Last Updated: [4/26/24]

Harpier LLC (“Harpier,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Notice. This Privacy Notice applies to your access and use of our websites, located at harpier.com and [insert web application link] as well as our branded pages on social media services (collectively, the “Site”). This Privacy Notice is incorporated into and is subject to our Terms of Use [harpier.com/terms-of-use](the “Terms”). 

This Privacy Notice only applies to information collected on the Site and is not intended to fully describe our privacy policies. It does not, for example, apply to information collected offline or through any website operated by any third party, even if it is linked to or accessible from the Site. The Privacy Notice describes the information that we gather from you, how we use and disclose your information, and the steps we take to protect your information. By using the Site, you consent to the privacy practices described in this Privacy Notice. 

1. The information that we collect about you and how we collect it: 

We collect several types of information from and about users of the Site, which may include certain “Personal Information” (information that can be associated with a specific person and can be used to identify that person, such as name, e-mail address, mailing address, telephone number, date of birth, financial account information, IP address, information related to educational and career achievements, and other similar types of information), other information that is about you but cannot independently be used to identify you, and information about your internet connection, equipment you use to access the Site and usage details. 

1. Information you provide:

You may provide us with Personal Information when you fill out forms or fields on the Site; when you register for an account; when you participate in online surveys; when you purchase products or services on the Site or when you contact us or request information about us, this Site or our products or services (whether by email or other means).

Your financial information, such as payment method (credit card number and expiration date), is used and stored by our third-party service provider, Stripe (“Payment Processor”), and the use and storage of that information is governed by our Payment Processor’s Terms of Service and Privacy Notice available at [insert URL]. We may from time to time request and receive some of your financial information from our Payment Processor for purposes of completing transactions or protecting against or identifying possible fraudulent transactions.

Some features of our Site allow you to provide content, such as comments or reviews from students and alumni and other content related to users’ experiences. To the extent permitted by local law, all content submitted to us or third parties in connection with your use of the Site may be retained or used by us indefinitely.

2. Information Schools and Districts Provide:

When schools and school districts (“Clients”) use the Site, they submit information necessary to create their school account, including first and last names, ID numbers, email addresses, usernames and passwords for the Clients’ staff who will use the Site

3. Information we automatically collect:

When you visit the Site, or use a third-party website that interacts with our Site, we may automatically receive and record certain information from your computer, web browser or mobile device, including your IP address or other device address or ID, web browser or device type, hardware and software settings and configurations, the web pages or sites that you visit before or after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. 

When you use the Site, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device, to recognize your web browser, help analyze our web page flow, customize our content, measure promotional effectiveness, and promote trust and safety. You are always free to decline our cookies if your browser permits, although doing so may interfere with your ability to use the Site or certain features of the Site. We may also use Google Analytics or a similar service that uses cookies to help us analyze how users use the Site. That use may be subject to the Google Analytics Terms of Use and Google Privacy Policy. Additional information is available here: http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by visiting http://www.google.com/policies/technologies/ads/ or the Google Analytics Opt-out Browser add-on at https://tools.google.com/dlpage/gaoptout/. 

2. How we use the information we collect: 

1. We may use your e-mail address or other Personal Information to contact you (a) for administrative purposes such as account recovery or to notify you of changes to this Privacy Notice or other policies or to our services, (b) to send you promotional materials about our or our affiliates’ or third parties’ services, and/or (c ) to facilitate connections between prospective student applicants and alumni, with their mutual consent. Generally, you can opt out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Site, or by contacting us directly at privacy@harpier.com. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.

2. We generally use the information we collect about you or that you provide to us in order to provide you with information you request from us or to fulfill any other purposes for which you provide such information.

3. We may use Personal Information in any way we may describe to you when you provide such information or for any other purpose with your consent.

4. We may use non-identifying information (including aggregated data) about your use of the Site to understand and analyze the usage trends and preferences of our users, to improve the Site, and to improve fraud detection and information security.

3. When we disclose your information: 

We may disclose aggregated information about our users, and information that cannot independently be used to identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

• To third parties for business or marketing purposes. When possible, we provide this information in an aggregated or de-identified way. 
• To our third-party service providers to provide website development, hosting, data storage, maintenance, credit card processing and other services for us. 
• If required to do so by law or in the good-faith belief that such action is necessary to take precautions against liability; to comply with various reporting obligations; to protect ourselves from fraudulent, abusive, or unlawful uses or activity; to protect the security or integrity of the Site; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to comply with state and federal laws; or in response to a court order, judicial or other government subpoena or warrant.
• To a buyer or other successor in the event of a divestiture, merger, consolidation, or asset sale, whether as a going concern or in the unlikely event of a bankruptcy or similar proceeding.
• In any way we may describe to you when you provide such information, to fulfill any other purposes for which you provide such information or for any other purpose with your consent.

4. Your Choices:

• You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Site. 

• Once you have registered for an account, you may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the Site. 

• If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (except for emails related to the completion of your registration, change of password, your purchase of goods or services, and other communications essential to your transactions through the Site) by using the unsubscribe process at the bottom of the email. Should you opt out, we will promptly honor your request, though we may retain certain information you submit (including in backups or archives) for a variety of purposes, including analytics, the prevention of fraud or abuse and compliance with our legal or regulatory obligations.

5. Our Commitment to Children’s Privacy:

Harpier believes that protecting the privacy of children is especially important and operates in compliance with the Children’s Online Privacy Protection Act (COPPA). The Site is not directed to children under 13. Users under 13 years of age are required to gain the consent of a parent or guardian to use the site. COPPA requires us to inform parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information

This section notifies parents of:

• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
• All operators that collect or maintain information from children through the Site.

This section of this Privacy Notice only applies to children under the age of 13.

1. Information We Collect from Children

Children can access many parts of the Site and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the site. 

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. 

2. Information We Collect Directly

A child must provide us with the following information to register with this website: the child’s first name, birth date, and a parent’s email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.

We enable registered users to communicate with others on or through this Website/Service through chat, email, and posting to public areas of the Site/Service (“Social Features”). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.

3. Automatic Information Collection and Tracking

We use technology to automatically collect information from our users, including children, when they access and navigate through the Site and use certain of its features. The information we collect through these technologies may include: 

• One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services
• Information that identifies a device’s location (geolocation information).

We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online. 

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Information we automatically collect” and “When We Disclose Your Information” sections of this Privacy Notice.

4. How We Use Your Child’s Information

We use the personal information we collect from your child to: 

• register him or her with the Site
• communicate with him or her about activities or features of the Site that may be of interest;
• track his or her performance in games or other activities

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve the Site and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about the child’s preferences, allowing us to customize the content according to individual interests.
• Speed up your child’s searches.

5. Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children’s personal information:

• To third parties we use to support the internal operations of the Site and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers or others, including to:

  • protect the safety of a child;
  • protect the safety and security of the Site; or
  • enable us to take precautions against liability.

• To law enforcement agencies or for an investigation related to public safety.

If Harpier is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Harpier’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

6. Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information. 

You can review, change, or delete your child’s personal information by:

• Logging into your child’s account and visiting the account profile page.
• Sending us an email at privacy@harpier.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

If you are a parent or guardian and discover that your child under 13 years of age has provided us with information, please alert us at privacy@harpier.com. 

6. Our Commitment to Data Security:

We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your Personal Information. Physical safeguards include not writing down master passwords or printing out user information. Managerial safeguards include not providing employees with access to user data, unless strictly necessary for their job. Technical safeguards include requiring a sufficiently complex password to access user data. However, no security measures are perfect or impenetrable, so we cannot ensure or warrant the security of any information you transmit to us through the Site, and you do so at your own risk. We also cannot guarantee that your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.

7. Visitors from Outside the United States:

This Site is controlled and operated by Harpier LLC in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary, to provide to you the products and services available through the Site. Where required, we comply with applicable legal frameworks relating to the collection, storage, use, and transfer of personal information.

8. Limitation of Liability:

By accessing this Site and/or providing us with Personal Information and other data, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of such information. In addition, while we take efforts to ensure the proper and appropriate use of data by our service providers that may receive your information from us, we are not responsible for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers.

9. Changes and Updates to this Privacy Notice:

We reserve the right to make changes to this Privacy Notice at any time. We will notify you via email about significant changes in the way we treat your information, including by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Notice.

10. Do Not Track Disclosures

Third parties such as advertising networks, analytics providers, and widget providers may collect information about your online activities over time and across different websites when you access or use our services. Currently, various browsers offer a “Do Not Track” option, but there is no standard for how “Do Not Track” should work on commercial websites. Due to lack of such standards, the Site does not respond to Do Not Track consumer browser settings.

11. Our Contact Information:

Please contact us with any questions or comments about this Privacy Policy Officer by e-mail at privacy@harpier.com.