PRIVACY POLICY

Last updated December 11, 2025

CONNECT TO COMPETE INC. (doing business as Everyone On) ("we," "us" or "our"), provides certain services through the TechHubNYC.org website in partnership with the New York Office of Technology and Innovation. This Privacy Policy describes how and why we might access, collect, store, use and/or share ("process") your personal information when you use our services ("Services").

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us as described in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below .

1. WHAT INFORMATION DO WE COLLECT?

PERSONAL INFORMATION YOU DISCLOSE TO US

In Short: We collect personal information that you provide to us when you create an account on TechHubNYC.org and register for digital skills classes provided on the platform. We occasionally collect information from public databases, marketing partners, social media platforms and other outside sources to ensure we have the most accurate and up-to-date information to provide you with digital inclusion resources.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us our and Services, when you participate in activities on the Services or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the features you use. The personal information we collect may include the following:

  • Name

  • Email address

  • Borough

  • Housing development

The demographic information that you provide to us must be true, complete and accurate to confirm truthful identity and that you live in the NYCHA community in which TechHubNYC.org is an exclusive benefit and service. 

If you provide other personal information in response to a class or Services prompt, we will process and store it in your account. We do not ask users to provide "special" or "sensitive" information such as racial or ethnic origins, sexual orientation and religious beliefs but if you volunteer that information when using the Services, we will collect and store it.

INFORMATION AUTOMATICALLY COLLECTED

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps") and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us to send you digital skills resources and keep you informed about digital equity news. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

  • To post testimonials. We may post testimonials on our Services that may contain first name and city.

  • To evaluate and improve our Services, marketing and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our outreach campaigns and to evaluate and improve our Services, marketing and your experience.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests and exercise, establish or defend our legal rights.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights or to fulfill our legitimate business interests.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may disclose your personal information to third parties in the situations below:

TechHubNYC.org: Your personal information may be shared with NYC Office of Innovation and Technology. Your personal information will only be used to promote TechHubNYC.org and Everyone On classes and resources.

Vendors and Service Providers: To assist us in meeting business operations needs, to help complete a transaction for you, and to perform certain services and functions, we may share personal data with vendors, service providers and affiliate companies.

Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively a “Transaction”), your personal data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

Other Users: Certain actions you take to post information on our Service may be visible to other users of the Service.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences and assist with basic site functions.

You can opt out of these online tracking technologies by submitting a request as described below under sections WHAT ARE YOUR PRIVACY RIGHTS? and “CONTROLS FOR DO-NOT-TRACK FEATURES”. 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information in your account until your account is deleted. We may also retain your contact information separately in order to send you marketing and promotional communications as described above.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

The website encrypts data using secure cryptographic algorithms. All data in transit is encrypted using TLS 1.2 or greater. The website leverages AES-256 encryption for data at rest. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. 

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

The Service is not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we learn that we inadvertently collected personal information from a child under the age of 13, we will delete that information as quickly as possible. If you are a parent or guardian of a child who you believe provided TechHubNYC.org with personal information without your consent, please https://www.everyoneon.org/contact-us.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In many jurisdictions, residents have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as support service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, contact us.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.


12. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, contact us.

14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update or delete your personal information, please contact us as described above.