Privacy Policy

Hats & Ladders Privacy Policy (August 2, 2019)

This Privacy Policy applies to the hatsandladders.com Websites, web applications, and related curricular materials (the “Products”) and governs data collection and usage. The Products are owned and operated by Hats & Ladders, Inc. (“Hats & Ladders”). By using our Products, you (“you,” or “User”) explicitly accept the collection and use of your data as described in this Privacy Policy. In addition, if you use Hats & Ladders through a school or other organizational sponsor that has contracted with Hats & Ladders to use the Products (“Authorized Institution”), that Authorized Institution may also have obtained your consent (or your parent’s or legal guardian’s consent) to the collection and use of your data as described in this Privacy Policy.

Hats & Ladders provides digital educational planning and counseling tools that enable Users to learn about themselves and connect to academic and career pathways. The collection of information from our users is inherent in the experience we provide.

Hats & Ladders is committed to ensuring the privacy of users, including the teachers, advocates, administrators, counselors, and other professionals who support use of our Products in school or beyond school settings (“Administrators”), and visitors to our Website.

To revoke your consent, please contact us at the addresses at the bottom of this Privacy Policy. If you do revoke your consent, your account and personally identifiable information will be deleted.

This Privacy Policy contains two parts:

    • The first part describes our how we handle the data we gather when individual Users or Administrators use our Products (other than the www.hatsandladders.com Website, but including the Hats & Ladders web application, which may be hosted on that site) (“Service Data”).
    • The second part separately describes the information that we gather from Users of our Website but not including the Hats & Ladders web application (the “Website”), how we use that information, and what we do to protect it.

Part 1:  Use of Our Products (Service Data)

  • Log In and Authentication

We use Google Sign In (via OpenID Connect) as a secure authentication system that reduces the burden of login for users, by enabling them to sign in with a Google Account, and provides the same standard of security that Google utilizes for Gmail and related products and services. 

  • Information We Collect

We collect information about you when you use our Products. Depending on the Products you use, we may collect:

        • Your contact information such as email address, and the first name and last initial associated with that email address
        • Your month and year of birth, grade level, gender, and zip code
        • Information relevant to college and career counseling, including information about your interests, academic preferences or aptitudes, in-school and extracurricular activities, personal values, obstacles you face, skills, and other career-related preferences and goals
        • Information about your use of and interaction with the Products
        • Information about your academic or career-related activities or projects, including photographs or recordings of activities or projects
        • Your group code 
        • Administrators’ names, titles, and curricular responsibilities
        • Information about Administrators’ use or administration of, or interaction with, our Products
  • How We Store and Retain Information

Hats & Ladders retains the information we gather about you in an effort to make repeat use of our Products more efficient, practical and relevant. We retain the information on data servers using industry standard protocols and technology. You may review or reset your profile information at any time by logging into your account.

Hats & Ladders will retain your personally identifiable information for so long as your account is active or as needed to provide you the Products. We retain your information that is not personally identifiable (for example, aggregate data about the potential careers Users marked as “favorites”) for as long as necessary, in our discretion, to provide our services, operate and improve our Products, and foster a positive, relevant, and personalized user experience. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this agreement.

If the parent or legal guardian of a User under the age of majority wants to review the profile in Hats & Ladders that has been developed by that User or learn more about the Hats & Ladders Product(s) being used by that User, he or she should contact us at the addresses at the bottom of this Privacy Policy.

  • How We Use Information

We use the information we collect to provide our services, operate and improve our Products, and foster a positive, relevant, and personalized user experience. Our Products include the display of personalized content relating to a User’s career experience and interests. As a User, by logging into Hats & Ladders and managing your profile, you have consented for us to use your information in the following ways:

        • To create your personalized map of interests, skills, academic preferences or aptitudes, personal values, obstacles you face, and other career-related preferences and goals;
        • To recommend careers, activities, and next steps in the exploration and pursuit of careers and related aptitudes or skills;
        • To provide access to special content or opportunities (including third party-sponsored content or opportunities) that align to your choices.

We may sometimes post materials from Users on our Website or in other promotional materials. These materials may include User comments, testimonials, and contest results. When we post such material, we limit associated identity information to the applicable school/sponsoring organization, state, and age or grade of user.

Like many Websites and apps, Hats & Ladders uses Google Analytics to analyze how people use our Products. We share information about use of Hats & Ladders with Google for that purpose. Google uses the information we share to deliver and improve its services, including advertising. For more information, including opt-out options, please see Google’s policies (www.google.com/policies/privacy/partners/).

Hats & Ladders may also perform internal research and analysis on aggregated and anonymous Service Data to assess the effectiveness of the Products and make improvements. Hats & Ladders may also publish results of research and analysis of aggregated and anonymous Service Data.

Administrators are provided private user names, passwords, or other identification credentials to access applicable Products and Service Data by Hats & Ladders. These identification credentials allow Administrators to track User progress and assignment completion. Hats & Ladders Products and associated Service Data are not made accessible to anyone other than our employees, contractors, and agents involved in Service development, delivery, and administration and those accessing the Products or associated Service Data using assigned user names and passwords.

Except as directed by the User or (if applicable) the Authorized Institution, Hats & Ladders does not disclose data that is identifiable to an individual to third parties other than our contractors and agents directly involved in the development and delivery of our Products. These contractors and agents who help us manage delivery of our Products and related information handling activities are required to use these data only as needed to perform the specific services they provide and not for any other purpose.

  • Links to Other Websites

In certain of our Products materials we include links to other Websites. This Privacy Policy does not apply to such external links, and we make no representations concerning the privacy policies followed by linked Websites. We urge parents and Administrators to learn more about protecting children on the Internet by visiting the following site: ConnectSafely.org.

  • Children Users and the Children’s Online Privacy Protection Act (“COPPA”)

Hats & Ladders does not solicit and does not knowingly acquire, store, or use personal information relating to children who are less than 13 years of age without verifiable parental consent. As provided for by COPPA, Hats & Ladders relies on Authorized Institutions to obtain parental consent for the online collection of personal information from children who use Hats & Ladders through those Authorized Institutions. If Hats & Ladders learns that personal information of persons less than 13 years of age has been collected without parental consent, then Hats & Ladders will take appropriate steps to delete this information from our systems.

  • Closing Your Account

If you would like to close your account, please contact us by email at info@hatsandaldders.com or by phone at 1.212.463.7559. We will send you an email to confirm that your personally identifiable information has been deleted. We will respond to information access requests within 30 days. If we require additional time, we will acknowledge receipt of your request within 30 days and promptly supplement our response within the time period required by applicable law.

Part 2:  Use of Our Website

Hats & Ladders does not require Website visitors to register and does not solicit personal information as a condition to visit or access general information on our Website. For Users and Administrators who access our Products through the Website, specific terms applicable to collection and use of Service Data are described above, but the following terms also apply to your use of the Website, including access to Products through the Website.

  • Association with Integrated Services

If you decide to share information with Hats & Ladders through a third-party social networking or integrated service (an “Integrated Service”), such as Facebook, you are giving Hats & Ladders the permission to use, share, and store it consistent with this Privacy Policy.

  • Website Use Information Collected

We may collect information about your use of certain Website features to enable us to understand how visitors access and use the Website and to better tailor the content to you and other Website users. In connection with these efforts, we may use various technologies that automatically record certain technical information from your browser or device, including standard log files. The technical information we collect may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, device operating system, and the dates and times that you visit the Website.

Like most Websites, we may send one or more cookies – small text files containing a string of alphanumeric characters – to the device by which you access the Website.

        • Cookies collect and retain information about user activities on a Website. Their use enables us to provide a more personalized experience to visitors, including Users and Administrators who access Products through the Website.
        • Hats & Ladders may use both session cookies and persistent cookies. A session cookie disappears automatically after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. You can, however, remove a persistent cookie at any time. Please review your web browser’s “Help” file or menu to learn the proper way to modify your cookie settings. However, without cookies you may not have access to certain services and features of the Website.

Hats & Ladders may use third-party service providers, such as YouTube to host videos, Google reCAPTCHA to detect misuse of our site forms, or Google Analytics to understand our Website usage. We may allow third-party service providers to place and read their own cookies, web beacons, and similar technologies to collect information through the Website. This information is collected directly and automatically by these third parties, and Hats & Ladders does not participate in these data collections or transmissions. We will, wherever feasible, contractually obligate our third-party service providers to abide by the terms consistent with this Privacy Policy.

We may collect and store information about your location to assess and improve content delivery to you and other Website users in your region. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.

  • Correspondence and Information Requests

Users of the Website may submit comments, questions, and other correspondence, and make requests for information about our Products via the Website. Personal information submitted in connection with such correspondence and requests is treated consistent with this Privacy Policy. If you submit an item of correspondence that includes a testimonial about our Products, we may publish applicable portions of the correspondence for informational or marketing purposes. However, we will not identify the author of such correspondence using personal information provided unless we obtain the author’s consent to do so. For correspondence received from children we believe are under the age of 13, we will not identify them using provided personal information without their parent’s or guardian’s consent.

  • Access and Use of Collected Information

Hats & Ladders permits access to information about Website visitors only to those of our employees, agents, and contractors who have a legitimate operational reason for such access.

Hats & Ladders does not rent or sell personal information that we collect to third parties.

In certain instances, Hats & Ladders may work with business partners to improve our Products and offerings. We may disclose automatically collected technical information and other aggregated anonymized data to authorized business partners to conduct research on educational technology or to assist in understanding the usage, viewing, and demographic patterns for certain Products and/or functionality on the Website.

Hats & Ladders may also disclose Website usage information if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena or warrant, or administrative request. In some cases, we may make such disclosures without first providing notice to applicable Website users.

In the event that Hats & Ladders is acquired by or merged with a third-party entity, we may transfer information that we have collected about Website use as part of such merger, acquisition, sale, or other change of control.

Hats & Ladders may disclose information as we believe in good faith is appropriate or necessary to take precautions against liability; to protect Hats & Ladders from fraudulent, abusive, or unlawful use of Products or the Website; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Website and Products delivery; or to protect the rights, property, or personal safety of Hats & Ladders, our users, or others.

  • Data Security

Hats & Ladders makes reasonable efforts to secure our Website and the information users send to us against unauthorized access and corruption. These efforts include employment of physical, administrative, and technical safeguards based on currently available technology and practices to promote the integrity and security of Website user information we collect.

  • Website Links

The Website may be linked to Websites operated by other entities or individuals. Some of these Websites, such as our Facebook page, may be co-branded with our name or logo. This Privacy Policy does not apply to, and we cannot always control the activities of, such other third-party Websites. You should consult the respective privacy policies of these third-party Websites.

  • International Visitors

Our Website is operated and managed on servers located within the United States. If you choose to use our Website from a Member State of the European Union or another region of the world with laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring your personal information outside of those regions to the United States and that, by providing your personal information on or to the Website, you consent to that transfer.

Changes and Updates to this Privacy Policy

Hats & Ladders may modify or revise this Privacy Policy from time to time, with or without advance notice. In the event there are significant changes in the way we treat your personally identifiable information, or in the Privacy Policy document itself, we will display a notice on the Hats & Ladders Website and web-based application. If you object to any of the changes to our terms, and you no longer wish to use Hats & Ladders, you may close your account. Authorized Institutions that currently license Hats & Ladders will be notified by email of material changes to how we collect and use their Users’ personal information. If you object to any of the changes, and you no longer wish to use Hats & Ladders, you may close your account.

Contacting Hats & Ladders

Please contact Hats & Ladders with any questions or comments about this Privacy Policy by email at info@hatsandladders.com or by mail at: Hats & Ladders, 27 West 20th Street, #501, New York, NY 10011.

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