction with us. This means we collect and use your personal data only where: you have given your consent for one or more specific purposes; it is necessary to perform a contract we are about to enter into or have entered into with you; it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; it is necessary to protect the vital interests of you or another natural person; or it is necessary to comply with a legal obligation. We will indicate the legal basis or bases on which we are relying for each purpose. Where we are relying on consent as the legal basis, we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.
PERSONAL DATA THAT WE SHARE WITH THIRD PARTIES
Information Shared with Authorized Viewers. We may share your information, including your personal data, with individuals that you have explicitly authorized us to share your information with (“Authorized Viewers”).
Information Shared with Our Service Providers. We may engage third-party services providers to work with us to administer and provide the Services (e.g. companies that provide us services such as hosting and maintenance of our Site, data storage and management, etc.). These third-party services providers have access to your personal data only to the extent needed to perform services on our behalf.
Information Shared with Third Parties. From time to time in the course of our business or operations, we may collaborate with other educational partners to collect, analyze and process data relating to our student users. Such collaboration enables us to grow and improve our Services.Generally, any such data is collected in an aggregated and anonymized format, which means that personal data will not be included in any such collected data. Your use of the Site and Services constitutes your consent to the collection and sharing of aggregated, anonymized data with such third parties in the manner described in this paragraph. In the event that any data is shared with third parties in a manner that contains personal data, we will take reasonable efforts to ensure that our users have consented to the collection and sharing of such personal data.
Aggregated Information and Non-identifying Information. We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other non-personally identifiable information, including with users, partners or the press in order to, for example, demonstrate how the Services are used, spot industry trends, or to provide marketing materials for Formation Ventures. Any aggregated information and non-personalized information shared this way will not contain any personal data.
SPECIAL CATEGORIES OF DATA
Formation Ventures does not intentionally collect any “special categories of data” under GDPR, UK GDPR, POPIA, or LGPD, without your explicit consent for one or more specified purposes or as otherwise permitted or required by applicable law. Special categories of data include personal data (a) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or (b) concerning health or data concerning a natural person’s sex life or sexual orientation.
FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”)
Formation Ventures may use education records that have been de-identified for product development, research or other purposes permitted by applicable law (“De-identified Data”), including:
- To demonstrate the effectiveness of the Services, including in our marketing materials; and
- To develop and improve our educational products.
Formation Ventures will not attempt to re-identify the De-identified Data nor will we transfer the De-identified Data to a third-party unless that party agrees not to attempt re-identification.
We offer you choices regarding the collection, use and sharing of your personal data and we’ll respect the choices you make. Please note that if you decide not to provide us with the personal data that we request, you may not be able to access all of the features of the Services.
HOW WE PROTECT, STORE AND TRANSFER YOUR DATA
Formation Ventures uses commercially reasonable information security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. Formation Ventures segregates certain personally identifiable and other information about your use of Formation Ventures’s Services into separate databases, some of which can be accessed only by a limited number of employees.
We restrict access to personal data to authorized Formation Ventures administrators, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Formation Ventures is operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including personal data, will be transferred to the United States. We may also allow service providers located around the world to access personal data as provided in this notice. If your personal data is subject to GDPR, UK GDPR, POPIA, or LGPD we will ensure your legal rights and protections travel with any such “transfer” of your personal data as required by applicable law. We do this by signing “standard contractual clauses” approved by the European Commission that give personal data the same protection it has in the European Union, and/or otherwise requiring that our service providers protect personal data in accordance with applicable law. We will also comply with similar applicable laws regarding the storage and transfer of personal data in other jurisdictions where your personal data may be collected or provided.
Storage Period. We will store your personal data until it is no longer needed to fulfill the purpose(s) for which it was collected or as otherwise required or permitted by law. After such time, we will either delete or anonymize your personal data or we may dispose of any data at our discretion without notice, subject to applicable law. Please contact us at email@example.com if you would like more details regarding our retention periods for different categories of personal data.
LINKS TO OTHER SITES
OUR POLICY TOWARD CHILDREN
The Formation Ventures Site and Services are not intended for use by children under the age of 13 and do not knowingly collect personal data from children under 13 years of age. If you believe that your child or student may have provided us with personal data without parental consent, you may contact us at firstname.lastname@example.org. If we learn that we have collected personal data of a child under 13 we will take steps to delete such information from our files as soon as possible.
Other Rights. To the extent provided by applicable laws (including the GDPR, UK GDPR, POPIA, and LGPD), you also may have the right to deactivate, block, anonymize, or delete personal data as appropriate; request and receive a copy of the personal data you have provided us and to transmit this data to a third party; and lodge a complaint with the applicable data protection authority. To exercise any of these rights that you are not able to do directly, please contact us at email@example.com.
RESPONDING TO DO NOT TRACK SIGNALS
Our Site and Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.