Privacy Policy

The Social Impact Initiative website and service including (without limitation) impactinitiative.co and all other websites, mobile applications and other interactive properties through which the service is delivered (collectively, the/our “Service”) are owned, operated and distributed by the 7 Schwartz Brothers Leadership Trust, a registered Section 501(c)(3) nonprofit organization (referred to in this Privacy Policy as “Social Impact Initiative” or “we” and through similar words such as “us,” “our,” etc.). By accessing any part of the Service, you are agreeing to the terms and conditions described below (this “Privacy Policy”) and the terms and conditions of our terms of service (the “Terms of Service”). If you do not agree to any of these terms, you should not use the Service. This Privacy Policy applies to all users, including but not limited to users who are simply viewing content available via the Service, users who have registered as members of the Social Impact Initiative, and teachers, mentors, personnel, or administrators associated with any individual, entity, or group affiliated with or using the Service.

We may, at our sole discretion, modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Service or sending you an email. By accessing the Service at any time after such modifications, you are agreeing to be bound by the updated policy. This Privacy Policy was last modified as of August 21, 2020.

General

Your privacy is very important to us. Accordingly, we have developed this Privacy Policy in order for you to understand how we collect, use, communicate and disclose and make use of Personal Data (as defined below). The following outlines our privacy policy.

EU Personal Data

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in the EU Privacy Notice below.

Student-based And Other Qualifying Users

A “Qualifying Institution” is a school, college, university, organization, institution, entity, youth group, or youth movement that the Social Impact Initiative has, AT ITS SOLE DISCRETION, agreed to provide access to and/or accounts with the Service. 

If you are a student attending a Qualifying Institution or if you are a member of a Qualifying Institution and are accessing the Service through an account provided by the Qualifying Institution (a “Student-based User”), you may only access the Service if you are at least 13 years old.  

You must be 13 years of age or older to use our Service. If you are under the age of 16, you may not use our Service without parental consent. We do not knowingly collect or solicit Personal Data from anyone under the age of 16, unless you are a Student-based User (as defined in this Privacy Policy). If you are under 16, please do not attempt to register for the Service or send any Personal Data about yourself to us unless you are a Student-based User. If we learn that we have collected Personal Data from a child under age 16 who is not a Student-based User, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected].

Personal Data

When you register with us and become a Social Impact Initiative participant, when you choose to teach or attend a class, we will ask you for Personal Data. “Personal Data” refers to information about you that can be used to contact or individually identify you. This includes, but is not limited to, your name, email address, but does not include your credit card number or billing information. To the extent applicable, transactions involving your billing and payment information are processed by PayPal and Stripe and are subject to their privacy policies. We do not store any of the credit card or banking information that you provide to these payment processors.

In order to send you email from Social Impact Initiative, we need your email address. To provide you with additional services, we may also request your name, general location, and telephone number. We may give some or all of this information to the teachers for classes that you sign up for so that they can coordinate their classes. We will not give your name, email, or other Personal Data to unaffiliated third parties except with your consent or as otherwise set forth in this privacy policy. Though we employ industry standard measures to preserve user privacy, we may need to disclose Personal Data when required by law or when we have a good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process that we receive or to protect our interests or the safety of others. In addition, we may provide Personal Data to employees, consultants or other business or persons for the purpose of processing such information on our behalf. In such circumstances, we require that these parties agree to protect the confidentiality of such information and to comply with the terms of this Privacy Policy. We may use your Personal Data to operate, improve, understand and personalize our Service. Further, the Social Impact Initiative reserves the right to share any user data, including Personal Data, with any Qualifying Institution, partner, school, movement, or organization to further the goals of the Social Impact Initiative.  

Voluntary Disclosure

Any Personal Data or content that you voluntarily disclose in public areas becomes publicly available and can be collected and used by other users for any reason. Your profile pages (“Profile”) and any online classrooms you participate in are typically publicly available. You have the ability to change your account settings to limit access to your profile, and may delete content you post to public classrooms. If you need assistance with controlling your account privacy settings or with deleting content, please contact us at [email protected]. Removal of posted content does not ensure complete or comprehensive removal of the content or information (e.g., some content may be “invisible” to other users but remain on our servers in some form). You should exercise caution before disclosing your Personal Data via these or any other public venues.

For example, if you choose to sign up for a Social Impact Initiative account, you may have a Profile on the Service, containing your full name and some basic information including your location and bio. You may also add additional optional information to your Profile. You may control what type of Profile information is shown to others through your Account Settings. Any information you choose to provide as part of your Profile should reflect how much you want other Social Impact Initiative users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage members to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your profile information at any time.

Children’s Privacy

As noted in our Terms of Service, you must be 13 years of age or older to use the Service. If you are under 16 you may not use the Service without parental consent. We do not knowingly collect or solicit Personal Data from anyone under the age of 16, unless you are a Student-based User. If you are under 16, please do not attempt to register for the Service or send any Personal Data about yourself to us unless you are a Student-based User. If we learn that we have collected Personal Data from a child under age 16 who is not a Student-based User, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected].

Information About Cookies

We use your IP address to help diagnose problems with our server, to administer our Service, and to analyze traffic patterns on the Service. The Service also uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Service, to analyze trends, learn about our user base and operate and improve our Service. For example, we use Cookies to deliver content specific to your interests, to save your password so you don't have to re-enter it each time you visit, and to track whether emails we send you have been viewed. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Service. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties.

Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Service or using our Service, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Service. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, how often you return, how your use of the Service may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Service. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites.

Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Service, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.

We use the following types of Cookies:



You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some service and functionalities may not work.

To explore what Cookie setting are available to you, look in the “preferences” or “options” section of your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Third Party Advertising

We may use third party providers, including Facebook and Google AdWords, to advertise the Service across the internet. These providers may use cookies, web beacons, and other storage technologies to collect or receive information from the Service and elsewhere on the internet and use that information to provide measurement services and display targeted ads to you. 

A cookie is used to indicate to other websites that you visited a particular page, and allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. This cookie does not in any way give access to your computer or mobile device.

If you do not wish to see ads from us, you can opt out in several ways:


Other Sites

The Service may contain links to other websites or services. We are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure that you are comfortable with it before providing any Personal Data. For example, all teacher payments for classes are processed through third party payment processors. As discussed above, we do not receive any of the credit card information you provide to our third party payment processors, and all such information is subject to their privacy policies.

Teachers and Mentors

As discussed above, we may give your Personal Data to the teachers and Mentors for classes (“Teachers”) that you sign up for so that they can coordinate their classes. As part of our Terms of Use, Social Impact Initiative Teachers agree not to abuse other users' Personal Data. Abuse is defined as using Personal Data for any purpose other than those explicitly specified in the Teachers' Class. However, please understand that Social Impact Initiative Teachers are not our employees or consultants and that we are not party to any transaction between you and the Teacher. As a result, we cannot control their actions and cannot be held liable for any actions that they may take.

Business Transfers

In the event that we are acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from users, including without limitation Personal Data, as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your Personal Data is treated, transferred, or used.

Transfers to the United States

The Service is hosted in the United States. If you are accessing the Service from the European Union, please see the section titled “Transfers of Personal Data” in the EU Privacy Notice below. If you are accessing the Service from any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Service, which is governed by United States law, this Privacy Policy, and our Terms of Service, you are transferring your Personal Data to the United States and you consent to that transfer.

California Privacy Rights

California Civil Code Section 1798.83 permits users of the Service who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email with 'California Privacy Rights' in the heading to [email protected] or write us at the address listed below.

EU Privacy Notice

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this EU Privacy Notice section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but, in addition to the information identified in the Privacy Policy as Personal Data above, “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Social Impact Initiative will be the controller of your Personal Data processed in connection with the Service.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected].

What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business or education partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:



Information we automatically collect when you use our Service: Some Personal Data is automatically collected when you use our Service, such as the following:


How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Service. For example, we use Personal Data to:


We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.


How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:


We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:


We also share Personal Data when we believe it is necessary to:


We also share information with third parties when you give us consent to do so. Furthermore, you acknowledge that we may transfer your Personal Data, and that any acquirer of us or our assets may continue to use your Personal Data, as set forth in the “Business Transfers” section above.

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Service. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

Personal Data of Children: As noted above, we do not knowingly collect or solicit Personal Data from anyone under the age of 16, unless you are a Student-based User (as defined in this Privacy Policy) or student of another qualifying organization or youth movement as determined by the Social Impact Initiative.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.


Transfers of Personal Data: The Service is hosted and operated in the United States (“U.S.”) through Social Impact Initiative and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Social Impact Initiative in the U.S. and will be hosted on U.S. servers, and you authorize Social Impact Initiative to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.

Social Impact Initiative is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Social Impact Initiative’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit https://www.privacyshield.gov/.

Please contact us at [email protected] with any questions or concerns relating to the Privacy Shield. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this EU Privacy Notice or our data practices generally, please contact us using the following information:

Name: Henry Schwartz

7 Schwartz Brothers Leadership Trust.

Email address for contact:

[email protected]

Physical address:

156-02 Liberty Ave,
Jamaica NY 11433

The Privacy Policy, together with the Terms of Service, constitutes the entirety of agreements between you and Social Impact Initiative and supersedes all prior or contemporaneous agreements, representations, and understandings between you and Social Impact Initiative, whether written or oral. There are no representations, promises, warranties, covenants, or undertakings other than those contained on the Privacy Policy or the Terms of Service.