YOJO Privacy Policy

1.1 Information We Collect Directly

We may collect information you directly provide us, such as when you register on the Site, subscribe to a newsletter, or contact us. This may include:

• Contact information, such as your name, email address, and phone number
• Learner/student profile information, including your education and career background, areas of study that interest you, types of programs you are interested in, and mentoring interest
• Authentication information, such as your username and password
• Other information you provide when you communicate with us, such as when completing our "Contact Us" form

1.2 Information We Automatically Collect

When you access the Site, we may automatically collect information about your device and usage, including:

• IP address
• Device identifiers such as MAC address
• Referring URL
• Browser type and version
• Operating system and version
• Pages viewed on the Site
• Time and date of visits
• Interactions and transactions with the Site, including time spent on the Site
• Other traffic and usage data
• Other information collected

We may collect this information using cookies, pixels, web beacons, and similar technologies to enhance your experience on the Site. A "cookie" is a unique numeric code transferred to your computer to track your interests and preferences and recognize you as a return visitor. A "web beacon" is a transparent graphic image placed on a website, email, or advertisement that enables monitoring things such as user activity and site traffic. We use these and similar technologies to collect information such as browser type, transactions and interactions, time spent on online services, visited pages, referring URLs, and other traffic and usage data. We may use this information to determine what features interest our users and revise our site features or operations, as further described below. We and other parties that provide these technologies may also use these technologies to collect information about your online activities over time and across third-party websites or other online services.

Google Analytics is one of the technologies we use to learn more about how visitors use the Site. Google Analytics uses cookies to help us analyze how visitors use the Site. The information generated by the cookies about your use of the Site includes your IP address. If you so choose, you can opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google collects, uses, and discloses information, please visit Google's Privacy & Terms.

For more information, see the "Your Choices" section below.

We may use, disclose, transmit, transfer, store, and otherwise process the information we collect for various purposes, including:

• Conducting our business and providing our services to you and others, including to match you to mentors and programs
• Providing, developing, maintaining, personalizing, protecting, modifying, and managing the Site, our services, and our organization
• Communicating with our contractors, service providers, and other third parties we use to support our organization and the Site
• Communicating with you, including responding to your inquiries or requests
• Debugging, identifying, and repairing errors and effectuating similar functional enhancements for our Site, services, and organization
• Modifying our services and user experience
• Understanding how you and others use our Site and determining what features and services may interest you and others
• Legal and safety purposes, such as maintaining the safety, security, and integrity of our Site, other technology assets, services, and our organization, protecting the legal rights, property, safety, and security of us, our users, our employees, and others
• Protecting against malicious, deceptive, fraudulent, or illegal activity and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
• Enforcing our policies, terms of use, contracts, or other legal rights.
• Investigating or preventing unlawful activities or misuse of the Site
• Evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, including as part of bankruptcy, liquidation, or similar proceedings
• Creating aggregate or de-identified data for internal analytics, research, and platform improvement. YOJO will not use student education records or personal information collected from minors to build or improve products or services sold to third parties, consistent with applicable student privacy laws including FERPA, SOPIPA, and NY Education Law 2-d
• Such other purposes as you may authorize or that we otherwise disclose

We may disclose your information for any purposes described in the How We Use Your Information section above. We may disclose your information:

3.1 To Other Users

We may share your information with other users, such as potential mentors, mentees, and program administrators.

3.2 To Service Providers

We may share your information with third-party contractors, service providers, and other third parties who perform services on our behalf, such as hosting, analytics on the Site, or email and communications delivery.

3.3 For Legal Purposes

We may disclose your information:

• For legal and safety purposes, such as maintaining the safety, security, and integrity of our Site, other technology assets, services, and our organization, protecting the legal rights, property, safety, and security of us, our users, our employees, and others
• To protect against malicious, deceptive, fraudulent, or illegal activity and participate in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
• To enforce our policies, terms of use, contracts, or other legal rights.
• To investigate or prevent unlawful activities or misuse of the Site

3.4 For Business Transactions

We may disclose your information to an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, including as part of bankruptcy, liquidation, or similar proceedings. In any such event, we will endeavor to notify affected users by email or by a prominent notice on the Site prior to your personal information becoming subject to a different privacy policy.

3.5 With Your Authorization

We may disclose your information to such other parties or such other purposes as you may authorize or that we otherwise disclose.

We respect your privacy and offer choices regarding our collection and use of your personal information.

4.1 Not Providing Information

You may choose not to provide the information we request. However, not providing the requested information may restrict your ability to use certain Site features and our services. For example, we cannot assist with placing you with a mentor or program if we do not have sufficient information about you and your interests.

4.2 Opt Out of Certain Email Communications

You can opt out of receiving communications by following the unsubscribe instructions included in those emails, updating your notification settings at YOJO.Center, or contacting us directly.

4.3 Automatic Collection Choices and Do Not Track

You may be able to restrict the collection of information or functionality through your device's operating system or by disabling cookies, but doing so may prevent you from using the Site's functionality.

Some Internet browsers have a "do-not-track" feature that lets you tell websites that you do not want your online activities tracked. We currently do not respond to "do-not-track" signals from web browsers. Other parties may collect personal information about your online activities over time and across different websites, applications, and other online products or services when you use the Site.

4.4 Right to Delete Your Account and Data

You may request deletion of your YOJO account and associated personal information at any time by contacting us. Upon a verified deletion request, we will remove your personal information from our active systems within a reasonable timeframe, except where retention is required by law, necessary to complete a transaction you initiated, or needed to comply with our legal obligations. Note that some information may remain in backups or logs for a limited period before being purged.

4.5 Users Under 18

If you are under the age of 18 and a registered user of the Site, you may request and, in certain circumstances, obtain removal of any content or information you posted on the Site that is visible to another user. Removal of such content or information may not ensure complete or comprehensive removal of all content or information you posted. To request removal of information, contact us via our contact form.

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. Please review the privacy policies of any third-party sites you visit.

6.1 YOJO's Own Practices

YOJO takes the privacy of minor users seriously. For users under the age of 18, we limit data collection to what is necessary to provide the Services and do not use minors' personal information for advertising or marketing purposes. For users under the age of 13, account creation requires consent from a parent or legal guardian, or must be initiated by an authorized program administrator under an executed Data Processing Agreement. See our Terms of Use (§14) for full details of our COPPA practices.

6.2 Third-Party Program Privacy Practices

Programs listed on YOJO.Center that serve minors operate under their own privacy policies, practices, and protocols. YOJO is not responsible for the data practices of third-party programs. Before submitting a minor's data to any program, the minor user and their parent or guardian should review that program's privacy policy.

6.3 Parental Rights

Parents and legal guardians of minor users may at any time request access to, correction of, or deletion of their child's personal information held by YOJO by contacting us. We will respond within 10 business days.

We are committed to making this Privacy Policy accessible to all users. If you require assistance or an alternative format, please contact us via our contact form.

We may update this Privacy Policy from time to time. An updated "Effective Date" will indicate the revised version, and we encourage you to review the privacy policy periodically.

If you have questions or concerns about this Privacy Policy or our data practices, please contact us via our contact form.

Thank you for trusting YOJO.Center.

10.1 How Long We Keep Your Data

We retain your personal information for as long as your account is active, or as needed to provide you with the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Active accounts: Personal information is retained for the duration of your account and for a reasonable period after account closure to allow for re-activation or legal compliance.
• Inactive accounts: Accounts with no activity for more than 12 months may be deactivated. You will receive prior notice before any deactivation or deletion.
• Application records: Records submitted in connection with a program application may be retained for longer periods as required by the program administrator or applicable law.
• Legal holds: Some data may be retained longer than standard retention periods if subject to a legal hold or regulatory requirement.

10.2 Deletion Requests

You may request deletion of your account and personal information at any time (see §4.4). Upon a valid request, we will delete or anonymize your personal information from our active systems within 30 days, subject to the exceptions noted in §4.4.

11.1 Technical and Organizational Measures

YOJO implements reasonable technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, loss, and destruction. These measures include:

• Encryption of data in transit using TLS/HTTPS.
• Encryption of sensitive data at rest.
• Access controls limiting employee access to personal information to those with a legitimate business need.
• Regular review of data collection, storage, and processing practices.
• Use of reputable, security-vetted cloud infrastructure and service providers.

11.2 No Absolute Guarantee

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you assume some risk in providing personal information online. In the event of a data breach affecting your information, we will notify you in accordance with our breach notification obligations described in our Terms of Use (§15).

Where YOJO processes student education records on behalf of an educational institution subject to the Family Educational Rights and Privacy Act (FERPA), YOJO acts as a school official with a legitimate educational interest as defined under 34 C.F.R. § 99.31(a)(1). In that capacity, YOJO uses student education records only to provide contracted services and does not disclose them to third parties except as permitted by FERPA.

Institutional customers processing student education records must execute a Data Processing Agreement with YOJO (see §15) prior to deploying the platform for student use. Full details of YOJO's FERPA obligations are set out in the Terms of Use (§13).

Depending on where you live, you may have additional rights regarding your personal information under applicable state law, including the California Consumer Privacy Act (CCPA/CPRA), Virginia CDPA, Colorado CPA, Connecticut CTDPA, Texas TDPSA, and others. These rights may include:

• Right to know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purpose for collecting it, and the categories of third parties with whom we share it.
• Right to access: You may request a copy of the personal information we hold about you.
• Right to correct: You may request correction of inaccurate personal information.
• Right to delete: You may request deletion of your personal information, subject to certain exceptions (see §4.4 and §10).
• Right to opt out of sale/sharing: YOJO does not sell personal information for monetary consideration. YOJO does not share personal information with third parties for cross-context behavioral advertising.
• Right to non-discrimination: We will not discriminate against you for exercising any of these rights.

How to Submit a Request

To exercise any of the rights above, please contact us via our contact form. We will verify your identity before processing your request and respond within the timeframe required by applicable law (typically 45 days, with a possible 45-day extension).

California Shine the Light (Cal. Civ. Code § 1798.83)

California residents may request information about disclosures of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for direct marketing purposes.

YOJO is based in the United States. If you access the Services from outside the United States, your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

For users in the European Union, United Kingdom, or Switzerland, any transfer of personal data outside those regions will be carried out in accordance with applicable data protection law, including through the use of Standard Contractual Clauses (SCCs) approved by the European Commission, or other lawful transfer mechanisms. By using the Services, you acknowledge and consent to the transfer of your information to the United States.

If you have questions about cross-border data transfers, contact us.

Institutional and enterprise customers who process personal data subject to GDPR, UK GDPR, CCPA/CPRA, FERPA, or applicable state student privacy laws in connection with their use of YOJO are required to execute a Data Processing Agreement (DPA) with YOJO before deploying the platform.

A DPA governs how YOJO processes personal data on behalf of the institution as a data processor (or service provider), sets out each party's responsibilities, and includes the technical and organizational measures YOJO applies to protect that data.

To request a DPA, please contact us with the subject line "DPA Request." We will respond within 10 business days.