Effective as of April 27, 2022.

This “Program Privacy Policy” describes how Beyond 12, Inc. (“Beyond 12”, “we”, “us”, or “our”) handles personal information that we collect from eligible Amazon, Inc. (“Amazon”) personnel (“Amazon Associates”, “you”, “your”, or “yours”) in connection with, as applicable, your application to, consideration of, enrollment in, and participation in the Career Choice Program. The Career Choice Program includes your use of:

  • the MyCoach mobile application (the “MyCoach App”);
  • our coaching services, including any text-based (such as HERE4U), voice-based, or other coaching services; and
  • any other website or mobile application offered to provide the Career Choice Program that we own or control and which posts or links to this Program Privacy Policy.

Collectively, we refer to all of the above for purposes of this Program Privacy Policy as the “Program.”

As explained in more detail below, you provide some of the personal information we collect in connection with the Program directly, we receive some of this personal information from third-party sources (such as the educational institutions in which you may enroll and your employer (Amazon)), and we get some of this personal information by collecting it as a result of your interactions, use, and experiences with the Program. Our use of your personal information is described in this Program Privacy Policy and is governed by our agreement with Amazon. This Privacy Policy does not apply to the processing of your personal information by Amazon. If you have questions with respect to Amazon’s processing of your personal information, you can contact Amazon directly.

Beyond 12 may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Table of Contents

  • Personal Information We Collect
  • How We Use Your Personal Information
  • Retention
  • Tracking Technologies
  • How We Share Your Personal Information
  • Your Choices
  • Other Sites, Mobile Applications and Services
  • Security Practices
  • International Data Transfers
  • Children
  • Changes to this Program Privacy Policy
  • How to Contact Us

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Program or otherwise may include:

  • Personal and business contact information, such as your first and last name, email and mailing addresses, employee identification number, employee alias, and phone number.
  • Academic institution information, such as your institution name and school-issued student identification number (including an image of an identification card).
  • Content you choose to upload to the Program, such as text, images, audio, video, or any other information you may share through the Program or otherwise with us, along with the metadata associated with the files you upload.
  • Any information you voluntarily share with Beyond 12, such as by text message, by chatbot, by email, by online form submissions, through the MyCoach App, or through live discussion.
  • Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, and preferences.
  • Registration information, such as information that may be related to a service, an account, or an event for which you register in connection with the Program.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online, including in response to quizzes and surveys.
  • Demographic information,such as your city, state, country of residence, postal code, and age/year of birth.
  • Precise geolocation information, such as when you authorize the Program to access your location.
  • Usage information, such as information about how you use the Program and interact with us, including information associated with any content you upload to the Program, or otherwise submit to us, and information you provide when you use any interactive features of the Program.
  • Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
  • Other informationthat we may collect which is not specifically listed here, but which we will use in accordance with this Program Privacy Policy or as otherwise disclosed at the time of collection.

Please keep in mind that we may not collect all of this information in connection with each aspect of the Program.

Information we obtain from third parties.  We may receive personal information about you from third-party sources. For example, we may obtain your personal information from Amazon; the educational institutions in which you enroll or attend; publicly-available sources; and data providers.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer, or mobile device, and activity occurring on or through the Program, including but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, general location information such as city, state or geographic area; information about your use of and actions through the Program, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information.  For more information concerning our automatic collection of data, please see the Tracking Technologies section below.

Referrals.   Users of the Program may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We may use your personal information for the following purposes and as otherwise described in this Program Privacy Policy or at the time of collection:

To operate and provide the Program.  We use your personal information to:

  • Provide, operate and improve our business including the Program and our products or other service offerings;
  • provide information to you about the Program;
  • establish and maintain your user profile on the Program;
  • enable security features of the Program, such as by verifying your account via email or SMS, and remembering devices from which you have previously logged in;
  • facilitate social features of the Program, such as by identifying and suggesting connections with other users of the Program and providing chat or messaging functionality;
  • communicate with you about the Program, including by sending you announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the Program and our communications regarding the Program;
  • provide support and maintenance for the Program;
  • respond to your requests, questions and feedback; and
  • otherwise provide services related to the Program.

For research and development.  We analyze use of the Program to improve the Program and to develop new products and services, including by studying user demographics and use of the Program.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Program; (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity; and (d) audit our internal processes for compliance with legal requirements (including statutory and contractual requirements) and our internal policies.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated, or de-identified data.  We may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated, or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Program and promote our business.

Retention

We retain your personal information for the period required by our agreement with Amazon, including, as appropriate, (i) to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal (including contractual), accounting, or reporting requirements, (ii) to establish or defend legal claims, or (iii) for fraud prevention purposes.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Tracking Technologies

Some of the automatic collection described above in the Personal Information We Collect section is facilitated by the following technologies:

  • Cookies, which are small text files that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies used through the Program include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
  • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

For information concerning your choices with respect to the use of tracking technologies, see the Your Choices section below.

How We Share Your Personal Information

Amazon.  We may share the following categories of personal information with Amazon or others that Amazon designates:

  • information to confirm your eligibility to participate in the Program, such as your Amazon alias and location;
  • confirmation of enrollment and at which institutions you are enrolled;
  • confirmation of your registration in the Program and related voucher materials; and
  • confirmation of your completing coaching sessions.

We do not control how Amazon or others that Amazon designates may use and/or disclose your personal information.

Service providers.  We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Program (such as customer support, hosting, analytics, email delivery,  and database management services).

Educational institutions.  We may share your personal information with educational institutions to which you apply and/or in which you enroll.  We do not control how these educational institutions may use and/or disclose your personal information.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information, including with law enforcement, government authorities, and private parties, for the compliance, fraud prevention, and safety purposes described in the How We Use Your Personal Information section above.

Business transferees.  We may share your personal information with, or transfer your personal information to, acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions), including a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Beyond 12 or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Where commercially feasible, we take steps designed to verify that the parties with whom we share personal information implement measures designed to provide a level of protection of personal information consistent with the practices described in this Program Privacy Policy, except that all such parties described above (other than service providers) may, to the extent permitted by law, use personal information as described in their own privacy policies.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of SMS Program-Related Communications.  If you provide your phone number through the Program, Beyond 12 may send you notifications by SMS, such as to alert you of a problem with your account, or to communicate with you about our offerings.  You may opt out of receiving further text or SMS messages from us by replying STOP to our messages or texting STOP to HERE4U.

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Program. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, parts of the Program may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  

Privacy settings and location data. We may make available certain privacy settings on the Program. Users of our Program may also choose whether to allow us to access your precise location data. Your device settings may allow you to revoke our ability to access location data.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Program to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with all or certain Program services.  We will tell you what information you must provide to receive the services offered through the Program by designating it as required at the time of collection or through other appropriate means.

Delete your content or close your account. You can request deletion of your data or closure of your account by contacting us at [email protected].  We may deny your request where we have valid legal or business reasons to retain your data.

Other Sites, Mobile Applications and Services

The Program may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions.  Other websites, mobile applications, and services follow different rules regarding the collection, use, and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security Practices

The security of your personal information is important to us.  We employ a number of organizational, technical, and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

The Program is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.  We encourage parents with concerns to contact us.

Changes to this Program Privacy Policy 

We reserve the right to modify this Program Privacy Policy at any time. If we make material changes to this Program Privacy Policy, we will notify you by updating the date of this Program Privacy Policy and posting it on the Program. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Program.

Any modifications to this Program Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Program (or as otherwise indicated at the time of posting). In all cases, your continued use of the Program after the posting of any modified Program Privacy Policy indicates your acceptance of the terms of the modified Program Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Program Privacy Policy or privacy practices to [email protected] You may also write to us via postal mail at:

Beyond 12, Inc.

Attn: Legal – Privacy

1625 Clay St. Suite 100

Oakland, CA 94612