Last Updated: 03/01/2023
- What information we collect and why we collect it.
- How we use that information.
- The choices we offer, including how to access and update information.
Types of Information We Collect
We collect two types of information about you: (1) information that you may choose to voluntarily provide us while using the Site (described below under “Information You Provide to Us” and (2) information collected automatically as result of your use of the Site (described below under “Information Collected Automatically”). We may also receive information about you from third-party sources (as described below under “Information Received from Third-Party Sources”).
Information You Provide to Us
You may choose to voluntarily provide certain personal information to us — such as name, telephone number or email address, employment status, date-of-birth, and level of education you have completed in order to access certain features of our Site or request information from us or a Provider. For example, the Site allows you to indicate interest in a training program so that we can expedite your application process once you apply for the training program. To support these activities, we will ask for information about you to follow-up with program partners.
When you send us a message using the “Contact Us” page or via email, we retain the content of the message, your email address, and any information you provide to us such as your name, phone number, your company, experience with our service, your contact preferences, and the response we send back to you. This helps us manage any follow-up questions you may have, measure how effectively we address your concerns and improve the Site. Any information retained would be used to assure the delivery of the services or information you requested and to optimize your experience and enhance the quality of the time you spend with us online. When you send us a message using the “Contact Us” page or via email, the email addresses and phone numbers collected are not further used to market to the individual beyond providing the services requested or responding to the requests.
This information is necessary for the adequate performance of the contract between you and us, for our legitimate interest in being able to provide and improve the Site, and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
Information Collected Automatically
The technologies and information we automatically collect include:
- Local storage: We may also use, collect, and store information and preferences locally on your device using mechanisms such as browser-based web storage (including HTTP cookies and HTML5) and application data caches or plug-in based local storage (such as flash cookies). Like many services, BetterOffer uses these technologies to analyze trends, gather demographic information, understand your engagement with the Sites, administer the Sites, tailor the Sites for you, and to help the Sites work better for you – for example, by remembering your language preferences. Third parties with whom we partner to provide certain features on our Sites or to display advertising based on your web browsing also may use HTML5 or other local storage to collect and store information.
- Device Information: We collect device-specific information such as your device type, device brand, operating system, hardware version, device settings, file and software names and types, battery and signal strength, and unique device identifiers. This helps us measure how Sites are performing, and improve the Sites for you on your particular device.
- Location Information: When you use our Site, we may collect and process information about your geographic location, for example through IP address, GPS, Bluetooth, or WiFi signals. We collect coarse (i.e., city-level) location data. We collect both coarse (i.e., city-level) location data and precise location data. If we collect precise geolocation information (“precise” meaning sufficient to identify street name and name of city or town) from you, we ask for your explicit opt-in permission. We will not store or track your device location on an ongoing basis or without your permission. We do not share precise geolocation data with third-parties, other than our service providers as necessary to provide the Site. If you no longer wish to allow us to track your location information, you may opt-out at any time by turning it off at the device level.
- Server Log Information: Like most online services, when you use our Site, we automatically collect and store certain information in our server log files. Examples include things like:
- Details of how you used our service, such as your activity on the Site, and the frequency and duration of your visits to the Site
- IP Address
- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
This information helps us make decisions about what we should work on next – for example, by showing which features are most (or least) popular. We may use your IP address and share it with third parties to help diagnose problems with our servers, for security purposes, to manage the Site, to enhance the Site and services based on usage pattern data, for analytics and for advertising.
Cross-Device Collection: To provide users with a seamless online experience, we may link your identifiers on different browsers and environments you are using to be able to provide a seamless experience across multiple devices and browsers without collecting or processing any additional identifying personal data.
Information Received from Third-Party Sources
How We Use the Information We Collect
In addition, we may use the information, including personal information, we collect for the following purposes:
- Fill your requests and provide any information you request, such as responding to your emails, submissions, questions, comments, requests, complaints and provide customer service
- Process your interest form in order for programs to follow-up with you regarding programs you indicate an interest in
- Personalize the Site, content and experiences for you
- Communicate with you through email, notices posted on the website, and other means. Examples of these messages include: (1) service messages – to provide you with updates about the programs you indicate an interest in; and (2) promotional messages – to provide you with information about us or our partners that we think you might find interesting; and (3) prompts to follow up with us regarding your program experience;
- Send you information about features on our Site or services or changes to our policies, Site and services
- Send you security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Site or service
- Optimize or improve our Site and to research and develop innovate features and services
- For safety and security reasons, such as detecting, investigating and preventing activities that may violate our policies or be illegal
- Provide you information about events, announcements, offers, promotions, products, and services we think will be of interest to you
- Provide you with BetterOffer advertisements based on your activity on our Site and on third-party sites and applications
- Perform analysis of the Site’s performance and determine the quality of programs on the Site.
- Complete research and potential publications using de-identified information
- For any other purpose for which the information was collected
We process this information given our legitimate interest in improving the Sites and our users’ experience with it, in protecting the Site, where necessary for the adequate performance of the contract with you, and to comply with applicable laws. Additionally, we will process your personal information for the purposes listed in this section related to marketing given our legitimate interests in undertaking marketing activities to offer you products and services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
Sharing Your Information
Third-Party Integrations on Our Site: When you use third-party apps, websites or other services that use, or are integrated with, our Site, they may receive information about what you share. Information collected by apps, websites or integrated services is subject to the terms and policies of those services.
Analytics Services: We use analytics services, including mobile analytics, to help us understand and improve how the Site and our service is being used. These services may include third-party analytics providers and may collect, store and use information in order to help us understand things like how often you use the Site, the events that occur within the Site, usage, performance data, and from where the application was downloaded. A current list of analytics providers that we use is located here and more information can be located below in the Section “Online Analytics, Advertising and Do-Not-Track.”
Business Partners: From time to time, BetterOffer will partner with other companies to jointly offer products or services, such as workforce development programs. If you purchase or specifically express interest in a jointly-offered product or service from BetterOffer, we may share information collected in connection with your purchase or expression of interest with our joint promotion partner(s). BetterOffer does not control our business partners’ use of the information we collect, and their use of the information will be in accordance with their own publicly posted privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in the services being offered.
Social Media Platforms: Where permissible according to applicable law, we may share certain limited personal information with social media platforms (such as Google or Facebook) and other websites, applications or partners, to generate leads, drive traffic to our Sites or otherwise market and advertise our products or services on those websites or applications. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products and services that may be of your interest. These social media platforms with which we may share your personal information are not controlled or supervised by BetterOffer. Therefore, any questions regarding how your social media platform processes your personal information should be directed to such provider.
Aggregated Information and Non-Identifying Information: We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified or non-personally identifiable information (such as statistics about visitors, traffic and usage patterns), including with users, partners or the press in order to, for example, demonstrate how the Site is used, spot industry trends, or to provide marketing materials for BetterOffer.
Legal Requirements: We may disclose information, including personal information, if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of BetterOffer, our employees, our community, or others, or to prevent violations of any other agreements entered into by us. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to law enforcement and government requests. Where appropriate, we may notify users about the legal requests, unless (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon BetterOffer, or its users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
Fraud Protection: We may share information to assist with security operations for scheduled penetration testing, auditing, and continuous improvement of our security practices, including without limitation, exchanging information with other companies and organizations for fraud protection. Authorized parties of the information would comply with our current privacy and security policies.
With your consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it.
Online Analytics, Advertising and Do-Not-Track
Online Analytics Providers
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. These third parties use the sorts of technologies described in the “Information Collected Automatically” Section above. The information collected by this technology will be disclosed to or collected directly by these service providers.
Advertising Technology Providers
Data about your activities on our Sites (outside of our Service) may be collected by us or by third-party advertising technology providers for use in delivering online advertising tailored to your individual characteristics, activities, interests and other factors. These ad services may track your online activities over time and across the web by collecting information through automated means, including through the use of the various technologies described above, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you on our website, our emails, and other websites. We and third-party vendors may use first-party cookies and third-party cookies together, and other automated technologies, and in some cases additional information, (i) to inform, optimize, and serve ads based on past visits to our Sites or other factors and (ii) to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Sites or other factors.
Ads may be delivered based on other factors, such as the content of the web page in which they are shown, or demographic information obtained through other means.
Do Not Track Disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. For more information on “do not track”, please visit www.allaboutdnt.org.
Data Security and Retention
The security of your personal information is important to us. To prevent unauthorized access, disclosure, or improper use of your information, and to maintain data accuracy, we’ve established physical, technical, and administrative safeguards to protect the personal information we collect. Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time.
If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (http://www.betterofferco.org) or elsewhere on the Site, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
As you can see, we try to be transparent about what information we collect, so that you can make meaningful choices about how it is used. You may have certain rights relating to your personal information, subject to local data protection laws. Please review local data protection laws for more information. Depending on the applicable laws these rights may include the right to:
- Access your personal information held by us;
- Know more about how we processed your personal information;
- Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
- Erase or delete your personal information (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
- Restrict our processing of your personal information, to the extent permitted by law;
- Transfer your personal information to another controller, to the extent possible (also referred to as the right to data portability);
- Object to any processing of your personal information. Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- Opt out of certain disclosures of your personal information to third parties;
- If you’re under the age of 16, opt in to certain disclosures of your personal information to third parties;
- Not be discriminated against for exercising your rights described above;
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our Sites; and
- Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
If you are a California resident, you may have additional rights as set forth under the California Consumer Privacy Act as amended and its implementing regulations (“CCPA”). Please see the Section “California Privacy Disclosures ” for more information if you are a California resident.
How to Exercise Your Rights
To exercise your rights, please contact us by using the information in the “Contacting BetterOffer” section, below. Your personal information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.
We may reject requests for access, change or deletion that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). In some cases, we won’t be able to guarantee complete access due to legal restrictions – for example, you will not be allowed to access files that contain information about other users or information that is confidential to us. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort.
Information that you have shared with others, others have shared about you, or content other users may have copied and stored, is not part of your account and may not be deleted when you delete your account. We aim to maintain our Sites in a manner that protects information from accidental or malicious destruction. Because of this, even after you update or delete personal information you have provided us from our Sites, your personal information may be retained in our backup files and archives for a reasonable period of time as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. BetterOffer provides users with the opportunity to withdraw consent or ‘opt-out’ of receiving any future marketing communications from BetterOffer and its partners at any time. Please see the “Communications from BetterOffer” section for more information. Additionally, you can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of the Site’s features may not be accessible, or may not function properly – for example, we may not be able to remember your language preferences for you.
The Site is hosted and operated in the United States. If you use the Site from the European Union or the United Kingdom, or any other region with laws governing data collection, protection and use that may differ from United States law, please note that you may be transferring your personal information outside of those jurisdictions to the United States. Where we transfer, store and process your personal information outside of the United Kingdom, European Union or EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws.
Communications from BetterOffer
If you registered on the Site, provided an email or phone number to us, or otherwise opted-in to receive communications from us, we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the Site or Service, and information regarding products, features or services from BetterOffer (or third parties we believe you may be interested in). These communication methods may include, but are not limited to, email, SMS text messages, postal mail, social media communications, telephone calls, and push notifications. If you have an account with us, we’ll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business. We may receive a confirmation when you open an email from us if your device supports it. We use this confirmation to help us understand which emails are most interesting and helpful.
You can always unsubscribe from receiving any of our 1) marketing emails or other marketing communications whenever you’d like by clicking the “Unsubscribe” link at the bottom of the email; 2) marketing SMS texts by replying or texting ‘STOP; or 3) marketing push notifications by turning off push notifications on your device. You can also always send us an email at email@example.com.
You can further indicate your preferences by contacting us using the information in the “Contacting BetterOffer” section below. Please note that opting-out of marketing communications does not affect your receipt of business communications that are important to your interaction with BetterOffer, such as support/service communications, security updates, or account management communications. You may not opt-out of receiving these communications.
Social Media Features
The Sites are not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personal information. Additionally, we do not knowingly collect (or knowingly allow any third party to collect) or maintain personal information from anyone under the age of 13. If we become aware that a child under 13 has provided us with personal information or that personal information has been collected from a child under 13, then we will delete this information from our files as quickly as possible. If you are the parent or legal guardian of a child under 13 who you believe has provided personal information to BetterOffer, please send an email to us at firstname.lastname@example.org, or contact us as set forth in the “Contacting BetterOffer” section below to have that child’s information deleted.
Online Surveys and Feedback
We like feedback, which means we may conduct online surveys to solicit your opinions and comments. Participation in these surveys is of course optional. If you choose to participate, the information you provide will be aggregated with information from other users to make improvements to the user experience and develop appealing content, features, and promotions.
You can also ask us questions and share comments or suggestions with us. Your questions, comments, and suggestions may not be kept confidential. We may use your questions, comments, and suggestions to improve the Site and our Service, but we will have no obligation to compensate you for any such contributions.
California Privacy Disclosures
Your Rights and Choices
If you are a California resident you have the right to request that BetterOffer disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.
California consumers also have specific rights of access, deletion and data portability regarding their personal information under the CCPA. If you are a California resident you have the right to request that BetterOffer provide the specific pieces of information that we have collected about you. You also have the right to request deletion of your personal information collected or maintained by BetterOffer. We provide these same rights to all users. Please see the “Your Rights” Section for more detail on how to exercise these rights, including how we will verify requests. If you are a California resident, you may also designate a natural person or business entity registered with the California Secretary of State to act on your behalf to exercise these rights.
We will not discriminate against you for exercising any of your rights under CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will be reasonably related to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
DO NOT SELL
NOTICE FOR MINORS (USERS UNDER 18)
If you are under the age of 18, or the parent of a child using the Site under the age of 18 residing in California, you are entitled to request removal of content or information you (the minor) have publicly posted on our Site. Currently, we do not allow minors to post content to share publicly on the Site.
“SHINE THE LIGHT” LAW
Pursuant to California Civil Code Section 1798.83(c)(2), BetterOffer does not share personal information with third parties for their own direct marketing purposes unless you affirmatively agree to such disclosure. If we do share personal information with third parties for their own direct marketing purposes and you authorize us to include your information, we will only share that information in connection with that specific promotion. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt-in to such use when you provide personal information on our Site. If you later decide that you do not want that third party to use your personal information, you will need to contact the third party directly.
California customers can receive more information about our compliance with this law or to make a request under California Civil Code Section 1798.83 by sending us an email at email@example.com or by writing to us as set forth in “Contacting BetterOffer” Section below.
1705 17th Street, Suite 200
Denver, CO 80202
Attention: Elise Henson