GENERAL

Your clear affirmative action of accepting this privacy notice forms the basis of our processing your personal information to provide you services. This Global Privacy Policy (together with our Terms and any other documents referred to in it) as well as our regional Privacy Policy based on your jurisdiction describes the manner in which your personal information may be processed.

Our Platform and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices. Please read this document carefully to understand our policies regarding your information and how we will treat it. This Privacy Policy may change from time to time and your continued use of the Platform, or the Services, is deemed to be acceptance of such changes, so please check periodically for updates.

INFORMATION WE COLLECT

We collect information from you directly, from the devices you use to interact with us, and from other parties. We may combine information from the Services together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion. You may be able to utilize the some of the Services without identifying yourself; however, if you would like to utilize or customize some features of the Services, you must first register on the Platform.
For illustration purposes, the information we collect includes (but may not be restricted to) the following categories of information:
a. Identity Data includes first name, last name, username, or similar identifier. When you use our Services, we may collect information such as your first name, last name, username, or similar identifier. We may also ask for your date of birth to authenticate your identity. b. Contact Data includes invoicing address, email address and telephone numbers, as well as contact information pertaining to Institutions and employers. c. Financial Data includes bank account and payment card details. We use a third party payment provider to collect financial data and all credit card information for all transactions that go through the Platform. It follows secure encrypted processes a standard for the e-commerce industry. d. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website. e. Account Data includes your username and password, your interests, preferences, feedback, interactions with other Users, and survey responses. Account Data also includes data relating to qualifications, work experience, past employment history, current employment history, etc. f. Usage Data includes information about how you use the Platform and Services. g. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. h. Employment Data includes information relating to employment opportunities, and applications thereto. i. Cookies, Log Files, and other digital tracking technologies are used to collect the following information from the device you use to interact with our Services: • Device information, including IP address, device identifiers, details about your web browser, your imprecise geographical location data (e.g., location derived from an IP address or data that indicates a city or postal code level), and with you permission, your precise geographical location data, including GPS coordinates (e.g. latitude and/or longitude), or similar information regarding the location of your mobile device. • Analytical information, including details about your interaction with our website, app, and electronic newsletters. • Diagnostic information, including web traffic logs • Advertising information, including special advertising and other unique identifiers that enable us or other parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit other-party websites or use other-party apps. They may use that information to better target advertisements to you on our behalf. j. Institutions, Admins, and Third Parties – Information we receive from other sources. We receive information about Users from Institutions, Admin Users, or if you use any of the other websites we operate or through the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Platform. We work closely with third parties (including, for example, sub-contractors, advertising networks, analytics providers, search information providers, software suppliers) and may receive information about you from them. k. Third Parties / Partners We and partners working on our behalf gather information about all Users collectively, such as what areas users visit most frequently and what services users access most often. We and partners working on our behalf may use. As part of this process, we may incorporate tracking technologies into our own Services (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”). We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Services, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use If you use our Platform as a Student or as an Alumni you will be asked to provide information, including personal information, regarding you (such as name, email address, address, qualifications, previous employer(s) information, profession, prior experience). If you use our Platform as an Employer you will be asked to provide information, including personal information, regarding you (such as name, email address, address, phone number, company name, company URL, company email address). If you use our Platform as an Admin you will be asked to provide information, including personal information, regarding you (such as name, email address, address, phone number, Institution details such as name, URL, email address, etc.). We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law as this data cannot be used to identify you.

GENERAL

We use cookies, pixel tags, web beacons, mobile device IDs and similar files or technologies to collect and store certain information that we automatically collect about your computer, device, and service usage.
Cookies are small pieces of information saved by the browsers. You can set your browser to notify you whenever a cookie is sent to you, giving you the option to decide whether or not to accept it. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
Our Platform may use cookies to serve you customized contents for your return visits to our Platform. Cookies also help us in authentication, enhancement of security, display targeted information and most importantly, help us improve your experience on the Platform.
When you visit our Platform, we may place a number of cookies in your browser. These are known as First Party Cookies and are required to enable to hold session information as you navigate from page to page within the Platform. For example, we use cookies on our Platform to understand visitor and user preferences, improve their experience, and track and analyse usage, navigational and other statistical information. Additionally, cookies allow us to bring you advertising both on and off the Platform and bring customized features to you. You can control the use of cookies at the individual browser level. If you elect not to activate the cookie or to later disable cookies, you may still visit our Platform, but your ability to use some features or areas of the Platform may be limited. Pixels (also known as web beacons), are code embedded in a website, video, email, or advertisement that send information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Services, and provide you with additional functionality.
App Technologies are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising off the Services, and provide you with additional functionality. Location-Identifying Technologies are technologies used to collect your location. For example, GPS, Wi-Fi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
Voice Processing Technologies are technologies used to collect audio through the microphone on your device to effectuate an instruction or request by you. We only maintain audio long enough to complete your instruction or request and then immediately delete it. We may use non-audio data associated with the collection for additional purposes such as data analytics and in accordance with this privacy policy.

PROCESSING YOUR PERSONAL DATA

We may use your Personal Information to make available Services, to interact with you on social media, to send you information about our Company, our Services, or to contact you when necessary in furtherance of a service request, enquiry, or other activity related to your use of the Platform. We may use your geolocation to provide services to you. We may use your data to customize and tailor your experience on the Platform, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. Without limitation to the foregoing, your information may be processed: (i) To develop, enhance, market, sell or provide our products or services, or those of companies with which we have a commercial relationship; (ii) To communicate information pertaining to Services; (iii) To issue invoices, administer accounts, collect, and process payments; (iv) To provide tips or guidance on how to use Platform, the facilities we offer, inform you of new features, or provide other information that may be of interest to you; (v) To personalize the service we provide to you, tailor your experience to your requirements and make more appropriate recommendations; (vi) To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services; (vii) To collect feedback on the Platform, the Users, or the Services; (viii) To process and track your transactions and to send you information about us, our affiliates’, service providers’ and business partners’ products and services and other information and materials that may be of interest to you; (ix) To audit compliance with our policies, contractual, and statutory obligations; (x) To prevent fraudulent transactions on the platform; (xi) To analyse software usage patterns for improving product design and utility; (xii) To analyse anonymized practice information for commercial use; and (xiii) As permitted by, and to comply with, any legal or regulatory requirements or provisions; or for any other purpose to which you consent.

DISCLOSURE OF INFORMATION

Except as described in this Policy, we will not, without your consent, disclose information about you. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances: 1. Any information that you voluntarily choose to include in a publicly accessible area of the Platform will be available to anyone who has access to that content, including other Users. Should a User opt to make their profile public, it will become accessible to all Employers on the College.dev platform and to other Users who have selected the same Institution. Please note private profiles may still be visible to the Admin Accounts related to your Institution. 2. We will disclose information about you to other Users, Institutions, and other third parties to assist you with Services. 3. We may work with third-party service providers to provide various services. These third-party service providers may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. 4. We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.


We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) enforce our policies, to protect ours or others’ rights, property, or safety; (iv) investigate and defend ourselves against any third-party claims or allegations; (v) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.


Affiliates – we share information with other members of our group of companies. Information about users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service. We do not allow our third-party service providers to use your personal data for their own purposes (unless you give them permission to do this yourself) and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Google reCAPTCHA v2: We use Google's reCAPTCHA v2 to fight spam and abuse. Your use of reCAPTCHA v2 is subject to Google's Privacy Policy and Terms of Use. Google's Privacy Policy and Terms of Use are available at https://policies.google.com/privacy and https://policies.google.com/terms.
Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.

DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. For example, we take physical and electronic process-specific security measures, including firewalls, personal passwords, and encryption and authentication technologies. Such measures include, but are not limited to, secure sockets layer encryption, routine security audits and scans, routine updating and patching of all servers, services, and applications, as well as usage of code intended to block attacks.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as required by applicable law.

DATA RETENTION

College.dev retains user data for as long as necessary for the purposes described below, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below.

For example, we retain data: 1. for the life of users’ accounts if such data is necessary to provide our services. E.g., account data. 2. for 'fill' years if necessary to comply with legal requirements. 3. for defined periods as necessary for purposes of safety or fraud prevention. Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account.

YOUR RIGHTS

Electronic Mailings Unsubscribe: If you do not wish to receive electronic mailings from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications. Ad Choices: You have options to limit the information that we and our partners collect for online advertising purposes.
a. You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our online properties.
b. The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
c. You may contact us directly.
If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you. Please note, if you delete your cookies, you may also delete your opt-out preferences. App and Location Technologies: You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings. Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly.
Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Analytics and Interest-Based Advertising: Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact information” section below and specify that you wish to opt out of matched ads. We will request that the applicable party not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable party to opt out. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs. Push Notifications: If you have opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

INFORMATION COLLECTED FROM JOB APPLICANTS

When you apply for a job with us, we may collect information from you through the new employee hiring process by our affiliates in accordance with law, including:
a. Information you provide in connection with your application. b. Information that you make available in your social media accounts. c. Information about you that is available publicly. d. Information that you authorize us to collect via other parties, including former employers or references.

In general, we may ask you to provide us with the following types of information about you: a. Contact Information such as name, email address, mailing address, phone numbers. b. Month, day, and year of birth. c. School name. d. Gender. e. Qualifications. f. Prior experience. g. Information included in resumes and job applications. h. Video and audio clips containing your video and audio answers to interview questions. We use this information to provide the online interview services and to consider you as a candidate for an open position or future positions.

STUDENT DATA COLLECTED FROM ADMINS AND INSTITUTIONS

In general, we ask Admins and/or Institutions to provide us with the following types of information about students:
1. Student’s contact Information such as name, email address, mailing address, phone numbers; 2. Student’s age; 3. Month, day, and year of birth; 4. Student’s gender; 5. Student’s current degree, diploma, or license details; and 6. Information included in resumes and job applications.

STUDENT DATA COLLECTED THROUGH SCHOOLS AND OTHER EDUCATIONAL INSTITUTIONS.

College.dev provides Services to Institutions. Through the provision of these Services, College.dev collects personal information from or about students (“Student Data”) at the direction of and on behalf of the Institution with which the student is affiliated. We consider such Student Data to be strictly confidential and in general do not use such data for any purpose other than improving and providing our Services to the Institution or on the Institution’s behalf. Our collection, use, and sharing of Student Data is governed by our contracts with the institutions and state, federal, and international laws as applicable, but not by the provisions contained in this privacy policy. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your Institution directly.

STUDENT DATA COLLECTED THROUGH CLASSES AND EVENTS

If the Student participates in the college.dev™ , YoungWonks or ProWonks Program’s online classes or other online events, we may use our own screen sharing product called YoungWonks Cast which utilizes the service provided by RaiseHand Inc. The privacy policy (located at: https://www.raisehand.com/privacy) will apply to the use of the RaiseHand service. We may use third party online conference services, called GoToMeeting and Zoom. GoToMeeting privacy policy (located at: https://www.logmeininc.com/legal/privacy) will apply to the use of GoToMeeting service, and we have no control over their terms or privacy practices. Zoom privacy policy (located at: https://zoom.us/privacy) will apply to the use of Zoom service, and we have no control over their terms or privacy practices. If the Student attends the college.dev™ events such as workshops, coding challenges, hackathons, fairs, makers day, etc. the Student’s video and audio will be accessible to anyone who has access to the college.dev™ platform.

APPLICANT DATA COLLECTED THROUGH OTHER-PARTY EMPLOYERS

College.dev provides Services to companies (employers) to facilitate employee recruitment. Through the provision of these Services, we collect Job Applicant Data that is personally identifiable information from or about Job Applicants at the direction of and on behalf of the other-party company (employer) that the job applicant is applying or has applied for a job at. We consider such Job Applicant data to be strictly confidential and in general do not use such data for any purpose other than improving our services and providing our Services to the other-party employer or on the other-party employers behalf. Our collection use and sharing of Job Applicant Data is governed by our contracts with the other-party employers and state, federal, and international laws as applicable, but not by the provisions contained in this Privacy Policy. If you have any questions about reviewing, modifying, or deleting personal information of Job Applicant, please contact the other-party employer directly.

CROSS BORDER TRANSFERS

We may collect, process, and store your information in India and other countries. The laws in India regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.

UPDATES AND CHANGES TO PRIVACY POLICY

We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat User’s personally identifiable information, or in the Privacy Policy itself, we will display a notice on the Platform or send Users an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services.