Chatbot Privacy Policy

Last updated: September 14, 2023

We at Making Waves Education Foundation (“Making Waves Education Foundation”, “we”, “us”, or “our”) have created this privacy policy (“Chatbot Privacy Policy”) to describe how we collect and use Personal Information (defined below) from and about the students and end users (“Users”, “you”, “your”) who use our Service (as defined below) to interface with and communicate with the organizations that use the chatbot platform (our “Partners”) and the choices that you have with regard to how we use your information. 


This Chatbot Privacy Policy applies to Users’ use of mobile features, applications and any other interactive features or services owned or controlled by Making Waves Education Foundation (each, a “Service” and collectively, the “Services”). Certain features discussed in this Chatbot Privacy Policy may not be offered on each Service at any particular time.  This Chatbot Privacy Policy does not apply to our general privacy practices, such as information collected through our web site or our Partners’ use of the Services; these activities are governed by our general Privacy Policy, available at https://making-waves.org/privacy-policy/. 


This Chatbot Privacy Policy explains what Personal Information (defined below) we collect from or about Users, how we use and share that information, and your choices concerning our data practices. Additional information for California residents may be found here. This Chatbot Privacy Policy is incorporated into and forms part of our Chatbot Terms of Use.

 

Before using the Service or submitting any Personal Information to us, please review this Chatbot Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Chatbot Privacy Policy. If you do not agree to this Chatbot Privacy Policy, please do not use the Service.

Personal information collection

Through providing the Services, we may collect information that, alone or in combination with other reasonably available information, can reasonably identify or relate to a specific individual or household (“Personal Information”) as follows: 

1.1 Information You Provide: We collect Personal Information you provide when you interact with Services to communicate with a Partner, such as by chatting with a bot provided on a Partner’s website or sending text messages to a Partner using our Services. This Personal Information includes information you provide during these interactions, such as your name, email address, phone number, physical address or zip code, demographic information (such as your school, gender, age or birthdate), and information about your interests and preferences. 

Note that our Chatbot will only ever ask for your name, email address and phone number; any other Personal Information you provide is at your own discretion and not required for your use of the Services. We may combine the information we collect from you through Services with other Personal Information we have about you as described in this Chatbot Privacy Policy. Any information combined with Personal Information will be treated as Personal Information. 

1.2  Information Provided By Our Partners: Our Partners enter your Personal Information into the Services so that they may communicate with you via the Services. This Personal Information includes, but is not limited to, your name, email address, phone number, and any other Personal Information our Partners may choose to provide. 

1.3  Third Party Services: Our Services may be made available on the web sites of our Partners or other third parties, such as Facebook. Our Services may also include links to web sites or services hosted by third parties, such as chat rooms or group counseling sessions, through which you may communicate directly with third parties and/or other Users. We only collect information regarding your interaction with the Services and do not gather information from the third party sites regarding your interactions with the third parties or other Users on those services. 

The information we collect is subject to this Chatbot Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party shares information with us, the types of information shared, and your choices with regard to what is visible to others on that third party web site and service.

1.4  Information Third Parties May Provide About You:  To the extent permissible by law, we also may supplement the information we collect with outside records from third parties, such as schools, universities, organizations, services, and institutions that are not our Partners, in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that we believe may be of interest to you. We may combine the information we receive from those other sources with information we collect through the Services. In those cases, we will apply this Chatbot Privacy Policy to the combined information. 

1.5  Information Collected Automatically: Depending on the Service used, we and certain service providers may automatically collect “Usage Information” when you access and use the Services online. To do so, we automatically assign and collect a unique identifier (“Device Identifier”) for any computer, mobile phone or other device (any, a “Device”) you may use to access the Services online so that our servers can recognize your Device. The Usage Information we automatically collect based on your Device Identifier include details of your online interaction with the Services, such as when and what messages you send and receive via the Services online. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information. 

Usage Information is automatically collected via tracking technologies, including:

 

Cookies: Cookies are small text files stored on your Device that allow us to recognize your Device and personalize the content of our Services. Our Services may utilize Cookies to store your Device Identifier to improve your current and future experience by allowing us to understand your usage of our Services and recognize you if you return to our Services. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of our Services may not function properly. 



An Embedded Script: We and service providers may use an embedded script, which is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our server or that of a service provider, and is deactivated or deleted when you disconnect from the Services. 



HTML5: We use Local Storage Objects (“LSOs”) such as HTML5 to store content, information and preferences, such as the messages you exchanged with the Services, to optimize the performance of the Services and provide certain features. Various browsers may offer their own management tools for removing HTML5 LSOs 

Our use of your information.

We may use information about you, including Personal Information, to: (1) allow you to participate in the Services, including, without limitation, to respond to your questions, complaints or comments; (2) tailor content, recommendations and offers we display to you on the Services; (3) provide you with information, products, services, or suggestions you request; (4) improve the Services and our products, and for internal business purposes, including the improvement of our AI chat algorithms; (5) contact you with regard to your use of the Services and, in our discretion, changes to our policies; and (6) as described in the Chatbot Privacy Policy or as disclosed at the time you provide your information.

 

Unless you have explicitly agreed to interact directly with us, such as to receive additional information or services that may be of interest to you, we only use the Personal Information collected via the Services as described above to provide the Services to our Partners. 
We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners.

We may collect aggregated information through the Service, through cookies, and through other means described in this Chatbot Privacy Policy. 

Information sharing

We may share your Personal Information, without further notice to you unless required by applicable law, as described below or otherwise in this Chatbot Privacy Policy:

 

When You Request That We Share Your Personal Information: Certain Services may include opportunities and features brought to you by a third party or that otherwise involve sharing your information with a third party. If you request or agree at that time to have your information shared, or use an interactive feature, widget, or third-party application, your information will be disclosed to that third party (or parties).  Please note that the third party’s handling of that information will be subject to the privacy policy and practices of that third party.

 

Our Partners: Because we provide the Services on behalf of our Partners, we may share your Personal Information with the Partners with whom you are communicating through the Services. 



Service Providers: We will share your Personal Information with unaffiliated entities that provide services to us or our Partners in connection with the Services, such as companies that provide hosting and other IT services, send messages through the Services, or offer customer service.  These service providers are subject to confidentiality obligations which limit their use and disclosure of such information. 



Administrative and Legal Reasons: We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Use or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual.

 

Business Transitions: Making Waves Education Foundation may share Personal Information with its parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that Making Waves Education Foundation goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred.

 

With Your Consent: We may share your Personal Information with third parties with your consent (if permissible under applicable law) provided at the time you provide us with information. 


Making Waves Education Foundation does not share your Personal Information with third parties for their marketing purposes without your consent and in compliance with all applicable laws. Making Waves Education Foundation may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information, Usage Information, and related insights with our Partners and third parties, such as other schools and universities, for our marketing purposes.

Third party analytics

Depending on the Service used, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to provide us with information regarding traffic on the Services, including the pages viewed and the actions Users take when visiting the Services. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.


Please note that your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online service you visit. 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. To find out more about “Do Not Track”, please  visit  http://www.allaboutdnt.com.

Mobile use

a. If you interact with the Services through a mobile device, it may be possible for you to transmit your mobile Device Identifier, your mobile carrier, or your physical location to Making Waves Education Foundation; however, Making Waves Education Foundation will not track such information in the background. If you transmit such information to Making Waves Education Foundation, we may store or use that information in compliance with this Chatbot Privacy Policy. You may be able to opt-in to receiving text messages sent using the Services. You may always opt-out by replying “STOP” to one of the text messages received. You also acknowledge and agree that use of the Services through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access providers.


b. Data obtained through the short code program used by the SMS Service will not be shared with any third-parties for their marketing reasons/purposes.

Your rights

Depending on where you live and the law governing your Personal Information, you may have certain rights, as described throughout this Chatbot Privacy Policy.  You may opt-out of electronic communications at any time by contacting us at info@making-waves.org or by visiting https://making-waves.co/ai-opt-out to manage your communication preferences.  Alternatively, to opt-out of text messages, you may reply “STOP” to one of the messages and to opt out of emails you may click “Unsubscribe” at the bottom of any of our email communications.

Making Waves Education Foundation will use commercially reasonable efforts to correct any factual inaccuracy or delete your Personal Information from our databases upon your request and in compliance with applicable laws. To honor your request, we will need the exact information you wish to correct, amend or delete.  To make a request to correct, amend or delete your Personal Information, please contact us at info@making-waves.org.

Third party content and services

Certain content provided through the Services may be hosted and served by third parties, including our Partners. In addition, the Services may link to third party web sites or content over which Making Waves Education Foundation has no control and which are governed by the privacy policies and business practices of those third parties. Please also note that Making Waves Education Foundation content and widgets may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data. Making Waves Education Foundation is not responsible or liable for the privacy practices or business practices of any third party. 

Security

Making Waves Education Foundation takes data security very seriously. Making Waves Education Foundation takes commercially reasonable technical, physical, and administrative security measures to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. In the event that Making Waves Education Foundation becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. If you have any questions about security on our Services, you can email us at info@making-waves.org.

International users

The Services are operated in the United States and intended only for Users located in the United States. However, if you access the Services from outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and acknowledge this transfer, processing and storage of your information in the United States.

Changes to this chatbot privacy policy

Making Waves Education Foundation may update this Chatbot Privacy Policy at any time and any changes will be effective upon posting. Upon any update the “Last Updated” date at the top of this policy will be updated. In the event that there are material changes to the way we treat your Personal Information, you are responsible for regularly reviewing this Chatbot Privacy Policy and your Making Waves Education Foundation account for notice of such modifications. Your continued use of the Services following an update to this Chatbot Privacy Policy will constitute your acceptance of the updated Chatbot Privacy Policy. We will notify you of material changes to the Chatbot Privacy Policy on our website and/or by email, and, if required by law, make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services. 

Question or comments

If you have questions about this Privacy Policy or to request corrections, amendments or deletions to any Personal Information that you have provided through the Site, please contact us at info@making-waves.org or call us at 510-275-7330.