Privacy Policy

Last updated: December 2022

This privacy policy (the “Privacy Notice”) discloses the privacy practices for Generation: You Employed, Inc. (“GYE”) and GYE’s affiliated entities (“Affiliates”) (collectively “Generation”). It explains Generation’s practices for the collection, use, maintenance, protection, and disclosure of information that we collect from you or that you provide to us, and applies when you: (1) visit GYE’s website at http://global.generation.org/ or the Affiliates’ websites at the generation.org domain (such as https://uk.generation.org/) (the “Websites”); (2) use any of the mobile, web, or desktop applications GYE provides in connection with our services, such as Canvas and the GYE Learner Portal (“Applications”); (3) email and correspond with Generation; (4) provide information to us offline including in person and in paper documents; and (5) otherwise where we notify you and incorporate this Privacy Notice. We collectively refer to our Websites, Applications, and data collection and processing associated with our services together in this Privacy Notice as the “Platform.”

Before accessing, using, or interacting with the Platform you should carefully review the terms and conditions of this Privacy Notice. By using the Platform, you consent to and agree that we may collect, process, use, retain, share, and transfer your personal information as described in this Privacy Notice. By accessing, registering with, uploading, downloading, subscribing to, or otherwise using the Platform, you agree to this Privacy Notice and our Terms of Use, including any updates thereto. If you do not agree with our policies and practices you should immediately refrain from using the Platform. We are not responsible for the content or the privacy policies or practices of any of our members, third-party websites, or third-party applications.

This Privacy Notice may change from time to time. Your continued use of the Platform after we make changes may be deemed to be acceptance of those changes, so please check back periodically for updates.

Contact Details

For the purposes of the EU and UK General Data Protection Regulations, which regulate our use of EU and UK individuals’ personal data, GYE and the Affiliate processing such personal data are considered joint data controllers. Generation’s Data Privacy Officer for purposes of EU General Data Protection Regulations is Minh-Huy Lai. Should you have any comments or questions about how we collect and use your personal information, the Data Privacy Officer or equivalent lead can be reached at privacy@generation.org and 198 avenue de France Paris 75013 France.

Types of Information Collected and Processes for Collection

Generation collects information about you and your use of the Platform through various means, including when you provide information to us, both online and offline, and when we automatically collect information about you when you access, use, or interact with the Platform. Such processing is needed to provide you with the Platform.

By using the Platform, you acknowledge that Generation may process your information in the United States and any other country where Generation operates in the manner described in this Privacy Notice. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to these countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information is transferred legally and continues to enjoy appropriate protections. Please read on to learn more about how we protect personal information, including personal information that’s transferred outside of Europe.

The types of information Generation may collect about you include:

Information You Provide to Us

We process the information you provide to us on the legal basis of Generation’s legitimate interests in providing the function or service you requested or pursuant to our performance of a contract to deliver a contractual service to you. We may rely on alternate legal bases where appropriate, such as your consent to certain types of processing. Categories of information we may collect from you include:

Personal Information: When you access, use, or interact with our Platform, we collect the information you provide to us, and certain information about your device and interaction with the Platform. In this Privacy Notice, we refer to any information that can uniquely identify an individual as “personal information.” This Privacy Notice provides information about our means of collecting personal information, the categories of personal information we collect, the purpose of collection, and to whom we may disclose it and why.
Account Information: In some instances, certain Platform users may register for an account (a “Platform Account”). We do not require you to register to use our Platform. However if you do register a Platform Account, you will gain access to those areas and features of the Platform that require registration. Generation will collect certain information about you in connection with your registration for a Platform Account, which may include personal data and other information such as a username and password.
Post-Graduate Services: In some instances and if you consent to such services, when you have graduated from our program we may collect certain information (including the title and the compensation details) from you and your employer on your performance and progress so that we can stay in touch and monitor the results of your employment pursuits.
Correspondence Information: If you apply for a job, sign up, email or otherwise correspond with us, subscribe to our newsletters, distributions, or mailing lists, or donate through the Platform, we may keep personal information associated with those correspondences, which may include your message, personal information,
notes/comments, job title, employer, employer type, employer size, country in which your employer is headquartered, areas of interest, source of referral, and contact information. We do this to respond to your requests, provide and improve the requested services, and to provide notifications or other correspondences to you. If you do not want to receive communications from us in the future, please let us know by sending us an e-mail requesting the same to privacy@generation.org or by following the unsubscribe instructions found in any e-mail we send. If you supply us with your postal address on-line, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at privacy@generation.org or by calling our phone number provided above. Please note requests to remove your email address from our lists may take some time to fulfil. We may also still contact you in certain circumstances to provide important announcements or notifications regarding the Platform.
Offline/Paper Documents: In some circumstances, GYE may collect data from individuals via paper documents or other offline formats. This Privacy Notice applies to the data GYE collects in this manner. We make efforts to notify individuals of this Privacy Notice and make it available to them for review.
Support Information: You may provide information to us via a support request submitted through the Platform or via email to privacy@generation.org. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for Generation or our service providers to have access to or use in the future in a manner consistent with this Privacy Notice.
Form Information: We may use forms to request certain information from you on the Platforms, such as your contact information to assist with contacts or job applications. This information may include personal information.

Specific types of information we collect from you include:

Basic personal details, including but not limited to, your name, email address, contact number(s), postal address and region.
Sensitive personal information, including but not limited to, your ethnicity, religion, gender, sexual orientation, marital status, socio-economic status, household status, offender status, disability status, caring status, and well-being status.
Availability and work eligibility details, including but not limited to, your current and/or future work eligibility status, visa type, visa expiry date, refugee or asylum status, current employment status, current government benefits received and past educational attainment.
Application details, including but not limited to, the source of your application, the date/time, the program(s) you applied for, employment history/expectations, current/past financial status, and employment search history/expectations.
Documents you provide throughout the application process, and subsequently, if successful, during the program, including but not limited to, CVs, covering letters, assessment outputs, proof of subsequent employment, proof of income, and proof of UK work eligibility. These documents may contain information on your employment, employment history, academic qualifications/history, professional training/certifications, skills, and experiences.
Records of electronic communications, including but not limited to the content and attachments of emails.

We may allow visitors to provide information to be published or displayed on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users on the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Gather Through Automated Collection

As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to and uses of the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on the Platform (including your IP address, browsing and navigation patterns, click stream data, device metrics, etc.)
Information about your computer, mobile device and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to: (1) estimate our audience size and usage patterns, (2) store information about your preferences, allowing us to customize the Platform according to your individual interests, (3) speed up your searches, (4) recognize you when you return to our Websites, (5) optimize your user experience across the Platform.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small piece of data placed on the hard drive of your computer to help us improve your access to the Websites and to identify repeat visits to the Websites. We also use cookies to track and target the interests of visitors to the Websites and to otherwise enhance the experience on the Websites. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Websites. Usage of a cookie is not linked to any personal information on our site.
Flash Cookies. Certain features of the Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Generation, for example, to count users who have visited those pages or opened an e-mail and for other related Websites statistics (for example, recording the popularity of certain Websites content and verifying system and server integrity).
Unique Identifiers: When you use or access the Platform, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Websites. Some features of the Platform may not function properly if use or availability of Unique Identifiers is impaired or disabled.
Analytics Information: We use data analytics to ensure site functionality and improve the Platform. We use mobile analytics software to allow us to understand the functionality of the Platform on your phone. This software may record information such as how often you use the Platform, what happens within the Platform, aggregated usage, performance data, app errors and debugging information, and where the Platform were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
Log File Information: When you use our Platform, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Platform, for example, when you visit our Websites, sign into our Platform, or interact with our email notifications. Generation uses log file data to provide, understand, and improve our Websites, and to customize the content we show you. Generation may link this log file to other information Generation collects about you via the Platform.
Public Information: Generation may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Notice, and may be accessed and collected by Generation. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Platform is neither private, nor confidential. Generation is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.

Any information that we collect automatically may be paired with personal information about you that we collect from other sources or you provide to us.

We process the information we collect about you automatically on the legal basis of Generation’s legitimate interests in providing the function or service you requested. We may rely on alternate legal bases where appropriate, such as your consent to certain types of processing.

Third-party Use of Cookies and Other Tracking Technologies

The Platform may contain links to third-party websites. If you click of these links, you leave the Platform and may be taken to an independent website managed by a third-party. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when navigate to them from our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Links do not imply endorsement, sponsorship, or recommendation of the third-party, their website, or the information it contains. This Privacy Notice does not apply once you have left our Platform. We do not control any third-party websites, including tracking technologies which may be used on such websites. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use the information we receive about you for the purposes described in this Privacy Notice. We generally process certain personal information received about you through our Platform on the legal basis of Generation’s legitimate interests in providing the Platform and its functionality to you or pursuant to our performance of a contract to deliver the services provided by our Platform to you. Such processing is necessary for the purposes of the legitimate interests pursued by Generation or our Service Providers related to the Platform or where such processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.

We use information that we collect about you or that is provided to us, including personal information: (1) to present our Platform and its contents, including to optimize the use of our Platform and its interface, (2) to provide communications, information or services, including those that you request from us, (3) to analyze use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features (4) to fulfill any other purpose for which it was provided, (5) if you have registered for a Platform Account, to provide you with notices about your account, (6) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, (7) to provide notice about changes to our Platform or any services we offer or provide though it, (8) to allow for participation in interactive features on our Platform, (9) in any other way we may describe when the information is collected or provided, (10) or any other purpose with your consent or other valid legal basis.

The following table provides legal basis identifications for certain uses of your information.

Use of information	Legal basis
(1) to present our Platform and its contents to you, including sharing information with our Service Providers to help present the Platform, and to allow GYE to optimize the use of our Platform and its interface. Examples of such uses include: Enhancing any information that we receive from you with information collected, generated, or obtained throughout our recruitment processes. Considering your employment and related circumstances after graduating from the training program to determine the success of Generation in delivering employment opportunities.	GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract; or GDPR Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(2) to provide you with the Platform and its services, communications, and related information, including those Services that you register for or request from us. Examples of such uses include: Considering your application in respect of the training programs for which you have applied or may be a good fit. Communicating with you in respect of the recruitment process for a training program. Considering your performance during the training program to determine the success of Generation in delivering training. Reporting to the organizations who fund our programs in line with agreements we hold with those respective organizations.	GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(3) to analyze your use of the Platform in order to update, modify, improve, tailor, customize, or otherwise adjust the Platform and its features	GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(4) to fulfill any other purpose for which you provide it	GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes; GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(5) to provide you with notices about your Platform Account	GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract; or GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(6) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us	GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract.
(7) to notify you about changes to our Platform or any services we offer or provide though it	GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(8) to allow you to participate in interactive features on our Platform	GDPR, Art. 6(1)(b): personal data is necessary for the performance of a contract; GDPR, Art. 6(1)(f): personal data is necessary for the purposes of the legitimate interests pursued by Generation or by a third party, and there is no prejudice to the data subject arising from the use.
(9) in any other way we may describe when you provide the information	GDPR, Art. 6(1)(a): you have given consent to the processing of your data for one or more specific purposes.

We also collect, use and may share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your data to calculate the percentage of users accessing a specific Websites feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Notice.

Where you have provided consent, you may have the right to withdraw that consent at any time by privacy@generation.org, but a withdrawal of consent will not affect its validity up until the point you have withdrawn it.

How Your Information May Be Disclosed and Shared

This Privacy Notice describes how we may disclose and share your personal information. We will not share, sell, rent, or otherwise disclose your personal information to third parties without your consent or another valid legal basis permitted by law.

We may share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Services or pursuant to our performance of a contract to deliver a contractual service to you:

GYE Personnel: We may share the information we collect within GYE as permitted by applicable law. GYE’s personnel may have access to your information as needed to provide and operate the Platform in the normal course of business.
Affiliates: We may share certain information we collect with GYE’s affiliated national entities (our Affiliates) where permitted by applicable law, as disclosed in this Privacy Notice, and with appropriate agreements, legal bases, and precautions in place. This includes information regarding you and your use and interaction with the Platform. GYE Affiliates may have also collected information about you, which they may share with GYE. GYE and our Affiliates are joint controllers of personal information associated with the Platform. Affiliates are not permitted to share personal information between Affiliates; an Affiliate may only share your information with GYE.
Employer Partners: We may share information with our employer partners who will interview and/or seek to hire you upon or after the completion of our program. Information we share with employers about you includes your personal information and information about your use of and performance under the Platform.
Donors: We may share aggregated, de-identified, or anonymous information with our donor partners without restriction. In some circumstances, some donors may also be GYE employer partners, and so they may receive your information as an employer.
Service Providers: Generation works with various individuals, organizations, contractors, and vendors to provide the Platform (“Service Providers”). This includes Services Providers to provide for the performance of hosting, providing analytics, performing research, undergoing development on the Platform, and engaging in social media services, as well as to other partners as we determine necessary to support our business, including to students, teachers, alumni, and mentors who may or may not be on the Platform. These third parties have only limited access to your information and may use your information only to perform their assigned tasks on our behalf and in furtherance of performance of the services provided via the Platform. Information we share with our Service Providers may include both information you provide to us and information we collect about you, and may include personal information and information from data collection tools like cookies, web beacons, and log files. We share personal information with our Service Providers on the legal basis of Generation’s performance of a contract with you regarding provision of the Platform services or on the basis of legitimate interests in providing you with the Platform. Our engagement of Service Providers is often necessary for us to provide the Platform to you, particularly where such companies play important roles like helping us keep our Platform operating and secure or in improving our Services, such as Service Providers that provide improvements for our instructors. In some other cases, these Service Providers aren’t strictly necessary for us to provide the Platform, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with Service Providers to make our Platform better.
Business Transactions: Generation may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Where permissible by and in accordance with applicable law, your information, including personal data, may be among assets sold or transferred as part of a Business Transaction.
Lawful Requests: We may be required to disclose Platform user information pursuant to lawful requests such as such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Platform or using Generation name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

Your Rights

Generation seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon the laws applicable to you.

Regardless of your jurisdiction, if you would like to manage, change, limit, or delete your personal information, you may do so by contacting us. Upon request, and where possible, Generation will provide you with information about whether we hold any of your personal information and the information we hold about you. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format.

European Union and United Kingdom Rights

If you are a resident of the European Economic Area or the United Kingdom (also referred to as a “Data Subject”), the General Data Protection Regulation (“GDPR”) and United Kingdom General Data Protection Regulation (“UK GDPR”) provide additional rights regarding our use of your personal information. This section is provided pursuant to the GDPR and UK GDPR. Each capitalized term used, but not defined, in this section shall have the meaning given to such term in the applicable regulation. This section describes how we collect, share, disclose, and process the personal information of residents of the European Union and United Kingdom. Personal information means any information relating to an identified or identifiable natural person (referred to ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes all “personal information” referred to in this Policy.

If you are located in the European Economic Area or the United Kingdom, you have certain rights regarding the personal information that we maintain about you, which in certain circumstances you will be able to exercise. The rights are as follows:

Access: You may request a copy of the personal information we maintain about you.
Portability: If we maintain your personal information based on your consent or so that we can enter into or perform under a contract with you, you have the right to obtain your personal information from us that you consented to give us, that is necessary to enter into or perform the contract, or that is necessary to provide member benefits to you. We will give you your personal information in a structured, commonly used and machine-readable format.
Correction: If you believe your personal information is incorrect, you may request that we correct, amend or delete your personal information that is inaccurate or incomplete.
Deletion or Restriction of Processing: You may request that we erase or restrict the processing of your personal information.
Object to Processing: You may object to the processing of your personal information in certain circumstances when we process your personal information for the purposes of our legitimate interests.
Right to Complain: You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes upon your rights.
Withdraw Consent: If we are processing your personal information based on your consent to do so, you may withdraw that consent at any time.

We only process personal information where we have a valid legal basis to do so including:

When you have consented to the processing of your personal information, including processing your personal information consistent with this Policy, including the advertising purposes disclosed in this Policy;
When processing is necessary to perform our obligations to you or fulfill a request you have made to us;
When processing is necessary to comply with a legal obligation that applies to us; or
When processing is necessary for purposes that are in our legitimate interests and you have given any required explicit or implicit consent to such processing, including protecting the security of our Platform, improving the functioning of our Platform, or providing you with information about products in which you have expressed interest.

If we process your information based on our legitimate interests as explained in this Privacy Notice, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings if you have registered for a Platform Account. However, please note you may not opt-out of Platform-related communications, such as account verification, changes or updates to features of the Platform, or technical and security notices.

Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting Generation at: privacy@generation.org. A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.

If we need to process your personal information to fulfill our obligations to you, failure to provide that personal information will mean that we cannot perform our obligations. If we collect your personal information for one purpose and need to process it for second purpose, we will provide you with additional information regarding this secondary purpose to ensure fair and transparent processing before we engage in further processing.

Access to the Information Generation has Collected About You

Generation welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Platform uses of your information, or to withdraw any consent you may have granted to Generation. Please contact us regarding your request to change, correct, request the deletion or removal of, or express any concerns relating to the collection, use, or disclosure of your personal information by e-mailing privacy@generation.org. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may retain the information we receive about you for as long as necessary to fulfil our contractual and legal obligations, consistent with our data retention schedules, or indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. In addition, we may delete your personal data from our systems as part of our general business processes or a data retention plan. Following termination or deactivation of a Platform Account, Generation may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.

Please note requests to delete or remove your information do not necessarily ensure deletion or complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Platform, may no longer be available to you.

You may also have the right to ask to see what information we hold about you, and what we are doing with it. This is known as a Subject Access Request, and must be made in writing to privacy@generation.org.

You also have a right to request your information in a format which supports its portability. Please contact privacy@generation.org should you wish to exercise this right.

Do Not Track

Generation does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use the Platform. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.

California and U.S. State Law Privacy Rights

As nonprofit organizations, GYE and its Affiliates are not directly subject to the requirements of the California Consumer Privacy Act of 2018 (“CCPA”) as “businesses,” or certain other U.S. state privacy laws. However, we strive to act to provide rights to our data subjects consistently with the intent of the CCPA and similar U.S. privacy laws. No matter where you live, you may request information about the personal information we hold about you by following the procedures to contact us outlined in this Privacy Notice.

Additional Provisions

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. When you submit personal information via the Platform, we take measures designed to ensure your information is protected. We also protect your information offline. We limit access to personal information to employees who need the information to perform a specific job (for example, communications or recruiting). The servers on which we store personal information are kept in a secure environment. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. Please do not to share your password with anyone.

Unfortunately, the transmission of information via the internet is always subject to security vulnerabilities. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

Changes to Our Privacy Notice

It is our practice to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Websites. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Platform and this Privacy Notice to check for any changes.

International Transfer of Information

Please note information Generation collects about you may be transferred, processed and/or accessed by us in the United States or another country where GYE or our Affiliates or Service Providers operate. Please be aware your personal data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Generation may transfer your personal data to the United States and process and store it there.

If you are located in the European Economic Area (“EEA”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Notice. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers, also as disclosed.

Children’s Data

Within the EEA. This Platform is not intended for children living in the EEA who are under 16 years of age. No one under the age of 16 may provide any information to or on the Platform. If you are under 16, do not use or provide any information to Generation or otherwise interact with the Platform. If we determine that we have collected or received any information from any child under the age of 16, we will delete that information immediately. If either (1) a child under 16 has provided information to the Platform or (2) you believe that we might have any information from or about a child under the age of 16, please contact us at privacy@generation.org to provide additional information or to request the removal of the relevant information from our database.

Outside of the EEA. Also, the Platform is not intended for children under the age of 16 years of age living outside of the EEA. No one under the age of 16 may provide any information to or on the Platform. If you are under 16, do not use or provide any information to Generation or otherwise interact with the Platform. If we determine that we have collected or received any information from any child under the age of 16, we will delete that information immediately. If either (1) a child under 16 has provided information to the Platform or (2) you believe that we might have any information from or about a child under the age of 16, please contact us at privacy@generation.org to provide additional information or to request the removal of the relevant information from our database.

If you feel that we are not abiding by this Privacy Notice, you should contact us immediately via email at privacy@generation.org.