The Connecting Talent to Opportunity Challenge (“Challenge”) hosted on cto-challenge.com (also referred to as the “Challenge website”, “website” or “site”) is being managed by Kaptivate, LLC (“Kaptivate”) under contract to the U.S. Department of Education (“the Department”, “Challenge Sponsor”) (Contract Number: 91990021A0017; Order: 91990025F0097). This challenge website is not a government website and the Department’s Privacy Policy does not apply to this site. For more information about the Department and the Department’s Privacy Policy, please visit www.ed.gov or view ED’s Privacy Policy.

Kaptivate is committed to protecting the privacy of visitors to this website, members of the Challenge community, Challenge participants, and those providing contact information in connection with the Challenge. In addition, Kaptivate is opposed to unauthorized commercial email delivery, otherwise known as spam. Please read the following Privacy and Spam Policy to understand how your personal information is treated. From time to time, Kaptivate may offer new information or services that may affect this policy. 

The following privacy policy (“Privacy Policy”) sets forth Kaptivate’s policy with respect to information, including personally identifiable data (“Personal Data”) and other information, Kaptivate collects from visitors to the Challenge website hosted by Skipso and located at https://cto-challenge.com and relevant product subdomains. Kaptivate, the owner and operator of the website, is a limited liability corporation formed under the laws of the Commonwealth of Virginia, United States. Skipso provides the underlying challenge-management platform and hosting services for this website and processes information on Kaptivate’s behalf as a service provider.

This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein.

For information about the Challenge, email team@cto-challenge.com. For questions about this privacy policy, email privacy@kaptivategroup.com. 

WHAT INFORMATION DO WE COLLECT & HOW IS IT USED?

Information You Voluntarily Submit to the Website: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, join the Challenge community, or submit a Challenge entry. Personal data may include, but is not limited to, the below:

• Your name and email address

• Your organization name

• Your organization address

Our legal basis for processing this information is your consent, and by voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Kaptivate and the authorized third parties referenced below.

We may receive information about you from other sources. For example, if you use third-party software through the site, they may transfer information to us for fulfillment. For more information about our use of third-party providers, please see below.

Information We Collect from Others: 

Automatically-Collected Information: We automatically collect certain information about you and the device with which you access the website. For example, when you use cto-challenge.com, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the website such as links clicked.

Cookies: We may log information using cookies, which are small data files stored on your browser. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the website. For more information about our use of cookies, please see below.

HOW YOUR PERSONAL INFORMATION MAY BE USED 

Kaptivate, and our subsidiaries and affiliates (the “Related Companies”), may use your personal information in the following ways:

• To create your account, identify you as a user of the website, and customize the website to your account;

• To send you promotional information, such as newsletters. Each email newsletter will provide information on how to opt-out of future mailings by unsubscribing;

• To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;

• To respond to your comments or inquiries;

• To provide you with user support;

• To track and measure website performance;

• To protect, investigate, and deter unauthorized or illegal activity;

• To review the effectiveness of our marketing programs and analyze other general demographic trends;

• To notify you of new information or services that may be of interest to you; or,

• To send promotional materials.

LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

Below are the types of lawful basis that we will rely on to process your Personal Data:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@kaptivategroup.com. 

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with legal or regulatory obligations means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

• Consent means where you have consented to a certain use of your Personal Data.

DOES KAPTIVATE SHARE MY INFORMATION?

Kaptivate will not share, rent, lease or sell your personally identifiable information with third parties. We may, however, share your information with third parties when we are authorized to share such information.

Challenge Sponsor: As needed, we will share your information with the Challenge Sponsor to support the conduct of the Challenge and your participation in the Challenge.

Parent Companies and Affiliates: We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.

Agents, Consultants, and Related Third Parties: Kaptivate, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Kaptivate may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Kaptivate, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.

Third-Party Vendors: Additionally, Kaptivate may use third-party service providers to service various aspects of the website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policy. Kaptivate currently uses the following third-party service providers:

Platform Provider. The Challenge website runs on technology and hosting services supplied by Skipso. Skipso processes Personal Data only to support the operation of the Challenge and does not use this information for its own purposes.

Tracking: Kaptivate and the Platform Provider use various marketing tools that help us create a better user experience for people visiting our site. These tools allow us to look at aggregated data such as scrolling patterns and clicks, as well as allow us to run tests to determine which pages result in the best actions. However, your personally identifiable information is not used by any of these tools. We use the following third-party service providers for tracking: Google® Marketing Platform, HubSpot®, and Screaming Frog®. 

Google Analytics: Privacy Policy

Google Analytics Opt-Out. To provide website visitors the ability to prevent their data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). If you want to opt-out, download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer, Safari, Firefox, and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, 3rd-party cookies must be enabled. Learn more about the opt-out and how to properly install the browser add-on here.

Newsletters: Kaptivate uses MailChimp® as its email newsletter service provider. Through MailChimp, we distribute our newsletter, and track actions you take that assist us in measuring the performance of the website and newsletters. 

Our newsletters contain tracking pixels. This pixel is embedded in emails and allows us to analyze the success of our newsletters. Because of these tracking pixels, we may see if and when you open an email, which links within the email you click, and the pages you visit on our website. This behavior is not passed to third parties. All data submitted at the time of subscription to our newsletter is stored on MailChimp servers. You may access MailChimp’s privacy policy here. At any time, you may be removed from our newsletter list by clicking on the unsubscribe button provided in each email.

Surveys: Periodically, we may invite you to complete a voluntary survey. All surveys are completed through Survey Monkey®. All survey responses may be submitted anonymously and only your IP address is stored. You may voluntarily enter your name and email address. All data submitted through Survey Monkey is stored on their servers and is subject to the SurveyMonkey privacy policy.

Webinars: From time to time, Kaptivate will host webinars, which may be hosted through Zoom®. If you elect to participate in a webinar, you will be required to submit personal information to register and log in. You may also receive email communications regarding reminders and playback availability.  Zoom Privacy Policy.

All information submitted for your participation is stored by the software hosting the webinar. Please consult their individual privacy policies.

OTHER TYPES OF DATA

Non-Identifiable Data: When you interact with us through the Website, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. The Website may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Sites, Kaptivate may conduct research on its customer demographics, interests, and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, and business partners. This aggregate information does not identify you personally. Kaptivate may also disclose aggregated user statistics to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

PUBLICLY VISIBLE INFORMATION

If you create a user profile on Kaptivate, or leave a comment on Kaptivate’s website, certain information may be publicly visible.

COOKIE POLICY

General Information

In order to provide the user with a better and personalized browsing experience, the Controllers as defined in the privacy notice need to keep information on how to use this website. 
To do this, “cookies” are used. Cookies are text files, which contain small amounts of information, sent from a Website to the browser of the computer or other device used by the user where they are stored, to then be re-transmitted to the same Website on each subsequent visit; and this recognizes the user and makes the Website more responsive to his requests, as well as facilitate navigation. 

You can get more information about cookies and how they work by visiting the website 
http://www.aboutcookies.org/. 

With each use of this Website, personal data may be collected through the use of the aforementioned cookies. This information on the use of cookies should be read in conjunction with the privacy notice of this Website where you can get more information on the processing of the user's personal data.

What type of cookies do the Controllers use and for how long ?

Cookies can be divided into two macro-categories: "technical" cookies and "profiling" cookies. 

Technical cookies are used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary for the provision of a service requested by the user. 

Profiling cookies are aimed to create a user profile and are used to send advertising messages in line with the preferences expressed in the context of surfing the net. 

There is also another category, analytics cookies, similar to technical cookies when they are used by the Website to collect information, in aggregate form, on the number of users and how they visit the Website. 

The Data Controllers use technical cookies on this Website: technical cookies include browsing or session cookies and functional cookies, the disabling of which could compromise the browsing experience of the Website. 

No analytics and profiling cookies are used on this Website. The Data Controllers inform users that the different types of cookies used have a predetermined duration, as indicated below, unless they are disabled, as described in the section "How can I control cookies?" The various types of cookies used on this Website are listed below.

1. Technical Cookies

Browsing or Session cookies used in the Website are necessary for its operation. This type of cookie is used in response to requests for services by the user. These technical cookies, provided and managed by Skipso LTD are used, among other things, for:

- Store the data provided by the user during a browsing session; 
- Keep the user's preferences and credentials active while browsing the Website; 
- View the contents in the chosen language at each access, recognizing from which country the user is connecting (and remembering this setting in future accesses). The activation of these cookies is required, as their disabling could prevent, or strongly compromise, the correct browsing of the Website. It is possible to set the browser used in order to block these cookies, but some parts of the Website may not work. 

Type of data collected: data related to Website browsing.

Duration: These cookies have a temporary duration, disappearing from the device when the user finishes browsing the Website and closes the browser used.

2. Functional cookies

The Data Controllers also uses functional cookies for browsing the Website, which are essential to ensure the correct operation of the Website, as they allow the user to browse within it and use its basic functions. In no case these cookies collect information that can be used for commercial purposes. These technical cookies are also provided and managed by Skipso LTD. If these cookies are disabled, the quality and browsing experience may not be satisfactory. 

Type of data collected: data related to Website browsing. 

Duration: These cookies have a temporary duration, disappearing from the device when the user finishes browsing the Website and closes the browser used.

How can I control cookies ?

Please note that deleting or blocking cookies may affect the user's browsing experience and some parts of this Website may no longer be fully accessible. 

The installation of technical cookies does not require the user's prior consent. It is possible to disable them through the browser settings as specified in the "Browser settings" section. In general, the user's consent is required for the installation and use of profiling cookies, expressed upon first access to a site. Once the user has given consent to their use, he or she may revoke it at any time by disabling the installation of profiling cookies through the browser settings. However, the Data Controllers does not use profiling cookies on this Site.

Browser settings

Most browsers allow the user to check which cookies have been installed, to delete them individually or to block cookies from all or certain websites. Once the cookies have been deleted, any settings on the previously set options will be lost. It is therefore possible to configure the browser to accept or reject the cookies used by this Website. Each browser is different, therefore it is necessary to check the configuration settings of the specific browser used to manage the options on enabling cookies. The activation or deactivation of the cookies used on the Website can be performed at any time according to the instructions contained in this cookie policy. Disabling the technical cookies indicated in the previous section could prevent correct browsing on the Website and/or limit its usability. Consequently, to better use the services accessible through the Website, it is not recommended to disable these technical cookies. 

With reference to the cookies of this Website, the user can change cookie settings, according to the configuration of the browser used. Below the user may find the links to the configuration webpages of the most popular browsers: 

- Safari: https://support.apple.com/guide/safari/manage-cookies-and-webWebsite-data-sfri11471/mac
- Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=fr&hlrm=en
- Firefox: https://support.mozilla.org/en-US/kb/block-webWebsites-storing-cookies-Website-data-firefox
- Microsoft Edge: https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-cookies
- Opera: http://help.opera.com/Windows/10.20/it/cookies.html

FURTHER INFORMATION AND CONTACT DETAILS

If you have any questions about or if you would like more information on the Cookies that we use and their purposes, please contact us at privacy@kaptivategroup.com.

WHAT IF THERE ARE CHANGES TO THIS PRIVACY AND SPAM POLICY?

If we change our Privacy and Spam Policy, we will post those changes on our privacy page you are currently viewing (https://www.cto-challenge.com/en/page/privacy-policy-en).

RIGHTS RELATED TO YOUR PERSONAL DATA

Under laws in certain countries in which we operate, customers and other visitors to our Website from those countries have a right to access Personal Data about themselves, and to amend, correct, or delete Personal Data that is inaccurate, incomplete, or outdated. We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete, or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

Please note that while any amendments, corrections, or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Please contact us at privacy@kaptivategroup.com to submit a request or obtain information regarding any of the above. Opt-out: You may opt-out of future email communications by following the unsubscribe links in our emails. You may also notify us at privacy@kaptivategroup.com to be removed from our mailing list.

Access: You may access the personal information we have about you by submitting a request to privacy@kaptivategroup.com.

Amend: You may contact us at privacy@kaptivategroup.com to amend or update your personal information.

Forget: In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to privacy@kaptivategroup.com.

California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have the right to request disclosure of our data collection and sales practices in connection with our data collection of your Personal Data. You may also request the categories of Personal Data we have collected, the source of the Personal Data, our use of the Personal Data, and if the Personal Data was disclosed or sold to third parties, including the categories of Personal Data sold or disclosed. You also have the right to request a copy of the Personal Data collected about you for the twelve (12) months prior to the date of your request. You have the right to request that we delete your Personal Data, with the exceptions noted above and those delineated in the CCPA. You have the right to request that we do not sell your Personal Data to any third parties. In the event you make such a request, we reserve the right to collect information from you to verify your identity and the right to request such information. All requests made pursuant to the CCPA shall be made to privacy@kaptivategroup.com or to Kaptivate LLC, 516 N. Washington Street, Alexandria, VA 22314-2314. We will respond to all requests within forty-five (45) days of our receipt of the request, unless we inform you of our need for an extension to the request. We will not discriminate against you for exercising any of your rights under the CCPA.

SENSITIVE PERSONAL INFORMATION

Unless you choose to provide it to us, we do not collect sensitive personal information from you using the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy and Spam Policy.

CHILDREN’S INFORMATION

Kaptivate does not knowingly collect any personally identifiable information from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Website without their permission. If a parent or guardian believes that Kaptivate has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at privacy@kaptivategroup.com and we will use our best efforts to promptly remove such information from our records.

SPAM POLICY

Kaptivate is strongly opposed to spam. We will only send emails to users that have explicitly requested to receive an email from Kaptivate. Examples may include:

• Opt-in subscribers to the Connecting Talent to Opportunity Challenge Community

• Users that complete a contact form

• All communication will be related and relevant to what you have requested.

WEB LINKS

The Challenge website contains links to other sites. Please be aware that Kaptivate is not responsible for the privacy practices or the content of such other sites. We encourage our users to be aware when they leave our site to read the privacy and spam policies of each and every website that collects personally identifiable information. This Privacy and Spam Policy applies solely to information collected by Kaptivate.

EMAIL COMMUNICATIONS

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send nonpublic personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.

HOW DO I CONTACT KAPTIVATE?

If you have any further questions or comments regarding this Privacy and Spam Policy, you may contact privacy@kaptivategroup.com.

OTHER TERMS AND CONDITIONS

Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Kaptivate. Please refer to those agreements as needed.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

CHANGES TO PRIVACY POLICY

The Website may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, especially before you provide any Personal Data. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.