Last Updated: November 14, 2022
This website is owned and operated by a New York limited liability company operating under the brand name the Eureka Program (“the Eureka Program”, "Company", "We", "Us", "Our"). The Eureka Program is committed to providing quality service to you, and as part of that commitment, we take your privacy seriously and are committed to the responsible handling of personal information. This privacy statement discloses our practices regarding the information we collect and how we use your information.
What information do we collect?
Personal Information you Disclose to us
The Eureka Program receives, collects, and stores any personal information you voluntarily provide to us when you express an interest in obtaining information about us or our services. This includes when you subscribe to our emails, complete an inquiry form, complete an application form, or contact us with feedback or questions. Personal information that we collect may include:
Identity Data: Information that identifies you, which includes your First Name, Last Name, Gender, Age, School Details, and other similar identifiers
Communication Data: Information to get in contact with you, which includes your address, email address, telephone numbers, social media usernames, and other communication data
Marketing Data: Information such as your preference for receiving our marketing communications, and details about your engagements with them.
Information Automatically Collected
When you interact with our website, we may collect information automatically through monitoring tools. This information is collected to help us understand how our users interact and use our website. This information does not reveal your specific identity, such as 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 URLs, device name, country, location, information about how and when you use our Services, and other technical information. Please refer to the section below for further explanation. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Here is some information on what data may be automatically collected from you when using our website and some of the technologies we use.
When you use our website, technical data such as your internet protocol (IP) address, location data, device, and browser information may be collected. We use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.
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 Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website 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.
We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. 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.
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 Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Cookies and Similar Tracking Technologies
In addition, most browser settings allow you to delete and/or reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Internet-based marketing and remarketing tools
How we collect your information
Much of the personal information we collect is collected directly from you using our website. Personal information is collected from you when:
● You subscribe to our emails
● You register for events and online courses
● You Engage with us through email, phone, or social media
● Enter a competition, promotion, contest, or survey
● You complete an Inquiry Form
● You complete an application form on our website
● You contact us directly with feedback or questions
● You enter your payment details to complete a purchase
We process your personal information for a variety of reasons, depending on how you interact with our services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
What Legal Bases Do We Rely On To Process Your Information?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
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 in order 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 given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
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 prior to entering into a contract with you.
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 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.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and 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 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
Information from Third Parties
The Eureka Program may at times obtain personal data through our partner programs through referrals. We may also obtain personal information from publicly available sources such as from public databases and registries or from trusted third parties such as our marketing or research partners. Information obtained through third parties is used for market research and marketing purposes.
How we use your data
We process your personal information collected from our website for purposes based on legitimate business purposes, in our fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We will always consider your rights when using your personal information. We may use and process your information:
To deliver and facilitate our services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services
To provide you with information. We may use your information to provide you with news, special offers, and general information about our goods, services and events we offer. You have the right to opt out of receiving such information.
To manage your account. We use your information to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For communication. We use your information to remain in contact with you by email, telephone calls, SMS, or other forms of electronic communication.
For marketing purposes. We may use your information to conduct our marketing, such as for our mailing lists, newsletters, event invitations, and alumni relations.
To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To post testimonials. We post testimonials on our Website that may contain personal information. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments and refunds made through the Website.
For payment of the Services we provide to you. To use certain services on our website, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our websites, to the extent permitted by applicable law, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers.
To request feedback. We may use your information to request feedback and to contact you about your use of our Website.
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
How we Share your Data
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
The Eureka Program also uses third-party applications to manage our services. Your information may be shared with our contracted service providers (such as Schoology and Google Classrooms) in the operation of your online accounts.
The Eureka Program has not disclosed or sold any personal information to third parties for business or commercial purposes in the preceding 12 months. The Eureka Program will not sell, transfer or trade personal information in the future belonging to website visitors, users, and other consumers. However, we may need to share your information with trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
Your Rights and Choices
You have the right to opt-out of communications for our website and services at any time. You can unsubscribe from our emails by clicking the “Unsubscribe” button at the bottom of our marketing emails or you may send us an email at any time to withdraw your consent to receive communications from us by sending an email to firstname.lastname@example.org.
You also have the right to:
request access to the personal data we hold about you
request correction of your personal data at any time.
request to restrict the processing of your personal information
request the deletion of the personal data we hold for you
If you request to access your personal data, withdraw your consent, or request us to delete your information, we may need to request specific information from you to confirm your identity and confirm your right to access your personal data. This security measure is put in place to ensure that personal data is only disclosed to the person who has the right to receive it. The Eureka Program will respond to your requests in a timely manner. If for any reason we are not able to provide the information requested within a reasonable time frame, we will notify you and explain the reasons. Please note that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Data Security and Retention
How do we keep your information secure?
Again, we want to emphasize that your personal data is of utmost importance to us and we take the responsibility of protecting your information very seriously. We have appropriate security measures put in place to prevent information about you from being accidentally lost, altered, disclosed, used, or accessed in an unauthorized manner. While we strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have procedures in place to deal with any suspected data breach that will affect you and will notify you of a breach where we are legally required to do so. Although we will do our best to protect your personal information, the transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
The Eureka Program’s website is hosted by a third-party platform. Your data may be stored through our partner’s data storage, databases, and general applications. Your data is stored on secure servers behind a firewall.
How long do we keep your information?
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods (such as for tax, accounting or other legal requirements).
Data Relating to Children (COPPA)
Our website and emails are designed for people who are 16 years of age and older. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will use reasonable efforts to locate and remove the corresponding information from our records.
Third-Party Links and Social Networking Services
Our website may include links to third-party websites, applications, and plug-ins. Engaging with these links, applications, and plug-ins may allow third parties to collect data about you. We are not responsible for the privacy practices or policies of these third-party links, applications, and plug-ins. We encourage you to read their privacy policies to learn about their privacy practices. We also encourage you to read the privacy policies of any websites you visit, including any websites that you access through the usage of our website.
Do California Residents Have Specific Privacy Rights?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
To exercise these rights, you can contact us or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
If you have any questions, concerns or feedback about your privacy, please feel free to contact us at email@example.com. Please also contact us if you would like to: access, correct, amend or delete any personal information we have about you.