Updated: November 16, 2022

Gladeo Privacy Principles

Gladeo is a mission-driven social enterprise and Public Benefit Corporation that is committed to building a more inclusive, equitable, and prepared workforce. We established Gladeo as a Public Benefit Corporation so that we could prioritize our mission of increasing equity and access to careers for all and your trust over generating profits. Our Privacy Policy is fueled by our commitment to these Privacy Principles:

1. Safety and Security: We’re deeply committed to creating a safe and secure online environment for our users.
2. Notice & Transparency: We give notice to users, educators, and our other stakeholders about how and when information is collected, used, disclosed, and secured in our Privacy Policy. In our Privacy Policy, we provide extensive details on how we collect, use, and disclose users’ information and their right to access, correct, and delete it. During the registration process, we ask users for their name, date of birth, email address, and zip code. We may also ask for gender, race, educational history and plans, career interest so that we can personalize their experience and improve our Service. 
3. Choice and Control: We give users the opportunity to choose and control what personally identifiable information users give us and if and how we share it. Users can decide how much additional information they disclose beyond the information needed to register for the use of our services.
4. Purpose & Trust: We’re committed to our mission of increasing equity and access to good career pathways for everyone. Our Privacy Policy explains why we collect personally identifiable information: to provide better, personalized career navigation guidance and to deliver educational and training opportunities to our users. We only use users’ personal data to improve our ability to serve them and to help them access reputable higher education, training programs, employment opportunities, and valuable services that might help them reach their career goals. We only share users’ personal information with their consent and when we have clearly communicated the purpose of such data sharing. (Third parties cannot share, relicense, sell, or otherwise repurpose the information.) Read our Privacy Policy for further details on why and how we use and protect your information.

 

Overview

Thank you for visiting the Gladeo Privacy Policy, which applies to sites owned and operated by Gladeo, Inc. (“Gladeo,” “We,” “Us”), a mission-driven, social enterprise and for-profit Public Benefit Corporation whose mission is to build a more inclusive, equitable, and prepared workforce of the future. Gladeo understands that you care about how your information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy, which, together with our Terms of Use, describes how we use and protect the personally identifiable information you share with us and that we collect about you when you use (or access) sites owned and operated by Gladeo and all corresponding linked pages. (collectively, our “Site” or “Sites” or “Service”) By use of the Site or Service, you acknowledge that you have read and accept the practices and policies outlined in this Privacy Policy.

 

This Privacy Policy covers Gladeo’s treatment of information that identifies you or could reasonably be used to identify you that we, or our third-party partners, gather when you are accessing our Web Site and when you use our services or products (“Personal Information”), as well as usage information that is anonymized and not associated with you (“Non-Personal Information”). This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

 

At this time, Gladeo is not intended for use by children under 13.

  

Collection of Information

We may collect information in the following ways, depending on your use of our Site and your account settings:

·   We collect information from you directly, such as when you create an account, communicate with us, participate in activities, events or surveys, or otherwise provide information during your use of the Sites.

·   We may collect information from others, such as your parent, teacher, counselor, case manager, or School, or third parties (meaning organizations outside of Gladeo), such as third party applications, Single Sign On (SSO) authentication services, or social media platforms that you use to connect to the Service.

·   We may collect some information automatically, such as information about your use of the Service and the devices you use to access the Site or when you view our online ads. We may use cookies, web beacons, or similar technologies to collect information as explained in the Cookie Policy section of this Privacy Policy.

Further information about how Gladeo collects your information is provided below.

 

Information you directly provide to us

When you create an account, participate in our offers, programs, or Site features, when you submit a testimonial, complete the Gladeo Quiz, or otherwise communicate with us, you may directly provide us with information, including (but not limited to) the following:

·   Identifiers, such as name, email address, phone number and postal address or zip code

·   Username and password for a Gladeo account

·   Professional information, such as job title, work history, educational background, resume, and cover letter

·   Educational information, such as educational background, educational plans, or grades or transcripts

·   Age or birthdate (for compliance purposes)

·   Gender

·   Student financial information

·   Demographic information, such a race or ethnicity

·   Other information you affirmatively allow a third-party service (such as Google or Facebook) to provide to us

 

Information obtained from a school, other users, or educational or workforce institutions

If you choose to provide information to educational institutions, workforce organizations, or other development organizations that Gladeo partners with, we may receive Personal Information about you that you have made available to the partners. For example, the work history or profile information that you have chosen to share with the strategic partners may be shared with Gladeo to allow you to register for programs or classes. We also make available certain features on our Service that allow other users to provide us information about you. For example, a school, teacher or counselor may provide information relating to participants in a class or program, or a case manager from a workforce center may provide information relating to a client’s account. If we associate information from other sources with personal information that we collect through our Service, we will treat the combined information as personal information in accordance with this Privacy Policy.

 

Information from Single Sign On (SSO) authentication services

If you decide to register for an account (or access your account) through an authentication service (such as Google Accounts or Facebook as a Single Sign On, also known as a SSO) (“Authentication Service”), we may collect information from these third-party services, consistent with your privacy settings in your account with the relevant Authentication Service.

 

Social Media Sharing

You may choose to directly share a link to the content you are viewing on Gladeo by clicking on a third party application icon (such as choosing to share a link via your social media account like Twitter or Facebook). It is your choice whether to log-in to your social media account, so that you can post a direct link to the content you are viewing. Use of social media sharing is optional.

 

Information we collect to enable your participation in special features or programs.

Gladeo may have a special program, feature, or activity we offer in partnership with a third party. If you wish to participate in these special features or programs, Gladeo may collect information from you to facilitate those programs. For example, Foothill College students may be asked to provide information that facilitates their participation in special features on the Site that Foothill College wants to make available to their students (such as a student ID number, what program they’re enrolled in, and their expected graduation date).

 

Information we collect automatically from your device when you visit our Sites or when you view our online ads

When you visit or use our Sites, when you view our online ads elsewhere , or when you open our emails, we may use cookies or other technologies (including pixels, tags, and web beacons) to automatically collect information about your computer or device, and your internet or other electronic network activity.  The following are examples of the types of information we may collect in this way:

·   Device type (such as desktop, tablet, or mobile device)

·   Browser type (such as Internet Explorer)

·   Operating system (such as Windows)

·   IP address, device ID, or similar information

·   Geolocation information: We may collect and use information about your location (such as your zip code) or infer your approximate location based on your IP address in order to provide you with tailored career navigational experiences for your region, but we don’t collect the precise geolocation of you or your device. You may be able to change the settings on your computer or mobile device to prevent it from providing us with any location information.

·   Websites or online services you visit before or after our Site

·   Your interaction with our Site: We may collect usage information about your use of our Service, such as the number of career profiles you have read, the number of videos you have viewed, the search terms you submitted, if you’ve completed the Gladeo Quiz, which careers and industries you have followed. This enables us to better tailor explorational experiences that are most appropriate for you.

·   Whether you open or forward our emails or click on elements within these emails

Please note that parts or all of the information we collect or obtain may be combined or linked (by us or by third parties providing services to us) for any of the purposes described in this Privacy Policy, including to help us customize how we communicate with you and to improve our educational and career navigational products, services, and outreach efforts.

 

Use of Information

We use the information we collect (in combination with other information we or third-party service providers may have) to operate our business, to communicate with you regarding our products, services, recommendations, and promotions, to provide you with other information, services, products, job listings, education and training program information, or other materials you request, to customize your interactive experience and/or to manage and improve our Sites, products, and service offerings.

 

Some specific examples of how we may use this information are as follows:

·   To create and manage your account as a user or member of our Site (or as someone who may post content to our Site)

·   To provide you the Service or access to the Site

·   To personalize your experience. We use your information to personalize your experience while using the Site. For instance, Gladeo remembers your quiz results and the careers you’ve followed so we can recommend the most appropriate content for you on your next visit and provide personalized career navigation experiences.

·   To communicate with you about your account and respond to inquiries. We may also use your information to provide you with information about Gladeo’s features, services, and other offerings that may be of interest to you.

·   To enable your participation in special programs and features. We use your information to enable your participation in programs or features we may offer in partnership with third parties, to the extent you decide to participate in such special programs and features.

·   To understand, improve and develop our Service. Gladeo uses information to understand and analyze the usage trends, learning behaviors, and preferences of our users, to improve the way the Service works and looks, and to create new features and functionality.

·   To develop new products, features, services, and sites. We may use information to maintain, develop, support, and improve our Service and other career development and educational products and services, and for career development and educational research.

·   To send you alerts on opportunities and other content that you’ve requested: If you choose to opt-in to receiving text or email notifications on relevant updates, work-based learning, job opportunities, or other materials you request, to register you to receive email or text notifications, if and only if you choose to participate in this special feature. You may opt-out of receiving these notifications at any time.

·   For legal, compliance, or safety reasons. We may use or share information to comply with applicable laws, rules, or regulations, and our Terms of Use, including protecting the safety and rights of Gladeo, users, and the general public. We may also use your information to detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; and to prosecute those responsible for that activity

·   To verify your identity in connection with responding to certain requests you may make pursuant to this Privacy Policy

 

Sharing and Disclosure of Information

Gladeo takes great care to protect the personal information you provide to us. We do not sell your personal information to third parties. This section explains circumstances in which we may share personal information with third parties. We may share personal information:

 

·   With other users of our Service that are associated with your account, such as a parent, counselor, case manager, or coach, if you use features that enable you to share your information with (or make it accessible to) others.

·   With your school or college, if you are using our Service for school purposes and decide to associate your account with your school by either entering a school code, created a Gladeo account through your school’s Gladeo subdomain (for example, foothill.gladeo.org), or through a direct personal invitation link.

·   With vendors, consultants, and other service providers working on our behalf.

·   With your consent (including third party applications that you choose to use, such as complementary services or an Authentication Service). If you choose to use a third-party application or service, the use of your information by the third party will be governed by that party’s privacy policy. We may share information with educational institutions, workforce organizations, or other strategic partners with your consent and if you request to receive information from them. These organizations must sign a strict data transfer agreement that outlines how personal information can be used. Below is an example of how we share your information:

 

Information you share on a “Learn More” or “Sign Up for Info” form on our Program Finder. Our Learn More or Sign Up for Info forms are free, optional forms that are made available to users on Gladeo’s Program Finder to help make it easier for learners to connect to and reach out to multiple qualified colleges, bootcamps, training programs, online course providers, scholarship organizations, nonprofits, and other educational and training service providers, they might be interested in applying to or enrolling in, without having to navigate to a bunch of different websites. If you choose to fill out and submit a Learn More or Sign Up for Info form and fill out your personal information and questionnaire, we will ask for your permission to share the information that you’ve provided us with the qualified school or organization that you have indicated interest in, making it clear that you agree to receive communications from these third party organizations. You may receive communications from these schools by email or whichever form of personal contact information that you provided on the form. The frequency and mode of communication are determined by each organization, and every communication they send is required to contain instructions for unsubscribing. Gladeo does not disclose your personally identifiable information to third parties, including colleges or other training providers, without giving you notice and getting your consent.

 

·   With third parties who deploy cookies and similar technologies. As described in detail below (under the "Cookie Policy" section of this Privacy Policy), third parties use a variety of cookies and similar technologies (referred to collectively below as “cookies” for simplicity) to collect information on our Sites for the purposes described in the Cookie Policy, including providing analytics services to us and providing advertising on our Sites and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called "online behavioral advertising"). The presence of third-party cookies used for online behavioral advertising may be considered a "sale" of personal information to those third parties for purposes of certain state laws. Except to the extent that third-party advertising cookies are considered a "sale" of personal information, we otherwise do not share your information in ways that would be a sale of personal information to third parties.  You can change your cookie preferences at any time by changing the settings in your web browser to disable or block cookies on your device.

·   We may share information in the context of a change of business, including a merger or acquisition. In the event that Gladeo is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of our assets, your information may be transferred or disclosed in connection with such business transaction. If the transaction involves the transfer of Personal Data to a third party, we will require the new owner to continue to honor the terms provided in this Privacy Policy, or we will provide users with notice and an opportunity to opt-out of the transfer of Personal Data by deleting Personal Data before the transfer occurs.

·   With not-for-profit organizations. We may share de-identified aggregated data and impact metrics with not-for-profit organizations. In certain circumstances, Gladeo may share de-identified or aggregated information that does not reasonably identify you as an individual for various purposes. For example, we may share de-identified information with partners including workforce development agencies or educational organizations to improve our Service or offerings or to conduct educational or labor market research. If we disclose information to third parties for research or product development purposes, such information will be aggregated and/or de-identified to reasonably avoid identification of specific individuals.

·   Other instances. Gladeo may share or disclose information - including information that personally identifies you -  if we have a good faith belief that doing so is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Use, including investigation of potential violations thereof; (c) investigate or defend ourselves against any third-party claims or allegations; (d) detect, prevent or otherwise address fraud, security or technical issues; (e) protect the rights, property, or personal safety of Gladeo, our users, or the public; or (f) as otherwise required or permitted by law.

 

Sponsorship, Links to Third Parties, and Other

As a public benefit corporation, Gladeo relies on our sponsors, workforce partners, education providers, advertisers, and other contributors to provide revenue and funding necessary to provide the Service free to students and career seekers. From time to time, we may also permit third parties to sponsor content displayed on our Service.

• For example, for-profit organizations, such as an employer like Google, may wish to sponsor all content related to a particular industry, such as Internet or Technology. Or, a nonprofit organization like 2-Year Public Community College, Foothill College, may want to sponsor career videos of their alumni who work as veterinary technicians or dental hygienists.
• Sponsored content will always be labeled (e.g., “Sponsored by __” or “Brought to you by __” or “Produced in partnership with __”)
• Gladeo does not share any of your personal information with these sponsors without your consent. We do not provide these sponsors with the ability to track or collect information about our site visitors or users.

 

Third parties may provide content, advertising, or functionality on our site

Some of the content, advertising, and functionality on our Site may be provided by third parties that are not affiliated with us. For example:

·   Employers (like Northrup Grumman) or recruitment agencies (like Triplebyte, a skills-based recruitment organiation for technology jobs) may market jobs, internships, or other similar opportunities on our Site. They may also share related content on the Site such as a Virtual Company Tour or an employee video that helps to market their employment offerings and employer branding.

·   Advertisers that provide related products and services may, from time to time, provide content, promotional discounts, advertising, or functionality on our site. For instance, Adobe may advertise a special promotional offer for its Creative Suite software subscription on related pages such as the Graphic Designer career page or the UX Designer career page.

·   Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them. These third parties may use cookies and similar technologies to provide these services.

·   We may enable you to share certain materials on the Site with others through social media platforms such as Facebook and Twitter, and those platforms may provide tools for doing so on our Site.

These third parties may collect or receive certain information about your use of the Site, including by using cookies and other technologies, and this information may be collected over time and combined with information collected across different websites and online services.

For example, one of the third parties that provides services on our Site is Google Inc. Like many websites, we use Google Analytics, a service that provides information about how many users visit our Site, when they visit, and how they navigate the Site once they are here. Google offers a browser add-on that enables users to opt-out of having data about their visits reported to websites by Google Analytics. More information about the Google Analytics add-on is here.

We also may use other Google Analytics tools, such as Demographics and Interest Reporting, which enables us to learn more about the characteristics and interests of the users who visit our Site, and Remarketing with Google Analytics, which enables us to provide relevant advertising on different websites and online services. You can opt out of having your data used for these additional Google Analytics tools by visiting this page and opting out of ads provided by Google.

 

Links to other sites

Gladeo may, from time to time, incorporate content and links to content provided by third parties that may be of interest to you and relevant to the career development and educational context of our Service. If we include links to third parties and you click on that link, you will be leaving Gladeo and the privacy policy of that third party applies. Alternatively, the Service may be linked by websites operated by other entities or individuals. We are not responsible for the privacy practices, security protections, or the content of sites owned and operated by third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each site you visit.

 

User-generated content and public profile features

Our Site may, from time to time, contain interactive areas where Site users might submit comments or other content (including information about the user that might be displayed in the user's public profile within an online community) that may be visible to others. Users should be aware that when they voluntarily disclose personal identifiers (e.g., name, email address, etc.) or other personal information in content submitted for posting or publication, the information can be read and used by others. This may result in unsolicited messages from other posters or parties. We make no representations and undertake no obligations as to the security or use of information you voluntarily include when submitting content.

 

Do-not-track

Some web browsers may transmit "do-not-track" signals to the websites and other online services with which a user communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. As a result, like many websites and online services,  Gladeo currently does not take action in response to these signals. If and when a standard is established and accepted, Gladeo may revisit its policy on responding to these signals.

 

Children's privacy

This Site is intended for adults and young adults. This Site is not directed to children and we will not knowingly request any Personal Information from children under 13 at this Site. If you are a parent or legal guardian and think your child under 13 has given us Personal information, please send your request to privacy@gladeo.org. Please mark your inquiries “COPPA Information Request.

 

United States only

This Site is intended for use by residents of the United States of America only. All matters relating to this Site are governed by the laws of the United States. If you are located outside of the United States and you contact us, please be advised that any information you provide to us will be transferred to the United States and processed in the United States.  By submitting information, you explicitly authorize this transfer and the processing of your information within the United States.

 

Transparency and Your Choices

We take your privacy very seriously. We strive to put you in control of the choices and decisions regarding your personal information. We understand that your personal information is important to you, and that is why you have choices in how your personal information is used and shared. We want you to have access to your personal information, so that you can help keep it as accurate as possible.

For example, you can choose whether to create an account (or use the Service without registering). If you register for an account, you can:

• Limit optional information you provide
• Choose whether you wish to share personal information with (and use) third party services
• Choose whether to add a counselor or mentor to your account
• Choose whether you wish to receive optional email
• Update, correct, and delete your account information through your account settings

 

You may use the Service without creating an account

You can access many of our online resources without providing personal information. If you do not create an account, however, Gladeo will not be able to provide you with certain features and functionalities found on our Service. You can still view content, but you will not have full account features (such as taking the Gladeo Quiz and accessing your quiz results, keeping track of your interested careers and industries, receiving a personalized newsfeed of recommended resources and opportunities). You may later enable or access those features by providing Gladeo with the necessary information to create an account.

 

You may limit the personal information you provide

You can choose to provide information which does not reasonably identify you to others. You can also decline to provide any optional information in your profile or answer any questionnaire questions.

 

Your control over your information

You always have the right to review and update the information that you previously provided to us at this Site. You may contact us as described in the "How to contact us and how to exercise your privacy rights" section below in order to arrange this.

 

You can opt out of receiving our communication emails

You have choices related to email and mail. If you do not want to receive email or other mail from us, please send your request to privacy@gladeo.org or follow the “unsubscribe” instructions in any email you get from us. Even if you opt out of getting communication messages, we may still send you transactional messages (such as responses to your requests and questions or updates about this Privacy Policy or the Terms of Use).

 

You can terminate your account

To request deletion of your information at any time, please log into your account and select “delete your account“ through your Personal Account Settings or by sending an e-mail to privacy@gladeo.org. Please note that your information will be retained in backup for up to one week. We may not be able to delete information in all instances. For example, we may retain certain information as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. Retained personal information will remain subject to the terms of this Privacy Policy. Unless we receive a deletion request, we will retain your information for as long as your account is active or as is reasonably useful for operational purposes. We may also retain information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual.

 

You can control certain cookies and tracking tools 

You have choices related to cookies and tracking tools. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. To control flash cookies, which we may use on certain sites from time to time, you can go here.  Why?  Because flash cookies cannot be controlled through your browser settings. If you block or reject cookies, certain features on the Website may not work. To opt out of having your online behavior collected for behavioral advertising purposes, click here. Certain choices you make may be browser-specific and/or device-specific.  If you block or reject cookies, not all of the tracking described here will stop.

 

California Residents

For purposes of California residents exercising the rights under the California Privacy Protection Act, please note the following regarding how we collect, use, and share your Personal Information as described in this Privacy Policy, including in the previous 12 months:

• We collect and use the following categories of Personal Information as set forth in applicable California law: identifiers; characteristics of protected classifications under California or federal law (such as demographic information like age and gender); commercial information; professional or employment information; internet or other electronic network activity information; geolocation data; and inferences.
• We collect these categories of Personal Information from the categories of sources described in the “Collection of Information” section above.
• We collect and use each of these categories of Personal Information for the business and commercial purposes described in “Use of Information” section above.
• We may disclose each of these categories of Personal Information for our business and commercial purposes as described in this Privacy Policy, to the extent permitted by applicable law, to the categories of third parties described in “Sharing and Disclosure of Information” section above.  

 

Changes to this Privacy Policy

Gladeo may modify or revise this Privacy Policy at our sole discretion from time to time. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. Gladeo will notify users of any changes to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Service. We recommend that you review the Privacy Policy each time you visit the Service to stay informed of our privacy practices. We will not make any material changes to our Privacy Policy that relate to the collection or use of Personal Data without first giving notice to the user and providing a choice before Personal Data are used in a materially different manner than was disclosed when the information was collected. Unless stated otherwise, our current Privacy Policy applies to all information collected by or through any Site that displays an authorized link to this Privacy Policy.

 

How to Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at privacy@gladeo.org.

If you would like to exercise any legal rights you may have to access, delete, or otherwise address your personal information, please contact us. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an agent to exercise your rights and that is authorized by the relevant laws, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will not discriminate against you for exercising these rights or choices, although some of the functionality and features available on the Sites may change or no longer be available to you. Any difference in the Sites will be related to the value of the information that is no longer available to us or usable by us.

 

Access – You can request that we disclose to you the categories of personal information (as defined under applicable law) that we have collected about you, the categories of sources from which we collected the personal information, the categories of personal information we shared or disclosed, our business or commercial purpose for collecting and sharing your personal information, the categories of third parties with whom we shared your personal information, and the specific pieces of personal information we collected about you over the past 12 months.

 

Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.

 

Regional Information

This Regional information notice supplements our Privacy Policy. In certain regions, you may have certain additional rights. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict Gladeo using it for certain purposes.

If you wish to exercise a right, please contact Gladeo at privacy@gladeo.org. Our ability to respond to specific requests may be limited by applicable law and the functionality of our Service