Notice:

4. Personal Information We Collect

In Short: Depending on your relationship with GoGira!, we collect personal information depending on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Information is collected automatically, from third-party sources, and provided directly by you.

Personal Information Automatically Collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Services.

We and/or our trusted partners (i.e. school, career, higher education, and financial-aid services, businesses, and content providers) may automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring Uniform Resource Locators (“URLs”), device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we and our trusted partners may also collect information through cookies and similar technologies.

• Log and Usage Data. 
  Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log and usage data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. 
  We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Geolocation Data. GoGira! utilizes your device's geolocation data to enhance certain location-based features, such as providing school, and partner recommendations, and on occasion in-app advertisements relevant to your geographical preferences. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). We may share your geolocation with service providers to improve our Services. You can opt out of allowing us to collect this information either by refusing access to the information at the in-app Privacy Controls Settings or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.
• Preferences and Engagement with our emails, text messages, push notifications, and online messages.
• Collection of Contacts Information. With your consent, we collect contact details from your phone and social networks when you choose to invite or share with others. This includes names, phone numbers, email addresses from your phone contacts, and public profile information along with names and profiles of your social network contacts.
• Data Minimization (relevant under Maryland new laws): We strive to collect only the personal information that is reasonably necessary and proportionate to provide or maintain the requested product or service, or as otherwise permitted by law.
• Details from interactions with our support services, like contact dates, chat transcripts, call details, and phone numbers.
• Unique identifiers for your devices and network, including resettable advertising identifiers.
• Device and software specifications, connection types, page view statistics, referral sources, IP addresses, and general location data.
• Data is collected through cookies, web beacons, and similar technologies, including advertising delivery data. (Refer to the "Privacy Controls and Rights on GoGira!” section)
• When allowed by law and with your consent, we and our partners may automatically collect information about your device, browser, and activities on our Properties. This includes details like your operating system, device model, device identifiers, browser type, screen resolution, IP address, general location, and your interactions with our Properties such as page views, navigation patterns, session duration, and access times. This data may be gathered over time across different sites and apps by our business partners, using cookies and similar tracking technologies.
• Links to our pages on social media platforms. By interacting with our social media pages, you are subject to the respective platform's privacy policy. This may involve the sharing of your information such as name, profile, photos, and engagement activities (like reactions and comments) with us. Any information received through these platforms is processed according to this Privacy Policy and the platform’s privacy regulations.

Personal Information Collected from Other Sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and Services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or X ), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

Personal Information You Provide to Us Dependent on Your Relationship With Us:

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

GoGira! Site Visitor:

If you access or interact with the GoGira! websites, apps, or platforms without registering for a GoGira! account, logging into an existing account, or revealing your association with a GoGira! account, you are considered a "GoGira! Site Visitor." This includes instances where you browse our Services or access content without engaging directly, or without utilizing our Services.

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, phone number, email address, and any additional information or details you provide, including feedback, reviews, and comments.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • Information revealing race or ethnic origin
  • Information revealing religious or philosophical beliefs
  • Student data
  • Financial data
• Protected Classification Characteristics under California or Federal Law. In compliance with California and federal law, we collect certain protected characteristics such as your age, gender identity, marital status, military status, residency, income level, ethnicity, religion, and philosophical preferences.

Student Registrants:

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, phone number, email address, and any additional information or details you provide, including feedback, reviews, and comments.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information including information revealing race or ethnic origin, information revealing religious or philosophical beliefs, student data, and financial data.
• Protected Classification Characteristics under California or Federal Law. In compliance with California and federal law, we collect certain protected characteristics such as your age, gender identity, marital status, military status, residency, income level, ethnicity, religion, and philosophical preferences.
• California Customer Records Personal Information We collect information as defined by the California Customer Records provisions, including your name, address, telephone number, and the last four digits of your payment number. This information is used for processing subscription purchases and may overlap with other data categories.
• When you register an account, we may collect basic account student information including name, communication preferences, email address, addresses, phone numbers, date of birth, educational status and plans, gender, ethnicity, permissions, mailing addresses, job titles, usernames, contact preferences, contact or authentication data, grade or educational level, parent and guardian information.
• When creating a student profile, we may collect additional details beyond your basic student information including profile statuses, academic status, residency status, avatar, financial status, references, resumes, portfolios, and any uploaded content, feedback, service interactions, preferences, and responses to forms.
• Payment Data. We may collect data necessary to process your payment if you make purchases or subscriptions, such as your payment instrument (e.g., credit card) and billing information.

Parent or Guardian:

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, phone number, email address, and any additional information or details you provide, including feedback, reviews, and comments.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive information including information revealing race or ethnic origin, information revealing religious or philosophical beliefs, student data, and financial data.
• California Customer Records Personal Information We collect information as defined by the California Customer Records provisions, including your name, address, telephone number, and the last four digits of your payment number. This information is used for processing subscription purchases and may overlap with other data categories.
• When you register an account, we collect your relationship to the student, your email address, phone number, and permissions; and basic account student information including name, communication preferences, email address, addresses, phone numbers, date of birth, educational status and plans, gender, ethnicity, permissions, mailing addresses, job titles, contact preferences, contact or authentication data, grade or educational level, parent and guardian information.
• When accessing or supporting a student profile, we may collect additional details beyond your student’s basic information including academic status, residency status, avatar, financial status, references, resumes, portfolios, and any uploaded content, feedback, service interactions and preferences, or responses to forms.
• Payment Data. We may collect data necessary to process your payment if you make purchases or subscriptions, such as your payment instrument (e.g., credit card) and billing information.

Higher Education Personnel:

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, phone number, email address, and any additional information or details you provide, including feedback, reviews, and comments.
• California Customer Records Personal InformationWe collect information as defined by the California Customer Records provisions, including your name, address, telephone number, and the last four digits of your payment number. This information is used for processing subscription purchases and may overlap with other data categories.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may collect data necessary to process your payment if you make purchases or subscriptions, such as your payment instrument (e.g., credit card) and billing information.

When you register an account to use GoGira! to review student profiles and identify possible connections or matches for your higher education entity, we collect verifiable institutional information, higher education associations, names, email addresses, contacts, business addresses, phone numbers, titles, roles, permissions, identification or authentication data.

Partner Professionals and Counselors:

Partner Professionals and Counselors include tutors, school counselors, higher education, career, and financial-aid-related services, and/or content providers are users who have registered on GoGira! to connect, match, and/or recruit students to their services. They access GoGira! and/or websites when logged into their accounts. If you represent a trusted Partner Professional on GoGira!, we may gather and show information related to your organization's activities. This might include your entity's name, which could incorporate your name and a publicly available professional address and description of Services. Additionally, we may collect and display information about your professional background that you choose to share with us through the Service. This could include details about your professional licenses or certifications, as well as your professional history or specialties.

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, phone number, email address, and any additional information or details you provide, including feedback, reviews, and comments.
• California Customer Records Personal Information. We collect information as defined by the California Customer Records provisions, including your name, address, telephone number, and the last four digits of your payment number. This information is used for processing subscription purchases and may overlap with other data categories.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may collect data necessary to process your payment if you make purchases or subscriptions, such as your payment instrument (e.g., credit card) and billing information.
• When you register an account to use GoGira! to review student profiles and identify possible connections or matches for your partner entity we collect verifiable entity information, professional associations, names, email addresses, contacts, business addresses, phone numbers, titles, roles, permissions, identification or authentication data.

References:

If a student invites you to submit a reference on their behalf, we collect the following personal information from you:

• Identifiers. When you contact us through our support services, contact form, or email, we collect details like your name, contact dates, chat transcripts, email address, Position/Title, Institution or Organization, and any additional information or details you provide, including feedback, reviews, and comments.
• California Customer Records Personal Information. We collect information as defined by the California Customer Records provisions, including your name and email address. This information is used for processing references and may overlap with other data categories.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive information including information revealing student reference reviews, feedback, and data.

Affiliates:

An Affiliate is a business, individual, or entity applying to or participating in the GoGira! Affiliate Program or that displays GoGira! Services and/or promotions on an Affiliate Site, or other means, using an affiliate tracking code in exchange for receiving commission from GoGira! for sales directly resulting from such promotions.

• Identifiers. When you apply or register to become a GoGira! affiliate, we collect details like your name, website, social media URLs, title/role, contact dates, chat transcripts, and email address, business information such as business/entity name, industry, audience, entity tax information, and any additional information or details you provide, including background information, feedback, reviews, and comments.
• California Customer Records Personal Information We collect information as defined by the California Customer Records provisions, including your name, phone, address, identification, and email address. This information is used for processing references and may overlap with other data categories.
• Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information including tax identification, driver’s license, state or government ID cards, financial banking account information, credit card number, background information, geolocation, and identification or authentication data.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by emailing us at Support@GoGira.com.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described:
  • § Send users information about special offers and discounts on our products and Services
  • § Develop and display personalized and relevant advertising content for our users
  • § Analyze how our Services are used so we can improve them to engage and retain users
  • § Support our marketing activities
  • § Diagnose problems and/or prevent fraudulent activities
  • § Understand how our users use our products and Services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by emailing us at Support@GoGira.com.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including but not limited to, the following examples:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations, fraud detection, and prevention.
• For business transactions provided certain conditions are met.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• For identifying injured, ill, or deceased persons and communicating with next of kin.
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the information is publicly available and is specified by the regulations.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

We collect and share your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
• Social media plugins

We use social media features, such as a "Like" button, and widgets, such as a "Share" button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded on your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers according to a written contract between us and each service provider.

We may use your personal information for our business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be the "selling" of your personal information.

European Economic Area, United Kingdom, Switzerland, and Canada Users

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by emailing us at email Support@GoGira.com.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to yourMember State data protection authority  or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our Services, in particular:

• Offer you the products or services that you want
• Respond to or help with your requests
• Manage your account with us
• Confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by email at Support@GoGira.com.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to theOffice of the Australian Information Commissioner  and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by email at Support@GoGira.com.

If you are unsatisfied with how we address any complaint concerning our processing of personal information, you can contact the office of the regulator, the details of which are:

• The Information Regulator (South Africa)
• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za  and POPIAComplaints@inforegulator.org.za