WIN-NextGen™ Privacy Policy

Effective Date: October 1, 2026

WIN-NextGen, Inc. (“WIN-NextGen™,” “we,” “us,” or “our”), a 501(c)(3) nonprofit organization, operates WIN-NextGen.org, a digital workforce development platform (the “Platform”). WIN-NextGen™ respects your privacy, and we take seriously our responsibility to protect the information you share with us.

This Privacy Policy explains what information we collect, why we collect it, how we use and share it, and how you can review, update, and delete it when you use our website, Platform, mobile experiences, and other services (together, the “Services”).

The Platform serves students from middle school through young adulthood. Because we serve users who may be minors, we provide additional protections for students ages 11–13, as described in Section 1.

By using the Services, you agree to this Privacy Policy, our Terms of Service, and our Cookie Policy. For students ages 11–13, a parent or guardian must review and accept this Privacy Policy on the student’s behalf before the student’s account is activated.

If you have questions about this Privacy Policy, please ask a parent or guardian to help you, or contact us at admin@win-nextgen.org.

1. A Special Note for Parents: Middle School Students

The Platform is intended for students from middle school through young adulthood. “Middle School Students” means students in Grades 6–8, or students ages 11–13, including homeschool students and others not enrolled in a traditional grade.

We do not knowingly collect personal information from children under 11. At sign-up, we ask for an age range and grade level, not date of birth. Children under 11 may not create an account; their parent or guardian is welcome to contact us at admin@win-nextgen.org.

Every student ages 11–13 needs parent or guardian approval before their account is activated, whatever their grade. We follow the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and the Federal Trade Commission’s COPPA Rule, and we apply the same protections to all students ages 11–13.

How approval works.

1. The student selects age 11, 12, or 13 and enters only their name, a username or email address for logging in, a password, and their parent or guardian’s name and email address.
2. The account stays in pending While it is pending, we collect no other information and the student cannot use the Platform.
3. We email the parent or guardian a notice explaining what information we collect, how we use and share it, and their rights, with a link to this Privacy Policy and a way to approve or decline the account. We may send a reminder before the deadline below.
4. When the parent or guardian approves, we activate the account and send a confirmation email, followed a few days later by a second email confirming the approval. The parent or guardian may withdraw approval at any time.
5. If the parent or guardian declines, or does not respond within 30 days, we delete the pending account and all information collected for it, including the parent or guardian’s contact information.

We do not accept a parent or guardian email address that matches the student’s own email address.

Separate choice about sharing with partners. In the same step as approving the account, parents and guardians choose whether to share their student’s information with any of the partner organizations listed, each of which runs an active program with us under a written agreement. For each partner chosen, the parent or guardian signs and returns a partner-sharing form, and we turn on that partner’s access only after the signed form is verified. A partner added later requires new permission. A student may use the Platform without sharing with any partner, and parents and guardians may change their choices at any time.

School-sponsored participation. When a school or district enrolls students under a written agreement with us, the school may provide consent on parents’ behalf for educational purposes only, and we use that information solely for those purposes.

2. FERPA and Student Data Privacy Laws

When we operate under a written agreement with a school, school district, or educational institution, we handle student education records in accordance with the Family Educational Rights and Privacy Act (FERPA). Under that agreement, we act as a “school official” with a legitimate educational interest, under the school’s direct control over how education records are used and maintained. We use education records only for the educational purposes the school authorizes, do not redisclose them except as the school permits and FERPA allows, and do not sell them or use them for targeted advertising.

Parents and eligible students who want to review or correct education records held for a school should contact that school, and we will support the school in responding. We also comply with applicable state student data privacy laws, including Maryland’s Student Data Privacy Act, and with any data privacy agreement a school or district requires.

3. Information We Collect

Information you provide

• Account information: your name, a username or email address, a password, your age range, your grade level, and your school or organization affiliation. Students age 14 and older may also provide a phone number or mailing address. Students ages 11–13 also provide a parent or guardian’s name and email address (see Section 1).
• Location: your city, state or region, and country, used to match you with local programs and partners and for regional reporting. For students ages 11–13, we collect location only after a parent or guardian approves the account.
• Platform activity: career interests, assessment responses, learning progress, badges earned, mentorship preferences, and messages, uploads, or submissions you make. Messages sent through the Platform’s chat are visible to WIN-NextGen™ staff to help keep the Platform safe.
• Newsletters, emails, and text messages: your email address or mobile number.
• Photos and videos (optional): photos and videos taken at WIN-NextGen™ program events, used only with permission. Permission is given separately for WIN-NextGen™ and for each program partner. Learners 14 and older give it themselves at sign-up. For learners ages 11–13, a parent or guardian decides: for WIN-NextGen™ during approval, and for each partner on the signed partner consent form.
• Events: the registration information an event requires. Events hosted by third parties may have additional policies, and we will tell you before you register.
• Surveys, polls, and emails to us: your responses and messages. Surveys are always optional.

Information collected automatically. When you visit the Platform, we and our analytics providers collect device type, browser type, IP address, pages visited, and how you arrived at the Platform (see Section 6).

Information from partners. Schools, employers, mentors, and learning partners may provide limited information, such as a roster, to give you access to the Platform.

We do not ask students for biometric identifiers or government-issued identification numbers.

4. How We Use Information

We use the information we collect to:

• Provide and personalize your Platform experience
• Match you with career pathways, learning content, mentors, and opportunities
• Track your progress and deliver badges, rewards, and other gamified features
• Contact you about your account, programs you take part in, awards, and your questions
• Send educational content and updates you have signed up for
• Monitor compliance with our Terms of Service and keep the Platform safe
• Operate, secure, and improve the Platform and our programs

Limits for students ages 11–13. We use a student’s information only to provide the Services and support the Platform’s internal operations. We do not use it for advertising, for marketing on behalf of other organizations, or to build profiles for non-educational purposes. The one exception is sharing program photos and videos when a parent or guardian has given permission, as described in Section 3.

5. How We Share Information

We do not sell personal information. We share it only in the situations below.

• Service providers. Companies that host the Platform, send our emails, or perform other services for us may access personal information only to do that work. They may not use it for their own purposes, and we require them to keep it secure.
• Third-party events. When you register through us for an event hosted by a third party, we share your registration information with that host and tell you which policies apply. For students ages 11–13, we do this only with a parent or guardian’s permission.
• Partner organizations. With your permission, we may share your personal and academic information with partner institutions so they can offer you opportunities. For students ages 11–13, this requires a parent or guardian’s separate, signed permission for each partner (see Section 1). Partners’ Group Leaders and Executive Sponsors see only the student’s name, grade, city, state, country, progress, and badges, plus the parent or guardian’s name and email for program logistics, but not the student’s own contact information. We require partners to protect the information at least as well as this Privacy Policy does.
• Photos and videos. With the permission described in Section 3, WIN-NextGen™ and each partner a learner has joined may share photos and videos from program events to share and promote WIN-NextGen™ programs, but only if permission was given for that organization. Permission given to WIN-NextGen™ does not cover a partner, and permission given to a partner does not cover WIN-NextGen™. Learners are identified by first name only. We do not publish a learner’s address, contact information, or school, and do not sell their image. Permission can be withdrawn at any time.
• Legal requirements and safety. We may share personal information when required by law or legal process, or to protect the safety, rights, or property of our users, WIN-NextGen™, or others.

We may also share aggregated, de-identified information, such as visitor counts and the most popular pages, with partners, sponsors, schools, and funders. This information does not identify you.

Some links on the Platform take you to offers or programs run by other organizations. Information you give on those sites goes to them, not to us, and is governed by their privacy policies.

6. Cookies, Analytics, and Communications

Cookies and analytics. We use cookies and analytics tools, such as Google Analytics, to keep you signed in, make the Platform work, and measure visits in aggregate. We do not use them for targeted or personalized advertising. For students ages 11–13, we use them only to support the Platform’s internal operations. You can manage cookies through our consent banner and your browser settings. See our Cookie Policy for details.

Email. We send account, program, and educational emails, and newsletters to those who sign up. You can unsubscribe from newsletters at any time using the link in the email or by contacting admin@win-nextgen.org.

Text messages (SMS). With consent, we send texts about events, programs, purchases, and account changes. For students ages 11–13, a parent or guardian must provide this consent. Reply STOP to opt out and START to opt back in. Message and data rates may apply.

7. Data Security

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect personal information, including information about students ages 11–13. If a security incident affects your personal information, we will notify you, and for students ages 11–13 their parent or guardian, as the law requires.

8. Data Retention and Deletion

We keep personal information only as long as reasonably necessary for the purpose it was collected, and then delete it securely. We do not keep information about students ages 11–13 indefinitely.

When you, or a parent or guardian, ask us to delete information, we will do so within 30 days, except where the law requires us to keep it.

9. Your Rights and Choices

You may:

• Access, correct, or update your personal information through your account profile or by contacting us
• Ask us to delete your personal information
• Withdraw a consent you have given
• Opt out of newsletters, marketing emails, and text messages

Rights of parents and guardians of students ages 11–13. A parent or guardian may at any time:

• Review the personal information we have collected from their student
• Ask us to correct or delete it
• Withdraw approval and stop further collection or use, which will close the student’s account
• Change their choice about sharing their student’s information with partner organizations, without closing the account

To make any request, email admin@win-nextgen.org. We will verify that a request comes from the student’s parent or guardian before acting on it.

There are limits. Information already shared with another organization before your request is governed by that organization’s policies, and we may need to keep certain records when the law requires it.

10. Third-Party Links

The Services may link to websites and services run by other organizations. This Privacy Policy does not apply to them, and we are not responsible for their content or privacy practices. Please read their privacy policies before providing any personal information.

11. International Users

The Platform is based in the United States. By using the Services, you agree that your information will be processed and stored in the United States in accordance with this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page with a new “Last Updated” date. For material changes, we will also notify users by email and post a notice on the Platform.

If a change would materially affect how we collect, use, or share information about students ages 11–13, we will notify their parents or guardians and obtain their consent before applying the change to that information.

13. Contact Us

If you have questions or concerns about this Privacy Policy or your personal information, please contact us.

Email: admin@win-nextgen.org

Mail:
WIN-NextGen, Inc.
Attn: Privacy Policy Administrator
9103 Woodmore Centre Drive, PMB 143
Lanham, MD 20706