Privacy Policy

Overview

In Tandem is a non-profit organization that connects youth with youth-serving organizations to ensure that youth voice is integral to the development of their offerings.  We use the information we collect to fulfill our mission to ensure that all youth have a voice in every major decision that affects them.

In Tandem is committed to protecting our users’ privacy. This Privacy Policy (the “Policy”) provides information about how we collect, store, use, and disclose information when you use or access our website located at in-tandem.org and any of our other websites, their respective subdomains, and software applications operated by or on behalf of In Tandem (collectively, our “Sites”) and the services available on the Sites (“Services”).  When personally identifiable information is collected, used, or disclosed in relation to our Youth Voice Fellowship (“The Fellowship”), which is one of our Services, it is subject to additional protections as detailed below in the Youth Voice Fellowship Privacy Policy. A summary of this Privacy Policy can be found here.

If you have any questions about our privacy practices, please contact us directly at hello@in-tandem.org.

What information is collected through the Sites and Services?

In Tandem collects any information that you provide when you use the Sites and Services, including when you use our web applications, sign up for our Youth Voice Fellowship, or contact us with a question. This information may include your contact information, and information that you enter to complete an application.

In addition, we may collect certain technical information about your use of the Sites, such as:

  • browser type, language, plug-ins, Internet domain and operating system;
  • Internet Protocol (IP) address;
  • unique identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
  • information collected through cookies, which are small text files stored on users’ computers to save information about the use of websites, such as our web applications; and
  • information related to your interactions with the Sites, such as the type of content viewed on the Sites.

Does In Tandem collect personally identifiable information from children under 13 years old?

No. In Tandem Sites and Services are intended for general audiences and are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are under 13 years of age, then you are not permitted to use the Site and Services in any manner that reveals personally identifiable information about yourself (such as your name, email, address or location). 

We allow minors ages 13 and up to use our Sites and Services.

How does In Tandem use and disclose information collected through the Sites and Services?

We may use this information to provide you with the products, services, or information you request; deliver communications that you request or which may be of interest to you; maintain, develop, support, improve, analyze, and troubleshoot the Sites and the Services; customize the content you see when you use the Sites; and when we believe in good faith it is necessary to protect the safety of users or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Sites or Services.

In Tandem will not disclose your information to any third party except as otherwise stated in this Policy and in the following circumstances:

  • when directed or consented to by you;
  • to service providers who work on our behalf and will use the information in furtherance of our operations, and in accordance with our privacy commitments;
  • in response to subpoenas, court orders, or legal process, or to comply with government reporting obligations pursuant to law;
  • when we believe in good faith it is necessary to protect the safety of users or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Sites or Services; or
  • to service providers, advisors, potential transaction partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets in bankruptcy or otherwise.  If some or all of our assets are acquired or otherwise transferred, including in bankruptcy, the acquirer will be permitted to maintain the information transferred, subject to confidentiality agreements, the terms of this Policy, and applicable law.

In Tandem may post testimonials from users, in the form of written materials or videos, reflecting a user’s individual experience in using the Sites. If a user testimonial includes information identifying you, In Tandem will obtain your consent prior to posting such testimonial on the Sites.

The Sites or Services may contain links to websites or apps, or contain integrated content (like embedded videos) provided by third parties.  For example, video content on the Sites may be provided by services such as Vimeo or YouTube.  The information practices of those third parties may differ from ours.  You should consult the privacy policies of any such third party that links from the Sites or provides content that you access through the Sites or Services, as we do not control and are not responsible for the information that they collect, use, or share.  Because your web browser may obtain integrated content directly from third-party servers, the third parties may be able to collect information as if you had visited their websites directly.

How does In Tandem secure information collected through the Sites and Services?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of personally identifiable information collected through the Sites against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

In Tandem may use one or more third-party service providers (“Vendors”) to help host the services.  Each Vendor has been vetted by In Tandem with respect to the Vendor’s representations about how personally identifiable information is transmitted, stored, processed, and maintained by the Vendor.

Will In Tandem make changes to this Policy?

We will not make changes to this Policy that would give In Tandem the ability to use information collected from users through the Sites in a way materially inconsistent with this Policy, without first providing prominent notice to users to allow them to choose whether to continue to use the Sites in accordance with the new Policy.  Similarly, we will not make changes that would give In Tandem the ability to use PII, as defined below, in a way materially inconsistent with the privacy provisions below or any contractual requirements, without first providing notice to youth-serving organizations (“Organizations”), parents or youths as applicable, to allow them to choose whether to continue to use The Fellowship in accordance with these changes.

Youth Voice Fellowship Privacy Policy

This section explains how information is collected, used, protected, and disclosed through our Youth Voice Fellowship (“The Fellowship), which is one of our Services.

The Fellowship connects Organizations with youth participants, including students, to collaborate on and co-design products, services, and tools in a privacy-protective way.  Organizations create activities that they make available through The Fellowship, which come in various forms including surveys, open-ended responses, short video clips, interviews and/or focus groups. Parents/legal guardians consent to allow their child to participate in activities while limiting the amount of personally identifiable information provided back to the Organizations.

Youth participants can join The Fellowship if they have reached the age of majority (18 in most states); if they are under the age of majority, youth participants provide assent and their parents/legal guardians provide consent. 

What personally identifiable information is collected through The Fellowship?

Through The Fellowship, we collect information from youth participants that are linked to those participants in a way such that they can be identified with reasonable certainty (“personally identifiable information” or “PII”). 

To participate in The Fellowship activities, youth participants may be asked to provide their email address, first and last name, birth date, state and zip code of residence, and the email address and phone number of their parent or legal guardian in addition to basic demographic information. We will contact the parent or legal guardian of those youth participants who are under the age of majority to obtain parental consent.

Through the activities, youth participants may provide responses to questions related to products (e.g., websites), services (e.g. tutoring), tools (e.g., curriculum) or other youth-facing materials (e.g., surveys and forms). Activities may call for written responses or involve live interactions via a video meeting platform (e.g. Zoom). Questions include topics such as accessibility, appeal, language, attitudes about, and youths’ experiences related to, the products, services, tools, or other materials and their contexts (e.g., schools, and classrooms). Participation is voluntary, and youth participants may stop at any time.

In addition, we may collect certain technical information about use of The Fellowship, such as browser type, Internet Protocol (IP) address, and information collected through cookies.  For more details on the technical information collected through The Fellowship, please refer to the “What information is collected through the Sites and Services?” section above.

In an effort to implement best practices to protect youth participants’ privacy, we make a number of commitments related to PII:

  • We will not collect, use, share, or retain PII for any purpose other than as authorized.
  • We will not share PII with Organizations unless authorized, and then only subject to strict protections.
  • We will not sell PII.
  • We will not build a personal profile of a youth participant other than to facilitate our services.
  • We will support access to and correction of PII by youth participants or their parents.
  • We will maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

How does In Tandem use and disclose personally identifiable information through The Fellowship?

We use the PII collected through The Fellowship to provide our Services, including as needed to maintain, develop, support, improve, analyze, or troubleshoot those Services.  We will not use or disclose a youth participant’s PII for any purpose other than as authorized by the participant and/or their parent/legal guardian, including those purposes described in this Youth Voice Fellowship Privacy Policy.

This is how it works.  Information collected from youth participants through The Fellowship is stored by In Tandem, and may include PII. In Tandem will take measures to limit and secure PII provided to Organizations, such that Organizations will receive only the PII necessary to complete their project (e.g., one’s likeness in a video session or recording) and shared through secure (i.e., encrypted) channels.

It is possible that some youth participants may volunteer PII in a free-form response that is provided to an Organization, or that some parents/legal guardians will authorize activities involving the collection of PII, for example during participation in a video interview. Whenever an Organization receives PII, the Organization is required to use the information only in support of the project and consistent with our policies, including being prohibited from disclosing PII to parties not involved in their project. 

Otherwise, In Tandem will not use or disclose PII collected through The Fellowship except in the following circumstances:

  • when directed or consented to by the parents (or the youth participant, if they have reached the age to consent for themselves), or by the administrator of a school’s account if we are acting as a School Official pursuant to FERPA;
  • to service providers who work on our behalf and who will use the PII in furtherance of our operations, in accordance with our privacy commitments;
  • in response to subpoenas, court orders, legal process, or to comply with government reporting obligations pursuant to law;
  • when we believe in good faith it is necessary to protect the safety of youth participants or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of The Fellowship;
  • to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets in bankruptcy or otherwise.  This means that if some or all of our assets are acquired or otherwise transferred, including in bankruptcy, the acquirer will be permitted to maintain the PII transferred, subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law.

How does In Tandem secure PII collected through The Fellowship?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of PII against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.  Our risk management includes maintaining a comprehensive security program, providing resources to Organizations on protecting the privacy of PII, and periodically evaluating our information systems to mitigate potential vulnerabilities.

In Tandem may use one or more third-party service providers (“Vendors”) to help host the Services.  Each Vendor has been vetted by In Tandem with respect to the Vendor’s representations about how PII is transmitted, stored, processed, and maintained by the Vendor.  If In Tandem partners with a school to collect youth PII (“Student PII”) in service of that school’s support for its students , In Tandem will enter into an appropriate agreement with each Vendor that comports with In Tandem’s role as a School Official and/or as a Research Studies provider under FERPA.

What rights do schools and parents have with respect to personally identifiable information collected through The Fellowship?

For activities authorized by parents/legal guardians, they may contact us using the information provided below to review and/or request that we delete the PII we have collected from youth participants under their consent. Parents may also refuse to permit further collection or use of the PII. If you are a parent/legal guardian and discover that your child who is under 13 years old has attempted to apply to The Fellowship, then you may alert us and request that we delete that child's personally identifiable information from our systems.

To exercise these rights, or if you have questions about our verifiable parental consent process, please contact us as described below. 

If In Tandem collects Student PII through The Fellowship for activities conducted with or authorized by schools, that Student PII remains under the direct control of the school, and we use Student PII only for purposes authorized by the school.  Therefore, schools retain the right to ask In Tandem to access, correct, or delete Student PII, and In Tandem will always support access to and correction of Student PII by parents consistent with legal requirements. Because Student PII collected through The Fellowship remains under the direct control of the school, parents who may have any concerns about the collection or use of Student PII through The Fellowship should contact their school.  If you are not sure who at your student’s school will be able to help, feel free to contact us at youth@in-tandem.org.

Can schools use The Fellowship in compliance with FERPA?

Yes.  The Fellowship enables schools to comply with FERPA. 

FERPA applies to “educational agencies and institutions” that receive federal funding from the Department of Education.  For example, most K-12 public schools are subject to FERPA.  Because In Tandem is not an “educational agency or institution,” it is not directly subject to FERPA.  However, to the extent that In Tandem collects Student PII, FERPA may require the school to impose certain restrictions on how In Tandem can use and disclose that information.

Under FERPA, schools can permit third parties like In Tandem to collect Student PII on its behalf, without parental consent, in limited circumstances, including:  (1) where In Tandem serves in the role of a “School Official” as defined by FERPA, and (2) where In Tandem facilitates particular research studies under FERPA.

What obligations does In Tandem have with respect to students’ civil rights?

Although civil rights obligations under federal or state law may apply to any schools that might partner with In Tandem, In Tandem will use commercially reasonable efforts to provide any legally required accommodations under such legal requirements, including those that prohibit discrimination against students and other youth with disabilities and English Language Learners.

 

Contact us

If you have any questions about this In Tandem Privacy Policy, please contact us at:

In Tandem
25 Broadway, Fl 3
New York, NY 10004
hello@in-tandem.org

This Privacy Policy is effective as of August 2024.

*To review a summary of the Privacy Policy, click here.