Effective date: Aug 14, 2024

Privacy Policy

Privacy Policy for HopeST app

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the App and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the App. By using the App, You agree to the collection and use of information in accordance with this Privacy Policy. 

Plain Language Summary: 

The App, called HopeST, is an AI powered chatbot application for use by students designed to help them explore their career interests. The App currently includes three types of chatbots: career advisor, resume builder, and career professionals. The chatbots are powered by ChatGPT from OpenAI. You will not interact with natural persons through the App. The App collects personal information from Your device or about You as a user. This app is meant for the use by students at least 14 years old. The rest of the policy outlines how We use Your personal information. If this were to change, We will update Our privacy policy and notify You. 

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our App or parts of our App.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • App refers to HopeST, the software program provided by Us.
  • Company (referred to as either "We", "Us" or "Our" in this Agreement) refers to Hope Street Group, 7055 Veterans Blvd., Suite D, Burr Ridge, IL 60527
  • Country refers to: United States
  • Device means any device that can access the App such as a computer, phone, or tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Prompts means the messages You submit when You interact with the chatbots of the App.
  • Provided Information means the information that You submit through the use of the App.
  • Service Provider means any natural or legal person who processes the data on behalf of Us. It refers to third-party companies or individuals employed by Us to facilitate the operation of the App (e.g. OpenAI), to provide the App on behalf of Us, to perform services related to the App or to assist Us in analyzing how the App is used.
  • System Information means diagnostic and other information generated by the App through Your use of the App.
  • Usage Data refers to data collected automatically, either generated by the use of the App or from the App infrastructure itself.
  • You means the individual accessing or using the App.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our App, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Username, which maybe Your real name; and
  • Phone number.

Usage Data

Usage Data is collected automatically when using the App.

Usage Data includes Provided Information. That is information submitted by You during use of the App and may include name of Your school name, Your school email address, graduation year, hobbies, career interest, participation in student programs, earning expectations, preferred career location, low income status, disability status, survey responses, and requests by You to speak with a natural person.

Usage Data also includes Prompts. That is, messages submitted by You to the chatbots, which act as prompts for ChatGPT from OpenAI.

Usage Data includes System Information such as Your Device's Internet Protocol address (e.g. IP address), the chatbots that You interact with, the time and date of Your usage of the App, the time spent using the App, location based signals such as GPS, Your operating system, unique device identifiers, and other diagnostic data.

Use of Your Personal Data

We may share Your username combined with Provided Information with teachers and administrators of Your school or school district.

We will not share Your phone number with teachers and administrators of Your school or school district, or any third party.

We will not share Your username combined with Your Prompts with teachers and administrators of Your school or school district.

We may also use Personal Data for the following purposes:

  • To provide and maintain our App, including to monitor the usage of our App.
  • To manage Your Account: to manage Your registration as a user of the App. The Personal Data You provide can give You access to different functionalities of the App that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the App.
  • To contact You: To contact You by telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding account verification, updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our App users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, services, marketing and your experience.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Use of Your Usage Data

We may use Usage Data in any of the ways that We use Personal Data, as described above.

Provided Information in aggregate form or de-identified so that it may no longer be used to identify You may be shared with third parties. We may analyze the general behavior and characteristics of users of the App and share aggregated information like general user statistics with third parties, including teachers and administrative staff of Your school or district. We may publish such aggregated information or make such aggregated information generally available.

Prompts, by their very nature, are shared with OpenAI, and may be used to further train ChatGPT and other AI chatbots. Your grant Us and OpenAI a perpetual, royalty-free license to use Your Prompts for any purpose. To view OpenAI’s privacy policy and understand how Your interaction with the App’s chatbots may be used to further train ChatGPT, please follow these links, respectively: https://openai.com/policies/privacy-policy/ and https://help.openai.com/en/articles/7842364-how-chatgpt-and-our-language-models-are-developed.

Retention of Your Data

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We 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 App, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Data

Your information, including Personal Data, is processed on computers owned or controlled by us. It means that this information may be transferred to — and maintained on — computers located outside of Your state but will not be transferred outside the United States. 

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our App may give You the ability to delete certain information about You from within the App.

You may update, amend, or delete Your information at any time by signing into Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal and Usage Data

Business Transactions

If We are involved in a merger, acquisition or asset sale, Your Personal and Usage Data may be transferred. We will provide notice before Your Personal and Usage Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, We may be required to disclose Your Personal and Usage Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

We may disclose Your Personal and Usage Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation.
  • Protect and defend Our rights or property.
  • Prevent or investigate possible wrongdoing in connection with the App.
  • Protect the personal safety of users of the App or the public.
  • Protect against legal liability.

Security of Data

The security of Your Personal and Usage Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal and Usage Data, We cannot guarantee its absolute security.

In furtherance of our commitment to data security, we adhere to specific legal and regulatory frameworks as follows:

1. FERPA Compliance: We comply with the Family Educational Rights and Privacy Act (FERPA) as instructed by each educational institution. It should be noted that the interpretation of FERPA may vary among educational institutions, and so the steps we take to comply is based on the guidance provided by the institution. This could necessitate different approaches to obtaining parental consent. In certain cases, such consent may be required prior to the processing of student data, particularly when data is not anonymized. Conversely, some institutions may determine that the use of anonymized artificial intelligence (AI) is compliant with FERPA without the need for additional permissions. We recommend that educational institutions seek independent legal counsel to determine the appropriate course of action under FERPA.

2. ISO/IEC 27001 Compliance: We adhere to the ISO/IEC 27001 standard for information security management systems. Compliance is maintained through regular internal audits. However, it is acknowledged that in certain circumstances, third-party audits may be required or advisable to ensure ongoing adherence to the standard.

Children's Privacy

Our App does not address anyone under the age of 13. 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 and Usage Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Additional Rights

You may have additional rights under Family Education Right and Privacy Act (FERPA), California Consumer Privacy Act (CCPA), or other federal or state laws, rules or regulations.

Links to Other Websites

Our App may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our App, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: support@hopestreetgroup.org