Privacy Policy

Last updated: 22 February 2024

Overview

Re:Coded Co. (“Re:Coded”, “our”, “us”, or “we”) is a US-based charitable nonprofit organization. As a 501(c)(3) nonprofit, we use the information we collect to provide you with a better experience and fulfill our mission of preparing talent from underserved backgrounds to start lifelong careers in the digital economy. We established ourselves as a nonprofit organization so that a for-profit motive will not interfere with our mission.

We are committed to protecting your privacy. Re:Coded is the controller of your personal data which is collected in accordance with this Policy. This Privacy Policy explains how information is collected, used, processed, disclosed, transferred, and protected by Re:Coded when you use (or access) our website at www.re-coded.com and other services (collectively, our “Service”).

If you have any questions about this Policy or wish to exercise any of your rights related to your personal information, please contact us by emailing privacy@re-coded.com.

Data Privacy Principles

Our Privacy Policy is rooted in our commitment to the following principles:

1. We’re deeply committed to creating a safe and secure online environment for you.
2. We do not sell your personal information to third parties. We established Re:Coded as a nonprofit organization so that our mission of education and your trust will not be in conflict with a for-profit motive.
3. We strive to provide you with access to and control over the information you give us, and we take the protection of your information very seriously.
4. We only keep your personal information for such time as is necessary for the purpose of our work and mission
5. We will always use you personal information in a lawful, fair, and transparent way.

Collection of Information

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

• 1. We collect information from you directly, such as when you create an account, communicate with us, participate in events or surveys, or otherwise provide information during your use of the Service.
• 2. We collect some information automatically, such as information about your use of the Service and the devices you use to access the Service. We may use cookies, web beacons, and similar technologies to collect information as explained in Navigational Information.

Examples of information we may collect includes:

• a. Contact Information and other Identifiers, including your name, mailing address, phone number, email address, emergency contact information, and other information that enables us to contact you;
• b. Verification Information, including date of birth and educational background;
• c. Demographic Information, including your gender, age, residency status, and education level;
• d. Account Information, including your username and password;
• e. Professional Information, including your company name, title, role, team, and other information about your profession;
• f. Program Information, including student records, student performance information, student projects and work, information regarding your job search, job search parameters, interview contacts, and other information about your use of the Services;
• g. Communications, and any other information that you share, send, or provide using the Services, including your e-mail, SMS, Slack;
• h. Device and Navigational Information, including information about your computer or device and Internet or other electronic network activity information.
• i. Non-Personal Information which may be linked to your personal information, including Information about your use of our Service

Navigational Information

In addition to information that you choose to submit to us, Re:Coded and/or our service providers may automatically collect and/or store certain information (“Navigational Information”) when you visit or interact with our websites, landing pages, and other web-portals (the “Site”). This Navigational Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. While the Navigational Information collected automatically may not include Personal Information, we may maintain it or associate it with Personal Information we collect from you in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized experience, including by enabling us to: Estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our Services according to your individual interests, speed up your searches, recognize you when you return to our Website.

Navigational Information may include: your IP address, MAC address, or other unique identifier (“Device Identifier”); your Device browser, operating system and mobile network information; the areas within our Site that you visit and your activities there, including remembering you and your preferences; your general location; and certain other Device data, including the time of day you visit our Site, among other information.

We may use various methods and technologies to collect and/or store Navigational Information, such as cookies, web beacons, and other similar technologies

Use of Information

How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to provide our services, personalize your experience and communicate with you about your account and our Service (including responding to inquiries and sharing information about new features and offerings that may be of interest), understanding and improving our Service, and developing new or improved educational offerings. It is also used to protect against fraud, abuse, or harm and otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);

We may also use non-personal data elements (such as de-identified, anonymized or aggregated usage information and feedback) for product development, research, analytics and other purposes, including for the purpose of analyzing, improving or marketing our Service, for demonstrating the impact of our Service, or conducting educational research.

Applicants. If you are an applicant, the Personal Information we use includes: Contact Information, Verification Information, Demographic Information, Account Information, and Professional Information so that we may identify you and contact you, including about your application, to respond to inquiries or troubleshooting requests and to deliver notifications and other operational communications, and review your application;

Contact Information, Account Information, and Verification Information to protect against fraud, abuse, or harm, verify your identity, and otherwise provide a Secure Environment (generally to meet our legal obligations or our legitimate interests);

• Other Personal Information and Communications to provide you with the Services, including, but not limited to (i) assessing your application, including your preferred class dates, your availability, why you want to learn with us, what you hope to do upon completion of the program, and how you heard about us; (ii) connecting you with the community, social media channels, apps, and websites; and (iii) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services.

Students. If you are a student, the Personal Information we use includes:

• Contact Information and Professional Information so that we may identify you and contact you, including to respond to inquiries or troubleshooting requests and to deliver notifications and other operational communications, enroll you in our Services, or provide you with a digital access badge;
• Contact Information, Professional Information, Account Information, Program Information, and other academic information, such as your progress and performance in programs and courses, your engagement with the Services, your portfolio, and any disciplinary data; to provide you with the Services, tailor Services to you, and connect you with the community;
• Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity, and otherwise provide a Secure Environment (generally to meet our legal obligations or to meet our legitimate interests); and
• Other Personal Information and Communications to provide you with the Services, including, but not limited to (i) providing you with relevant courses and other training programs; (ii) connecting you with the community, social media channels, apps, and websites; (iii) providing Services that you request; (iv) connecting you with prospective employers and other relevant opportunities, and (v) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services.

Sharing of Personal Information

Re:Coded 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 disclose personal information with third parties.

We may disclose personal information with other users of our Service, if you use features that enable you to share your information with (or make it accessible to) others with consultants and other service providers working on our behalf to advance our mission. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.

We may also disclose personal information with other users that are associated with your account, such as Re:Coded employees and contractors.

• As part of our Services, we may connect you with prospective employers or employment opportunities. Typically, the information we share about you would consist of your resume, LinkedIn profile, and GitHub profile. You may elect to opt-out of your information being shared with employer partners.
• Personal information may also be shared with others for compliance purposes, such as when reasonably necessary to protect the security and safety of our users or Service, or when permitted by law with your consent for other purposes not specified above.

We may also disclose de-identified or aggregated information that does not reasonably identify any individual.

Data Security Measures

We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. From time to time we implement and update administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. We limit access to your data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures to deal with suspected data security breaches. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

In addition to these measures, we encourage you to protect your personal information by creating a username that does not reveal your identity, creating (and keeping) a strong password, being thoughtful about what you post and continuing to learn about online safety.

Retention

We will retain your data for as long as necessary to provide our services to you and fulfill transactions you have requested, or for other purposes such as collecting longitudinal data about our community’s career progress. Because these needs can vary for different data types in the context of different products or services, actual retention periods can vary significantly. If you wish us to delete your data at any time, please email us at privacy@re-coded.com.

International Data Transfer

In order to provide the Services, we may transfer your data outside your country to countries which provide adequate level of data protection, or where Re:Coded has put in place appropriate safeguards to seek to preserve the privacy of your information. Those countries include the United States.

European Economic Area and United Kingdom

This Policy abides by the rules of the GDPR, including the rights of Data Subjects. The General Data Protection Regulation (GDPR) imposes obligations onto organizations anywhere, so long as they target or collect data related to people in the EU. The GDPR applies to us in instances where we offer goods or services to EU citizens and residents inside the EU (“Data Subjects”).

The provisions of the EU GDPR have been incorporated directly into the law of the United Kingdom as the UK GDPR and the Data Protection Act 2018. The UK GDPR is the UK General Data Protection Regulation which sets out the key principles, rights and obligations for most processing of personal data in the UK, except for law enforcement and intelligence agencies.

In some cases, the parties who we use to process personal data on our behalf are based outside the EEA and/or the UK, therefore their processing of your personal data will involve a transfer of such data outside the EEA and/or the UK.

Whenever we transfer your personal data out of the EEA and/or the UK, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (in the case of transfers out of the EEA) or the UK Government (in the case of transfers out of the UK).

Donor Information

This Donor information notice supplements our Privacy Policy in connection with donors. If you donate to Re:Coded and do not donate anonymously, we obtain information such as your name, email address, and mailing address. If you donate using our online form, our payment processor will also collect your credit or debit card number or other payment information. Please note that information collected by these payment processors is subject to their own privacy policy.

We may use donor information to communicate with you about your contribution and to send fundraising updates and information regarding the advancement of our mission.

We do not disclose personally identifiable donor information except with your consent or as required by law.

Changes to this Policy

We reserve the right to modify this Policy at any time by this provision. If we make changes to this Policy, we will post the revised Policy on the Re:Coded website and update the “Last Updated” date at the top of this Policy. By continuing to use our website or providing us with personal data after we have posted an updated Policy, or notified you by other means if applicable, you agree that you will be deemed to have agreed to be bound by the replacement policy.

Your Rights

Under applicable data protection laws, you have the following rights

• Access and obtain a copy of your data on request (known as a “data subject access request”);
• Require us to change incorrect or incomplete data;
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing;
• Object to the processing of your data where we are relying on its legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
• Ask us to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it; and
• Request the transfer of your personal data to another party.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

If you would like to exercise any of these rights, or you have any questions about this Policy, please contact us at privacy@re-coded.com.

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