Effective Date: June 1, 2024
Bletchley Institute LLC and our affiliates (collectively, “Bletchley Institute,” “Bletchley,” “we,” “us,” or “our”) care about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how Bletchley Institute collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), or other services that refer to or link to this Policy, as well as any offline products, programs, courses, and services (collectively our “Services”).
Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us. If you do not approve of the practices stated in the Privacy Policy, your choice is not to use our Services. This policy may change from time to time (see “Changes to This Policy”), so please check the policy periodically for updates.
References to “Personal Information” means data that relates to you and can — either on its own or in combination with other information — reasonably be associated with you as an individual. Personal Information includes information that could be reasonably linked, directly, or indirectly, with you. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified, or the information can no longer be related to you, using means reasonably available to us.
The Personal Information that we collect and our use of that information depends on your relationship with us and the requirements of applicable law as described below.
We collect information:
Except as otherwise described in this Policy, Bletchley Institute only collects Personal Information from you or others based on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:
In addition to information that you choose to submit to us, Bletchley and/or our service providers may automatically collect and/or store certain information (“Navigational Information”) when you visit or interact with our websites, landing pages, and other web-portals (the “Site”). This Navigational Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. While the Navigational Information collected automatically may not include Personal Information, we may maintain it or associate it with Personal Information we collect from you in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized experience, including by enabling us to:
Navigational Information may include:
We may use various methods and technologies to collect and/or store Navigational Information, such as:
Do Not Track. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.
Third-Party Sources. We may obtain Personal Information about you from your company, school, or other organization associated with your use of the Services. We also may receive Personal Information about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.
In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.
How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:
Applicants. If you are an applicant, the Personal Information we use includes:
Students. If you are a student, the Personal Information we use includes:
Guests. If you are a visitor or guest who visits a facility in connection with the Services, except as otherwise specified in this Policy, we use the following Personal Information for the following purposes:
Clients and Hiring Managers. If you are a client or hiring manager, in addition to the Personal Information we use about guests, the Personal Information we use includes:
All. Whether you are an applicant, student, alumni, guest, or other user of our Services, we also use your Device and Navigational Information and Other Personal Information to prepare aggregate use statistics, analyze, provide, better tailor, and improve our products and Services, tailor and provide you promotions and advertising, both on and off the Services, otherwise enhance your engagement with us, and as otherwise described in this Privacy Policy.
LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others a Secure Environment, and analyzing, improving, and better tailoring our products and Services.
We also generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third-party websites, and in providing promotions or sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.
As described in this Policy, we disclose your Personal Information within Bletchley Institute and its affiliates, to our community, to our service providers and advertisers, and to other end users in order to provide our Services and to improve ways of working in our community.
We may share your Personal Information across Bletchley Institute and its affiliates depending on where you are located and the Services that you use. Bletchley Institute uses your information in accordance with this Policy.
Our Community. Our Services include online and offline communities, forums, networks, and other features through which you may share information and connect with others. This includes:
Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
Financing Products. When you enter into an agreement with Bletchley Institute to obtain a financing product or financial assistance, we may share your Personal Information to maintain or service your account(s) (including referrals to debt collectors, when appropriate), protect against fraud, unauthorized transactions, claims, or other liability, report to consumer reporting agencies, undertake a proposed or actual exchange or sale of all or a portion of our business or accounts, comply with subpoenas or other judicial process or regulatory requirements, or as otherwise required or permitted by law. You generally do not have the right to limit our sharing of this Personal Information.
Financial Partners. When you engage a third party to finance your participation in Bletchley Institute or provide tuition assistance, you are entering into a relationship with a third party for a financial product or service. As described in our Privacy Policy, we are not responsible for the data collection, privacy, and information sharing policies and procedures of any such third parties. Please read their privacy policies Financial Partners. When you engage a third party to finance your participation in Bletchley Institute or provide tuition assistance, you are entering into a relationship with a third party for a financial product or service. As described in our Privacy Policy, we are not responsible for the data collection, privacy, and information sharing policies and procedures of any such third parties. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information.
Scholarship Providers. If you apply for a scholarship and/or receive a scholarship through Bletchley Institute or a third-party scholarship provider, we may share your Personal Information with the third-party scholarship provider in order to administer the scholarship or meet reporting requirements.
Employer Partners. As part of our Services, we may connect you with prospective employers or employment opportunities and may be compensated by the employer for successful candidate placement. Typically, the information we share about you would consist of your resume, LinkedIn profile, and GitHub profile. This may also include information you provide in a profile on a job search platform. You may elect to opt-out of your information being shared with employer partners.
Program Partners. If you utilize the Services through your employer, university, or other organization, we may share your Personal Information with such third party in order to meet the requirements of the partnership. Please review their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information.
Jobs Report. As part of our annual outcomes report, we will share your Personal Information with the third party we engage to review and examine our data and statements included in the report.
Research / Survey Solicitations. From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
Corporate Transactions. We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Information to other parties:
We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.
With Your Consent. We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.
We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:
We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). For more information on these types of tracking tools, please see the section on NWe, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). For more information on these types of tracking tools, please see the section on Navigational Information above. We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-Bletchley related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance (EDAA) to learn more. Canadian users may also visit the Digital Advertising Alliance of Canada.
Additionally, residents of states with specific privacy laws may exercise their rights as described below in the section “Exercising State Privacy Rights”.
We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and video with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results.
While we will not edit comments, we may delete a comment from our page on a social media site if it, for example, does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language, or if it is a personal attack or hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.
We will process such requests in accordance with local laws. To protect your privacy, Bletchley Institute will take steps to verify your identity before granting access or making any changes to your Personal Information.
Where you have consented to Bletchley Institute’s use of “sensitive” Personal Information (e.g., Personal Information relating to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you) (“Sensitive Personal Information”), you may withdraw that consent, in accordance with applicable law.
Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Data for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Bletchley will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, Bletchley Institute will comply with the law or contract.
Opting-Out of Marketing Communications. We provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt out of those communications, e.g., communications regarding updates to our Terms of Use or this Policy. If you no longer desire to be contacted by us, you must terminate your relationship with Bletchley Institute and can no longer use our Services.
Collaboration. We may partner with other organizations to run events or programs. The Personal Information and other information that you provide to sign up or participate in that event or program will be available to that organization, and you may receive emails or other communications from it after the event. Please refer to that organization’s privacy policy for information on how to opt-out of its communications.
Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP
Where Bletchley Institute engages in interest-based advertising, we endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, Bletchley Institute’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.
Bletchley Institute is headquartered in the United States, and as a consequence your Personal Information may be processed in a country that may have privacy protections less stringent than your country of residence. In accordance with applicable law, we implement measures to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below.
Bletchley Institute will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended as determined by our records retention program.
When determining how long this retention period will last, we take into account the length of time Personal Information is required to:
The security of all Personal Information provided to Bletchley Institute is important to us. Bletchley Institute takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. To protect this Personal Information from unauthorized access and use, we use security measures that comply with law and are consistent with industry standards.
Our campuses have security cameras installed to meet our legitimate business interests in protecting the safety of our employees, students, and guests and their property. These security camera recordings may be accessed by Bletchley Institute or the landlord for any of our campuses and facilities. This video footage may be made available to third parties authorized by Bletchley Institute or our applicable landlord. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are generally retained for a limited period of time, but may be kept longer where Bletchley Institute or our applicable landlord determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.
Our Services are not directed at children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16, except as permitted under applicable law. If you are under the age of 16, do not use or provide any information on this website or through any of our Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware that a child under the age of 16 has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law. If you believe we might have any information from or about a child under 16, please contact us at marketing@bletchley.org.
This Privacy Policy does not apply to services not provided by Bletchley Institute. We may display advertisements and other content from third parties or partners that link to third-party websites that we do not own or operate. We provide links to these third-party sites as a convenience to you. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms. Additionally, third parties may sell goods or offer services at our facilities or in combination with our Services. We are not responsible for those third parties’ services or their privacy practices.
Any information that is collected via the Services is covered by the Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion.
If we make any material changes to this Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, as required by applicable law, and we will update the “Effective Date” below to indicate when those changes will become effective.
Personal Information is controlled by Bletchley Institute LLC. If you have any questions or comments regarding our Policy, please contact us at legal@bletchley.org.
Legal Team
Bletchley Institute LLC
11 Broadway, 2nd Floor
New York, New York 10004
Bletchley Institute will address your concerns and attempt to resolve any privacy issues in a timely manner.
Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.
California “Shine the Light” Law. Cal. Civ. Code §1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to marketing@bletchley.org or write us at the address noted above in the “Questions or Comments” section.
Minor California Residents. California residents who are registered users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at marketing@bletchley.org. In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
State Privacy Laws. Several states have enacted privacy laws which provide their residents a number of rights as they relate to Personal Information. These are the “right to know”, the “right to correct”, the “right to delete”, and the “right to opt-out”.
Right to Know. You may request Bletchley Institute provide you the specific pieces of personal information that Bletchley Institute has about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that Bletchley Institute sold or disclosed for a business purpose about you; 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. Please note that much of the information you can make a request for is already contained in this Policy. Should you wish to exercise this right, please see the section below which explains how to do so. If you do not have an account with Bletchley Institute, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
Right to Correct. You may request for Bletchley Institute to correct Personal Information which you believe to be incorrect. However, you cannot request a change to information which is factually correct, or is the opinion of another person. Should you wish to exercise this right, please see the section below which explains how to do so. Further, our systems or portal may allow you to correct information yourself when you log in and use the applicable account management tools we have provided. If you do not have an account with Bletchley Institute, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
Right to Delete. Some state privacy laws give their residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if Bletchley Institute has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Bletchley Institute; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. If you do not have an account with Bletchley Institute, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
Right to Opt-Out. While we do not sell your personal information in the traditional sense, Bletchley Institute does sell your Personal Information to third parties as defined by applicable state law. This is because we share Personal Information with third parties for marketing purposes and permit our marketing partners to collect data directly from you. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request by using the mechanisms noted below under “Exercising State Privacy Rights”.
Also, as Bletchley Institute engages in interest-based advertising, we endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, Bletchley Institute’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.
Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
Designating an Authorized Agent. Certain state laws permit their residents to designate an agent to manage their rights under state law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising State Privacy Rights”. Note that If you do not have an account or are not enrolled with Bletchley Institute, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.
Non-discrimination. Bletchley Institute does not discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising State Privacy Rights. If you are a resident of a state with specific privacy paws and would like to exercise any of your rights you may do so by using the DAA opt-out tool (available at http://www.aboutads.info/choices), emailing us at marketing@bletchley.org. You may also contact us by using the contact particulars noted in the “Questions & Comments” section above.