Your privacy is important to us. It is Homeroom Detroit’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://homeroomdetroit.com, and other sites we own and operate.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, e-mail address and date of birth), your devices and even information about how you use a website or online service.
This policy is effective as of 21 July 2022.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. The legal ground can be your explicit consent, our legitimate interest balanced to your privacy rights or the necessary data collection and processing to provide our services to you. We also may fall under the legal obligation to provide the data to public authorities in which case we make sure they have sufficient grounds and authorization to request such data.
Legal grounds are described in more details in the section “(GDPR) Compliance” of this policy.
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.
“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
- Device Type
- Operating System
- Geo-location data
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information — for example, when you register an account, submit content to us or when you contact us — which may include one or more of the following:
- Social media profiles
- Date of birth
- Answers to questionnaires and surveys generated by us
- Communication between you and us (e-mail, chat)
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you decide to add any above mentioned data to any of our free text fields, you acknowledge that you are doing this entirely on your own decision and responsibility. Such random data processing does not constitute as systematic processing to provide our services.
We consider “user-generated content” to be materials (text, image and/or video content) voluntarily supplied to us by our users for the purpose of publication on our website or re-publishing on our social media channels. All user-generated content is associated with the account or email address used to submit the materials.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
- Register for an account
- Sign up to receive updates from us via email or social media channels
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- Give feedback to our services
- When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to provide you with our platform’s core features and services
- to enable you to customize or personalize your experience of our website
- to contact and communicate with you
- for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you and you have given us such consent
- to enable you to access and use our website, associated applications, and associated social media platforms
- for internal record keeping and administrative purposes
- for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms
Aggregated Data: We may also collect, use and share aggregated data such as statistical or demographic data for any purpose related to our services. Aggregated data may be derived from your personal data, but once in aggregated form it will not constitute personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
For more details, please contact us.
We do not aim any of our products or services directly at children under the age of 16, and we do not knowingly collect personal information about children under 16.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- a parent, subsidiary, or affiliate of our company to manage our services
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities to deliver the services
- our existing or potential agents or business partners
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you if you have given us consent
- an entity that buys, or to which we transfer all or substantially all of our assets and business
Third parties we currently use include:
- Amazon Web Services Inc. (EU/EEA)
- Google Analytics (USA)
- Hotjar (USA)
- Google Adsense (USA)
- hCaptcha (USA)
International Transfers of Personal Information
The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.
We share our usage reports (including user feedback, geographical region and demographic analytics, engagement and return metrics) collected with Google Tag Manager and cookies with third parties involved in co-developing the service. Your personalized questionnaires or profiles are not shared with these third parties. We share only the data and reports of our services in an aggregated way for service innovation purposes.
Your Rights and Controlling Your Personal Information
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Downloading of Personal Information: We provide a means for you to download the personal information you have shared through our site. Please contact us for more information.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on the preferences you have specified.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt-out of, as applicable, any new uses of your personal information.
For any questions or concerns regarding your privacy, you may contact us at [email protected]
Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)
Data Controller / Data Processor
The GDPR distinguishes between organizations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We are a data controller with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You
Performance of a Contract
Where you have entered into a contract with us (Terms of Service), or in order to take preparatory steps prior to our entering into a contract with you. For example, if you contact us with an inquiry, we may require personal information such as your name and contact details in order to respond. We also need certain data to provide the service as we have described it. For example, account registration and services and activities carried out under your account.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests. Our legitimate interest is always balanced with your privacy rights.
Compliance with Law
Your Rights and Controlling Your Personal Information
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: : You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
Additional Disclosures for California Compliance (US)
Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.
Cookies and Pixels
At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities.