Online Privacy Policy

Effective Date: August 18, 2021

Customer Privacy Policy

Girls With Impact is committed to protecting students’ privacy. This Girls With Impact Online Customer Privacy Policy (“Policy”) explains what personally identifiable information we collect from or about students through their use of our Online Learning Programs that our Customers (as defined below) have licensed from us and how we use, disclose, and otherwise process that information. This Policy does not apply to our general purpose website at http://www.girlswithimpact.com or to anything other than our Online Learning Programs.

Students’ Access to Our Online Learning Programs

Our Online Learning Programs are provided to students under the age of 18 (or through high school graduation to the extent that occurs at age 18 or later) solely through fixed-term subscriptions purchased by guardians, schools, school districts, and other educational entities (our “Customers”). Girls With Impact’s Online Learning Programs are not available to students under age 18 except when they are enrolled for access as an authorized user by one of our Customers.  Our Customers are required to obtain any and all legally required consents and authorizations from a student’s parent/guardian prior to their enrolling for access a student under age 18. Our Customers also dictate which aspects of our Online Learning Programs students are able to access.

Your Consent

By using (or allowing your child/student to use) Girls With Impact’s Online Learning Programs you (on behalf of yourself and your child/student) accept, and agree to be bound by, the terms of this Policy. If you do not accept and agree to the terms of this Policy, neither you nor your child/student may use our Online Learning Programs.

Information We Collect and How We Use It

We collect the following information about students who use our Online Learning Programs. 

Personally identifiable information provided by the Customer who enrolled the student for access, by the student’s parent/guardian, or by the student. This information may include information such as the student’s name, name of school, grade level, and e-mail address.

Browser information, such as IP address, the name of a student’s operating system, the name and version of a student’s browser, the date and time of a student’s visit, and the pages the student visits. This information is not personally identifiable, but it can be linked to information that identifies a student, and we reserve the right to do so.

Tracking information, including information collected by cookies, such as which pages students visit, which links they use, and how long they stay on each page. The tracking information we collect is not personally identifiable but can be linked to information that identifies a student, and we reserve the right to do so. Please note that a student’s browser must be set to accept cookies for our Online Learning Programs to be fully functional.

We use the information we collect through our Online Learning Programs for educational, efficacy, program and business enhancement purposes and also for other purposes that are authorized or required by the Customer who enrolled the student for access and/or the student’s parent/guardian. For example, we use students’ login information to verify their identities, and we track certain activities so that educators know when students have completed assigned tasks. We may use information collected through our Online Learning Programs to improve those tools—for example, we may use information on students’ performance to improve the programs’ efficacy, we may use browser information to make our tools more compatible with the technology used by students, and we may use cookies to personalize students’ experience when using our tools. However, we do not build profiles of students for any purpose other than to support authorized educational purposes (or as authorized by the student’s parent/guardian), and we do not use students’ information for any marketing or promotional purpose. We reserve the right to use the information we collect for security purposes— for example, to detect intrusions into our network.

Entities With Whom We Share Student’s Information

We share students’ personally identifiable information with the Customer who enrolled the student for access to our Online Learning Programs.  We may also share such information with vendors, suppliers, licensors and/or subcontractors (“Contractors”) that perform services on our behalf. Our agreements with these Contractors generally contain confidentiality and non-disclosure provisions requiring that such Contractors maintain the confidentiality of any personally identifiable information that may be disclosed or made available to them so that Girls With Impact can use Contractor’s product or services. We reserve the right to share students’ personally identifiable information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose such information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Online Learning Programs; or to protect our own rights or property or the rights, property or safety of our users or others. Finally, we reserve the right to transfer students’ personally identifiable information to a successor organization if, for example, we transfer the ownership or operation of our Online Learning Programs to another organization, if we liquidate and sell our assets, or if we merge with or are acquired by another organization. If such a transfer occurs, the successor organization’s use of students’ personally identifiable information will still be subject to this Policy.

Children Under the Age of 13 and COPPA

Our Customers determine which of their students will be enrolled to access and use our Online Learning Programs, and our Customers determine what information about those students they will provide to Girls With Impact or input into the Online Learning Programs.  For students under the age of 13, we require our Customers to obtain any necessary or legally required parental consents before allowing students to access or use the Online Learning Programs.  Even then, we do not knowingly collect personal information directly from children under the age of 13.  If you have knowledge that a child under the age of 13 has provided personal information to us, please contact us using the information provided below. Girls With Impact’s COPPA assurance statement can also be accessed here.

Security Measures and Data Retention

Girls With Impact maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of students’ personally identifiable information against risks—such as unauthorized access or use or unintended or inappropriate disclosure—through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. However, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.

Unless students and their parents/guardians separately authorize us to do so, we will not knowingly retain students’ personally identifiable information beyond the time period required to support the educational and other purposes authorized by the Customer, except that we reserve the right to retain data on backed-up, electronically stored records, the destruction of which would be unreasonably burdensome.

Requests for Access and Deletion of Student’s Personally Identifiable Information

Any student or parent/guardian who is interested in accessing the information Girls With Impact stores about the student should request such information from their student’s school (Girls With Impact’s Customer). Likewise, requests to have a student’s information modified or deleted should be directed to the student’s school. Girls With Impact will work with its Customers to respond to all reasonable requests for access, modification, or deletion that the Customers receive and will comply with all applicable laws regarding data retention/destruction. However, there are various circumstances when Girls With Impact may deny a request for access, modification, or deletion, including (but not limited to) when Girls With Impact believes that applicable law or a court order requires it to retain information, when Girls With Impact believes that retention of the information is necessary to protect its rights, or when the request extends to backed-up, electronically stored records, the destruction of which would be unreasonably burdensome.

Links to Other Web Sites

Our Online Learning Programs may contain links to third-party web sites. These web sites are independently owned, controlled, and/or managed web sites whose content we believe will be of possible interest and value to our Customers and their students. However, Girls With Impact does not control these sites or their data privacy and security practices. Once you leave our Online Learning Programs, the use of any information you provide is governed by the privacy policy of the operator of the site you’re visiting. That policy may differ from ours. We specifically recommend that children check with their parents or teachers before clicking links to any third-party sites.

Girls With Impact Assurances Related to the Family Educational Rights Privacy Act

Girls With Impact understands that many of its Customers are subject to the Family Educational Rights Privacy Act (“FERPA”) and provides a list of FERPA-related assurance to our Customers. Students and their parents/guardians may obtain a copy of those assurances upon request, by contacting the student’s school or by contacting Girls With Impact using the information provided below.  Girls With Impact’s FERPA assurance statement can also be accessed here.

Protection of Pupil Rights Amendment (“PPRA”)

The programs and activities of our Customers that receive funds under any program funded by the U.S. Department of Education may obligate our Customers to satisfy certain PPRA obligations. Girls With Impact does not administer to our Customer’s students any surveys or analysis concerning any of the PPRA protected areas nor does Girls With Impact intentionally collect any student information related to such administration.

Student Privacy Pledge

Girls With Impact is a current signatory to the Student Privacy Pledge.  As a signatory, Girls With Impact uses commercially reasonable efforts to comply with the commitments made as a signatory.  Specific details on the Pledge can be found at http://www.studentprivacypledge.org.

Changes to This Policy

If this Policy changes, the revised policy will be posted on our website. We will not make material changes without first providing prominent notice to our Customers. When reasonably able to do so, we will also provide prominent notice to students who use our Online Learning Programs and their parents/guardians, but generally we rely on our Customers to alert students and their parents/guardians to changes. Before using students’ information in a manner inconsistent with the privacy policy in effect at the time it was collected, we will first provide students a chance to opt-in or opt-out (depending on applicable law) of such use. This Policy was last updated on August 18, 2021.

Contact Information

Please contact us at programs@GirlsWithImpact.com if you have any questions or comments about this Policy. You can also contact us by general mail or phone listed below.

General Mail

Girls With Impact

15 E Putnam Ave #276

Greenwich, CT, 06830