Privacy Policy

Effective Date: 07/29/2020
Revised Date: 02/07/2024

General Points

• Healthy Adolescent Transitions only uses personally identifiable information (PII) for the functionality of Healthy Adolescent Transitions.
• Healthy Adolescent Transitions does not share, rent, sell, trade, or disclose PII.
• The Healthy Adolescent Transitions site has and will have no ads, and PII is not used for ad targeting.
• Your contributions on Healthy Adolescent Transitions are owned by you.
• When your account is deleted
  • All student submissions will be deleted.
• Healthy Adolescent Transitions may use de-identified data to improve Healthy Adolescent Transitions, e.g., to improve the user experience or to understand which functionality is often used and needs improving.
• Healthy Adolescent Transitions will not re-identify de-identified data.
• You can request a complete export of your data.
• In the case of a breach of user data, unless contractually or legally prohibited, we will communicate the breach and its extent as quickly as possible, but no later than 3 days after becoming aware of the breach.
• Healthy Adolescent Transitions has signed and is happy to sign strict data protection agreements, like the NDPA and New York State Model Data Privacy Agreement for Educational Agencies.
• Healthy Adolescent Transitions is FERPA, NY Ed Law §2-d and NY regulations §121 (Bill of Rights) compliant and can be used COPPA compliantly (when schools or parents consent to its use).
• We assume that we are compliant with any reasonable data privacy regulation world-wide, given that we are a privacy-first company, collect as little personal information as possible, and don’t abuse the little data we collect.  

Regarding Subcontractors

• Healthy Adolescent Transitions uses the following subcontractors that in theory could access PII:
  • Amazon AWS - the world’s biggest cloud infrastructure provider, which governments around the world are using to host confidential data.
  • If someone emails support, their message and email address may be stored in HubSpot, Office365, and Slack.
• We use first-tier subcontractors with whom we have signed rigorous confidentiality and data protection agreements.
• We reserve the right to change which subcontractors we use and will provide an up-to-date list upon request.

Data Privacy and What Data Is Collected

• Healthy Adolescent Transitions operates under a policy of minimizing the information we collect about users. The less data we collect, the better. Below is a list of data, apart from user contributions, which we do collect:
  • Healthy Adolescent Transitions’s firewall stores your IP for 30 days.  
  • Metadata your browser submits, like screen size, operating system etc., is currently not being collected.  
  • When you sign up with an email address, we store your email address, username, and password.
  • When you sign up via Google single sign-on, we store your Google account ID, email address, and derive your initial Healthy Adolescent Transitions user and display names from your Google account name. You can remove and change these data as you wish.
• All Healthy Adolescent Transitions use of cookies and browsers’ local store is essential for providing Healthy Adolescent Transitions functionality:
  • Healthy Adolescent Transitions uses cookies to log you in and to correctly associate your contributions and activities on Healthy Adolescent Transitions with your account.
  • Healthy Adolescent Transitions uses local store to store which popups you have already seen.
• Healthy Adolescent Transitions uses browser fingerprinting, session cookies, and tracking pixels to provide our service and collect user activity statistics for quality improvement purposes. No form of ad targeting is used by our systems.

Regarding Data Security

• Healthy Adolescent Transitions follows best practices of the Zero Trust Security model, which, in a nutshell, means that in order to gain access to a server or service, extensive user authentication has to always happen and that the least privileged access principle is followed.
• Healthy Adolescent Transitions minimizes who can access confidential data and currently only essential team members have access to all user data
• All administrative accounts are secured by strong passwords and two-factor authentication. Devices used to access confidential data use full disk encryption and are rigorously secured.
• Regular developers do not work with data from production systems, nor can they access the production systems themselves.
• All developers’ source code modifications are independently reviewed by another developer and new versions of Healthy Adolescent Transitions will only be deployed after the Quality Assurance and Release Team have successfully completed extensive automatic and manual tests.
• Support staff have the ability to look up the email address associated with a username to verify that a person with a support request is really who they are purporting to be.
• All staff have signed confidentiality agreements and those with access to confidential user data have received additional security and confidential data handling training.
• Healthy Adolescent Transitions user data is always encrypted in transit and at rest.
• Our production data is backed up hourly and the backups are stored for 30 days, after which they are destroyed.
• Our Incident Response Plan is available upon request.
• We have signed the Student Privacy Pledge 2020.

Google APIs Limited Use Policy

Healthy Adolescent Transitions's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.