Privacy Policy

Updated: 10/20/21 

This Privacy Policy (the “Privacy Policy”) governs your use of the wethinkinc.us website and any of our other websites on which a link to this Privacy Policy appears (collectively, the “Site”), and any services, content and resources available or enabled via the Site (collectively with the Site, the “weThink Services”). Through the weThink Services, weThink, Inc., (“weThink,” “we,” “us,” or “our”) provides a platform for students, parents, coaches, educational institutions and others to develop, assess and track essential life skills like problem solving and leadership.  This Privacy Policy describes how weThink handles personal information that we collect through the weThink Services.  In addition, this Privacy Policy applies to personal information that we obtain through our social media sites, marketing activities, live events and other activities described in this Privacy Policy. 

weThink may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

While this Privacy Policy applies to information that we process in connection with providing the weThink Services to a Sponsoring Organization (as defined below), our relationship with such Sponsoring Organization may be governed by a relevant Sponsoring Organization agreement or other applicable legal requirements.  In such circumstances, the relevant Sponsoring Organization agreement or other applicable legal requirements may restrict our collection, use, disclosure, and other processing of your personal information. If you have questions with respect to personal information that we process in the context of a Sponsoring Organization agreement or relationship, you should direct them to the relevant Sponsoring Organization. For the avoidance of doubt, this Privacy Policy applies to personal information that we process in connection with any Performer (as defined below) accounts that are maintained independent of, or that are continued post-termination of, any agreement with a Sponsoring Organization.

Index

Defined terms

             Personal information we collect

             How we use your personal information

             Tracking Technologies

             How we share your personal information

             Your choices

             Other sites and services

             Security

             International data transfer

             Children

             Changes to this Privacy Policy

             How to contact us

 

Defined terms

Capitalized terms not otherwise defined in this Privacy Policy shall have the following definitions:

  • Performer means any individual weThink Platform end user (for example, students, sports team members, or similar individual).
  • Sponsoring Organization means any school district, school, sports organization or other governmental entity, business, organization or entity to whom we provide the weThink Services pursuant to a Sponsoring Organization agreement or purchase order. 
  • Administrator means any weThink Services user that has administrative privileges in connection with her or his use of the weThink Services (for example, teachers, managers, school leaders or aides, coaches, or similar individuals) and that maintains control over access to a Sponsoring Organization account (for example, by adding and/or removing Performers).
  • Guardian means any individual granted access to a Performer’s account through such Performer’s Sponsoring Organization.
  • You, your, yours refers to any individual to whom this Privacy Policy applies.

 

Personal information we collect

Information you provide to us.  Personal information you may provide to us through the weThink Services or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title, organization name, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Account data, such as the username and password that you may set to establish an online account on the weThink Services, biographical details, photograph, age and any other information that you add to your account profile. 
  • Performer data, such as survey responses, skill assessments (including self-assessments and assessments of other Performers), rankings and ratings, areas for improvement or development, and other data related to a Performer’s interaction with the weThink Services, including participation in interactive experiences.
  • Administrator data, such as data related to survey creation and assignment, notes and feedback regarding Performers, responses to surveys, assessments of Performers, data related to the creation of Performer teams and spaces, and data related to the relationships with and among Administrators, spaces, teams and individual Performers.
  • Communications data based on our exchanges with you, including when you contact us through the weThink Services, social media, or otherwise.
  • Transactional data, such as information relating to or needed to complete your orders on or through the weThink Services, including order numbers, transaction history and payment information such as payment card information or bank account number.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • weThink Platform data, such as help center data (including content to assist with using the weThink Services), example lessons that Performers, Administrators and others can post, rank or download for use, and other informational data designed to help individuals use or improve their experience with the weThink Services.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

·Third Party Accounts, such as Google and Microsoft when you use your Google ID or Microsoft ID to set up or log into an account using single sign on (“SSO”). If you choose to login to the Service via a third-party platform, or otherwise connect your account on the third-party platform to your account through the Service, we may collect information from that platform. For example, this information may include your username, user ID, profile picture, cover photo, and networks to which you belong (for example, school, workplace, etc.).

·Public sources, such as government agencies, public records, and other publicly available sources.

  • Private sources, such as data providers/data licensors, social media platforms and other similar private sources.

·Marketing partners, such as joint marketing partners and event co-sponsors.

 

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the weThink Services, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the weThink Services, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Location data when you visit the wethinkinc.us website.

For more information concerning our automatic collection of data, please see the Tracking Technologies section below.

Other Service Administrators and Performers.  As we designed the weThink Services to be interactive, we may collect personal information about you from other weThink Services Administrators and Performers.  

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection. As we described previously, this Privacy Policy addresses our use of your personal information where such personal information is under our control.  We may be restricted in our use of your personal information where such information is subject (contractually or otherwise) to the direction of our Sponsoring Organizations.

Service delivery.  We may use your personal information to:

  • provide, operate and improve the weThink Services and our business;
  • establish and maintain your user profile on the weThink Services;
  • enable security features of the weThink Services, such as by remembering devices from which you have previously logged in;
  • communicate with you about the weThink Services, including by sending announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the weThink Services and our communications; and
  • provide support for the weThink Services, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the weThink Services and our business. 

Marketing and advertising.  We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes. To the extent we engage in direct marketing, you may opt-out of our marketing communications as described in the Opt-out of marketing section, below. Our third-party advertising partners may also use tracking technologies to collect information about your interaction with the weThink Services, our communications and other online services over time (described further in the Tracking Technologies section, below), and may use that information to serve online ads that they think will interest you or similar users, whether on our site or other online platforms (known as “interest-based advertising”).

Compliance and protection.  We may use your personal information to:

·comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

·protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

·audit our internal processes for compliance with legal and contractual requirements or our internal policies;

·enforce the terms and conditions that govern the weThink Services; and

·prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the weThink Services and promote our business.  

Tracking Technologies

Some of the automatic collection described above in the personal information we collect section, above, is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
  • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

 

For information concerning your choices with respect to the use of tracking technologies, see the your choices section, below.

 

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  As we described previously, this Privacy Policy addresses our sharing of your personal information where such personal information is under our control. We may be restricted in our sharing of your personal information where such information is subject to the direction of (whether contractually or otherwise) our Sponsoring Organizations.

Service providers.  Third parties that provide services on our behalf or help us operate the weThink Services or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Third parties designated by you. Third parties where you have instructed us or provided your consent to do so in accordance with, and as necessary to comply with, such instructions or consent.

Linked third-party services. If you have enabled features or functionality that connect the weThink Services to a third-party platform or social media network (such as by logging in to the weThink Services using your account with the third-party, providing your API key or similar access token for the weThink Services to a third party, or otherwise linking your account with the weThink Services to a third party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations of or due diligence with respect to such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, weThink or our affiliates (including, in connection with a bankruptcy or similar proceedings). 

Sponsoring Organization.  If you use the weThink Services through or in connection with our relationship with a Sponsoring Organization, we may disclose your personal information to the relevant Sponsoring Organization.  We do not control how the relevant Sponsoring Organization may use your personal information.

Other Administrators and Performers.  Certain content you post via the weThink Services, such as on the website, may be visible to other users (specifically, Administrators and Performers within a shared sponsoring organization) of the weThink Services.

Your choices

The following choices may be available to you with respect to personal information subject to this Privacy Policy. Your choices, however, may be limited if you use the weThink Services through a Sponsoring Organization as our agreement with the relevant Sponsoring Organization or other applicable legal requirements may limit our ability to afford you the choices listed below. 

Access or update your information. If you have registered for an account with us through the weThink Services, you may review and update certain account information by logging into the account.

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Cookies & advertising choices. Your options for controlling what information cookies and similar technologies collect about you may include:

  • Blocking cookies in your browser.  Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the weThink Services may not work properly.  For more information about cookies, including how to manage and delete cookies on your device, visit www.allaboutcookies.org.  If you do not accept our cookies, you may experience some inconvenience in your use of the weThink Services. For example, we may not be able to recognize your computer and you may need to log in every time you use the weThink Services.

·Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins, you may be able to block certain tracking technologies.

  • Third-party opt-out option.  You can opt-out of interest-based advertising through certain third parties by using such third-party’s opt-out tool. For example, you can prevent the use of Google Analytics relating to your use of the weThink Services by downloading and installing a browser plugin available here.
  • Industry association opt-outs.   You may opt out of receiving interest-based advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms linked above.

You will need to apply these opt-out settings on each device and browser from which you wish to opt-out. 

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-party platforms. If you choose to connect to the weThink Services through a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close or transfer your account. You can choose to delete certain content through your account.  In certain circumstances, and subject to any contractual obligations we may have to Sponsoring Organizations, you (or a Guardian acting on your behalf) may also request the transfer of your account. If you wish to request to close your account, please contact us.

 

Other sites and services

The weThink Services may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Children’s Privacy – COPPA

We support the guidelines and regulatory requirements provided in COPPA.  We do not knowingly collect any information from children under the age of 13 unless and until the relevant institution has provided consent and authorization for a student under 13 to use the products and services and for us to collect information from such student. Where a customer institution instructs us to collect personal information from children under the age of 13, we collect, use, process and retain such information solely to provide the services on behalf of the customer and for the purposes set forth in our agreement with the customer. We collect only as much information as is necessary to provide the service and the customer may access, delete or withdraw consent for continued processing of the child’s information at any time. If you have any questions about reviewing, modifying, or deleting personal information of a child under the age of 13, please contact your educational institution directly.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the weThink Services or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the weThink Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

  •         Email: privacy@wethinkinc.us