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Think Digital / Raly Report Privacy Policy

Last updated: May 29, 2026

Think Together, d/b/a Think Digital, a California non-profit corporation ("Think") respects your privacy and is committed to protecting it through its compliance with this policy and applicable state and federal laws, including the California Consumer Privacy Act of 2018 ("CCPA") and California Privacy Rights Act of 2020 ("CPRA"). This policy describes how Think collects, processes, retains, uses and discloses personal data about you when providing services to you through its website and any other services that link to this policy (our "Services").

Scope

This policy applies only to information Think collects through the Services and in communications, including email, text and chat, between you and the Services. It does not apply to information collected through any other means, including other websites or by any third party through any content that may link to or be accessible from or through the Services.

Think may provide additional or different privacy policies that are specific to certain features, services, activities or other websites.

Please read this policy carefully to understand Think's policies and practices regarding your information and how we treat it. By interacting with Think's Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Age Restriction

Our Services are not intended for, and we do not knowingly collect or disclose any personal information from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

Types of Data Collected

Think collects information that may identify, relate to, describe or reasonably be linked to you as an individual ("Personal Information"). Personal information does not include information that: (a) is publicly available, including from government records, or through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience; (b) lawfully obtained, truthful information that is a matter of public concern; or (c) deidentified or aggregated consumer information. The types and categories of Personal Information that we have collected in the last 12 months or that we may collect or process in connection with the Services are detailed in the chart below.

Category Examples Collected Retention Period
A. Identifiers. Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name or other similar identifiers. YES The duration needed to fulfill the original purpose of collection, our legal compliance obligations, and the resolution of potential disputes.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). Name, signature, address, telephone number, passport number, driver's license or state identification card number, education, employment, membership in professional organizations, professional licenses and certifications. Some personal information included in this category may overlap with other categories. YES The duration needed to fulfill the original purpose of collection, our legal compliance obligations, and the resolution of potential disputes.
C. Protected classification characteristics under California or federal law ("Protected Classes"). Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information). NO N/A
D. Commercial information. Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO N/A
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO N/A
F. Internet or other similar network activity. Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites. YES The duration needed to fulfill the original purpose of collection, our legal compliance obligations, and the resolution of potential disputes.
G. Geolocation data. Physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited. YES The duration needed to fulfill the original purpose of collection, our legal compliance obligations, and the resolution of potential disputes.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO N/A
I. Professional or employment-related information. Current or past job history. YES The duration needed to fulfill the original purpose of collection, our legal compliance obligations, and the resolution of potential disputes.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO N/A
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO N/A
L. Sensitive personal information*. Social security numbers, precise geolocation (within 1850 ft), racial or ethnic origin, religious beliefs, genetic, health or biometric data. NO N/A

*Sensitive personal information is a subtype of Personal Information which the CCPA only treats as sensitive personal information when we collect or use it to infer characteristics about a consumer. Think does not collect such information.

The Retention Periods listed in the chart above are estimates. Think keeps the categories of Personal Information described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations and for security and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain Personal Information. At the end of the retention period, Personal Information will be deleted or deidentified.

If required under applicable law, we will collect and process sensitive Personal Information only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

In addition to the Personal Information above, we may also collect:

If we combine or connect non-personal statistical or technical data with Personal Information so that it directly or indirectly identifies an individual, we treat the combined information as Personal Information.

Sources of Personal Information

Directly From You

We collect information about you when you interact with our Services, such as creating an account, filling out form, or posting content to the Services, including reviews, media such as text, photos or videos.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include Personal Information. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons and other tracking technologies including details of your interactions with our Services, such as traffic data, location data and other communication data, and which resources and Services features that you access and use. These automatic collection technologies help us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.

Web Beacons. Some parts of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Think to count users who have visited those parts or opened an email and for other related statistics.

To the extent any of these automated technologies are considered a Personal Information sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies. Please note that some Services features may be unavailable as a result.

Collection by Third Parties

When you interact with the Services, there are third parties (including sub-processors, your device manufacturer, internet provider, mobile service provider, analytic companies, advertisers) that may use automatic collection technologies to collect information about your or your device.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, platforms, and other online services. Think does not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We may receive Personal Information about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from the Association of California School Administrators ("ACSA") or service providers that we engage to perform services on our behalf.

How We Use Personal Information

We use information that we collect about you or that you provide to us, including any Personal Information, to:

We do not sell your Personal Information to third parties. Think may use your Personal Information to contact you about products and services offered by Think, its affiliates or subsidiaries, that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile to opt out.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your Personal Information for a new or unrelated purpose.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose Personal Information in the categories A-B, F-G and I, as follows:

Think Digital uses the following sub-processors to operate the Raly Report platform. Each sub-processor is bound by data protection obligations consistent with this Policy:

Think Digital will provide at least thirty (30) days' notice before adding a new sub-processor that processes district data.

Your Rights and Choices About Your Information

California residents have specific rights regarding their Personal Information under the CCPA. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information (the "right to know"), including the specific pieces of Personal Information we have collected about you (a "data portability request"). You may exercise your right to know twice in a 12-month period. This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under the CCPA or other state laws, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by logging into your account and adjusting your account settings and preferences or by sending us an email at raly.security@thinkdigital.org stating your request to opt out. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly.

Promotions by the Company. If you do not wish us to use your information to promote our own products or services, or the products or services of Think's subsidiaries or affiliates, you can opt out by logging into your account and adjusting your account settings and preferences or sending us an email stating your request to opt out.

Location Data. You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

You may have certain rights related to your Personal Information, including:

Access and Data Portability. You may confirm whether we process your Personal Information and access a copy of that Personal Information, including the sources from which we collected it and, if applicable, the category of persons to whom we disclosed the Personal Information, and the business or commercial purpose.

Correction. You may request that we correct inaccuracies in your Personal Information that we maintain, taking into account the information's nature and processing purpose.

Deletion. You may request that we delete Personal Information about you that we maintain, subject to certain redactions and exceptions under applicable law.

Opt Out of Using Personal Information for Targeted Advertising, Profiling, and Sales. You may request that we do not use your Personal Information for these purposes.

You also have a right to ask a business that uses or discloses sensitive Personal Information to limit those actions to those uses permitted by the CCPA. As Think does not currently collect sensitive Personal Information beyond the permitted CCPA uses, we do not currently offer this right.

Think does not currently use automated decision-making technology ("AMDT") to make significant decisions about you. For that reason, we do not currently provide AMDT access, opt-out, or appeal rights.

You have the right not to be discriminated against or subject to retaliation for exercising any of your privacy rights under the CCPA. Think will not discriminate or retaliate against you for exercising any of your rights under this policy.

How to Exercise Your Rights

To exercise any of your rights under Section 7, you may email your request to us at raly.security@thinkdigital.org. Your identity must be verified before Think can process requests.

Some browsers and browser extensions support the Global Privacy Control ("GPC") that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Think will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten-day timeframe, please contact the email above.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, deleted, or made your Personal Information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date. For requests going back more than 12 months, Think will make a reasonable attempt to provide the information unless doing so proves impossible or would involve a disproportionate effort. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable request unless it is excessive or repetitive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How We Protect Your Personal Information

Think uses commercially reasonable measures designed to protect your Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your Personal Information transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of Personal Information is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your Personal Information against unauthorized use, disclosure, and access.

Changes to Our Privacy Policy

Think may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. We will notify you of changes to this policy by updating the "last updated" date on the first page and posting the updated policy on the Services.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: raly.security@thinkdigital.org.

AI Features and Data Use

If you use AI-powered features in the Raly Report platform, your submitted content is processed by third-party AI providers solely to provide those features to you. Your content is not used to train, fine-tune, or improve any AI model. Only the minimum data necessary for a specific AI request is transmitted to third-party AI providers.

District Data Deletion

Upon expiration or termination of a district's subscription to the Raly Report platform, all district-associated data — including uploaded content, edit history, and AI suggestions — will be permanently deleted from Think's systems within thirty (30) days. Districts may request an export of their data before the deletion date by contacting Think's support team.