This Privacy Policy describes the types of information gathered by Local Impact Inc. (“Local Impact”, Local Civics”, “us” or “we”) in the process of providing https://www.localcivics.io/ (the “Site”), the computing application (the “App”) and software tools, and the associated data, services, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy.

Please also refer to our Terms of Service at https://www.localcivics.io/terms-of-service, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service. This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Last updated” date above to see when this Policy was last updated.

Territoriality

‍‍Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

‍Information Collected

‍‍We collect two types of information about persons who use the Service: Personal Information and Non-Personal Information. “Personal Information” is information that is personally identifiable to you, such as your name, address, email address or phone number, as well as other non-public information that is associated with the foregoing. Anything you publicly post or that is available publicly will not be considered Personal Information, and will be outside the restrictions of this policy. “Non-Personal Information” means information that is not associated with or linked to your Personal Information. We may create Non-Personal Information from (i) automatically gathered information or (ii) Personal Information by excluding information (such as name) that may make the information personally identifiable to you.

Personal Information Collected

‍‍We collect certain Personal Information about you, which may be supplied from the school/organization that you, or your child are affiliated with, when you sign-up for the Service, when you complete a survey, when you create or update an account, when you use the Service, when you request services, or otherwise when you submit such information. The information that may be collected includes: Name; Username; Email address; First-party cookies; Third-party cookies; Location data; Browser and operating system information; and Device information. You may provide us information when you interact with us through email, online chat, or otherwise. We may retain such information in order to provide you with services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service. You are not required to provide any personal information in your profile page in order to use the Service. If you choose to add personal information, or materials containing personal information, to your profile, Local Impact will not be responsible for such materials/information and you do so at your own risk. The Service may access the internet or use your mobile data plan in order to use certain features of the Service.

‍Non-Personal Information

‍‍Non-Personal Information is collected about you when you use the Service, including but not limited to the type of device you used and its browser and operating system information, the pages accessed most frequently, how pages are used, previous page and referring page URLs, and similar non-personal data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize user agent strings, web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. If non-personal information is paired to any of your Personal Information, we will treat the non-personal information as if it was Personal Information too. Although it may be possible to turn off the collection of cookies through your device, that may interfere with your use of the Service.

‍Use of Information/Internal Use of Information

‍‍Local Civics does not sell or rent any of your, or your child's personal information to any third party for any purpose - including for advertising or marketing purposes. We accept and gather information in an effort to provide the Service to you. We may also use this information to help us develop and improve our Service and other offerings, fulfill your requests, track usage trends, conduct experiments and perform research and analytics, communicate with you regarding administrative matters, send materials to you, tailor our Service and offerings to meet your interests and those of others, and for other purposes permitted by law. We may use anonymous, aggregate information, of which your information may be a part, without restriction.

Sharing Information Collected with Third Parties, Consultants, & Affiliates

We may share your information, including personal information, with our business associates, consultants, service providers, advisors and affiliates in order for them to provide services to us, to you, and to enable us to provide the Service. For example, our host and internet service provider may have access to this information. If you use the Service to interact with other users, your information may be shared with those other users and will also be accessible by us. We identify users and their profile pages to other users on the platform, and any information you, as a user, post to those pages will be shared with other users. We may also share information, including specific user engagement and event attendance data which may include personal information, with the approved officials/administrators of the school/ organization with which you or your child are affiliated. Further, we may disclose collected information to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim or otherwise as permitted by applicable law. We may disclose any information in our possession in the event that we believe it necessary or appropriate to prevent criminal or illegal activity, personal injury, property damage or bodily harm. Additionally, we may transfer your information to successor in interest, which may include but may not be limited to a third-party in connection with, or as the result of, of an acquisition, sale, asset sale, merger, reorganization or bankruptcy involving our company. You hereby acknowledge that necessity and legitimate interests that we have in disclosing information as described in this privacy policy and hereby consent to such sharing and disclosures. Other than as described herein, we shall only use or disclose information with your consent, or as permitted/required by the contract between Local Impact and your/your child’s school/organization, if applicable. Such consent may be requested by and/or provided through the relevant school/organization.

How Do We Use Cookies & Other Network Technologies?

To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies. Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.
Local Impact or its service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some of our Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our site.

Links

Our Service may contain links to other websites. We are not responsible for the privacy practices of such other sites. When you leave our Service to visit another website or application, please read the privacy statements of websites that may collect personally identifiable information. This Privacy Policy applies solely to information collected by us through the Service.

‍Storing & Securing

If you are visiting the Site or otherwise using the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA. We will store and use your personal information until the earlier of your request that we delete it, or the completion of the purpose for which it was collected, unless we have to keep it in order to comply with applicable law(s) or regulation(s). To the extent possible, we will delete the information within thirty (30) days of the triggering event. Any information which has been automatically logged, backed-up, or archived shall be segregated without use/access until it can be deleted in line with our document retention procedures. We employ procedural and technical safeguards to secure your personal information against loss, theft, alteration, and unauthorized access, use and disclosure, including but not limited to encryption (at rest and in transit via https protocol, passwords, and a firewall). We also employ security procedures to protect your information from unauthorized access by users inside and outside the company. Regardless of the precautions we take, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, we cannot ensure or warrant the security of any information you transmit to us.

‍Access & Control

User profile and contact information will be retrievable through the Service. Some other information collected about you may be retrievable through your username login. To retrieve your information, follow the instructions on the Service. Users that do not have an account/profile with us, may make a similar request by emailing us at info@localcivics.io.

‍Communication Tools

‍The Service may contain tools that enable you to share personal information, including sensitive information, with others on the Service. Should you choose to use such tools, please exercise caution when sharing sensitive information.

‍Do Not Track

‍At this time, the Service does not specifically respond to browser do-not-track signals.

Parental Consent & Children’s Privacy

‍We do not knowingly permit users to register for our Service if they are under 13 years old in compliance with the requirements of the Children's Online Privacy Protection Act (COPPA). Children under 13 are unable to create their own Local Civics accounts. In order for a child under 13 to be able to create a Local Civics account, consent must be provided by the child’s parent, guardian, school, or school district in accordance with the provisions of COPPA, Federal Education Rights and Privacy Act (“FERPA”), and contractual language specified in service agreements with Local Civics’ partner schools and districts. A parent's or school's consent is required for the collection, use, or disclosure of personal information from children, and we will not collect, use or disclose any such personal information without such consent.

In the event that we discover that a child under the age of 13 has provided personally identifiable information to us without consent from a parent, guardian, school, or school district, we will make efforts to delete the child’s information or immediately obtain parental consent for that data collection in accordance with the Children's Online Privacy Protection Act. Please see the Federal Trade Commission's website for (www.ftc.gov) for more information.

If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us without your approval, please inform us by contacting us at the email address below and we will delete such information from our database. You also have the right to review information your child has provided to us. To exercise these rights, please email us at info@localcivics.io with “COPPA Request” in the subject line.

In accordance with the “direct control” provisions of FERPA, Local Civics’ partner schools and districts can provide consent for the disclosure of non-personally identifiable student information under the “school official” and “educational purposes” provisions language

Partner schools and districts are responsible for directly obtaining any necessary consent from parents or through applicable FERPA and COPPA provisions language that permit schools or districts to act as agents on behalf of their students for consent purposes.

In addition to the information listed above, we automatically collect some information from any use of our Service as set forth in the “Information Collected” section. We use this information to provide the Service to the child, for security and safety purposes, as required by law, or to enforce our Terms. We will not require children to provide more personal information than is reasonably necessary in order to participate in the Service.

We do not disclose any personal information about children to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other users. Information collected from students (including personal information and information collected automatically) is never used or disclosed for third party advertising or for any first- or third-party behaviorally targeted advertising, and children’s personal information is never sold or rented to anyone, including marketers or advertisers.

‍School Information

‍The Family Educational Rights and Privacy Act (FERPA) is a US federal law that protects the privacy of students’ education records, including personally identifiable and directory information. FERPA was enacted to ensure that parents and students age 18 and older can access those records, request changes to them, and control the disclosure of information, except in specific and limited cases where FERPA allows for disclosure without consent. Under FERPA parents/guardians, or if applicable, the eligible students (18 years or older) have the ability to review/inspect, and/or amend/correct, student record information that may be in our possession or under our control. To exercise these rights, please email us at info@localcivics.io with “FERPA Request” in the subject line.

California Privacy Rights

‍California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at info@localcivics.io with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

‍Contact Information

‍If you have any questions or suggestions regarding our Privacy Policy, you may contact us in writing at Local Impact Inc. dba Local Civics, 2196 Third Avenue, Unit 10094, New York, NY, 10035 or via email at info@localcivics.io.

‍Governing Law

You agree that your use of this Privacy Policy and any disputes relating thereto shall be governed in all respects by the laws of the State of New York. Any dispute relating to this Privacy Policy shall be resolved solely in the state or federal courts located in Manhattan, New York. This privacy policy was last updated January 17, 2024.