Privacy Policy

Generation Connect, Inc. (“Generation Connect,” “GC,” “we,” “us,” or “our”) respects the privacy of the teens, Seasoned Adults, parents and guardians, staff members, partners, and other individuals who participate in or interact with our community.

This Privacy Policy explains how we collect, use, disclose, protect, and retain personal information through the Generation Connect website, platform, guided programs, GC Tech Support, applications, training, certifications, surveys, communications, and related services.

Because Generation Connect intentionally connects generations—including minors and adults—we believe privacy and safety should be built into how our platform operates.

This Privacy Policy should be read together with our Terms of Use and any additional consent, participation, safety-screening, payment, or program notices that apply to you.

1. Who We Are

Generation Connect is an intergenerational technology and workforce-development platform that connects trained teen Tech Navigators with older adults, whom we call Seasoned Adults.

Our services may include:

• facilitated intergenerational programs;
• one-to-one GC Tech Support;
• technology education and digital-literacy activities;
• Tech Navigator applications, training, and certifications;
• workforce and community-service opportunities;
• assessments, surveys, and program evaluations;
• program and appointment scheduling;
• live video sessions;
• partnerships with schools, government agencies, workforce organizations, community organizations, and other sponsors; and
• related administrative and support services.

Some GC services are free or sponsored by a partner. Others may be purchased directly by a participant.

2. Personal Information We Collect

The information we collect depends on how you interact with Generation Connect.

A. Account and Contact Information

We may collect:

• name;
• email address;
• telephone number;
• date of birth or age, when needed;
• account username or identifier;
• authentication information;
• user type, such as Seasoned Adult, Tech Navigator, parent/guardian, staff member, or partner;
• organization, school, community group, or referring partner; and
• communication preferences.

We use account information for functions such as email verification, account authentication, password resets, security notifications, program enrollment, and appointment communications.

Passwords and Authentication

Generation Connect does not store passwords in readable form. Passwords are securely hashed using industry-standard security practices and cannot be viewed, retrieved, or decrypted in their original form by Generation Connect staff, administrators, contractors, Tech Navigators, other users, or service providers with administrative access to the platform.

If you forget your password, Generation Connect cannot retrieve or provide your existing password. You must reset it through the platform’s secure password-reset process.

B. Tech Navigator Application and Participation Information

For Tech Navigator applicants and participants, we may collect:

• age or date of birth;
• school or educational information;
• participation pathway;
• interests and technology skills;
• languages;
• availability;
• experience;
• application responses;
• professional or faculty references;
• reference names, positions, and email addresses;
• parent or guardian information when applicable;
• emergency-contact information;
• program enrollment;
• attendance;
• training participation;
• community-service or work hours;
• certifications;
• assessment and quiz results;
• eligibility for GC Tech Support assignments;
• assignment availability; and
• payment or compensation records when applicable.

Certification and assessment records may include test scores, individual answers, test start and submission times, time spent completing an assessment, and other information necessary to administer and evaluate training and certification.

C. Seasoned Adult Profile and Participation Information

For Seasoned Adults, we may collect:

• age or date of birth;
• contact information;
• organization or program affiliation;
• technology experience;
• technology interests and support needs;
• device or technology topics for which assistance is requested;
• personal interests voluntarily shared to support intergenerational connection;
• program enrollment and attendance;
• program and GC Tech Support history;
• appointment information;
• survey and assessment responses;
• ratings and reviews; and
• information voluntarily provided in a profile or biography.

We use this information to provide appropriate services, facilitate intergenerational connections, match participants with suitable Tech Navigators, evaluate our programs, and improve the GC experience.

3. Community Safety Screening

Because Generation Connect connects adults with minors, participants age 18 or older may be required to complete a Community Safety Screening before participating in certain GC programs or services.

The screening is a safety measure designed to help maintain a trusted environment for both generations.

GC’s screening process uses information such as a participant’s legal name and date of birth to conduct a limited search of relevant publicly available criminal records.

For Community Safety Screening, Generation Connect does not require:

• a Social Security number;
• driver’s-license number;
• state identification number;
• immigration or citizenship documentation;
• credit-history information; or
• bank-account information.

Information collected specifically for Community Safety Screening is used for safety and eligibility purposes. It is not sold or shared for marketing purposes.

A third-party screening provider may process information on GC’s behalf. When applicable law requires a separate disclosure, authorization, notice, or other procedure, GC will provide it separately.

4. Parents, Guardians, and Minors

Generation Connect is designed to serve teens, including minors.

You must be at least 13 years old to create or maintain a Generation Connect participant account.

Tech Navigators and other participants ages 13 through 17 require parent or legal guardian consent before participating when required by GC.

For minors, we may collect information from or about a parent or guardian, including:

• name;
• email address;
• relationship to the minor;
• electronic signature or consent record;
• date and time of consent; and
• communications concerning the minor’s participation.

We use this information to document consent, administer the minor’s participation, communicate about program or safety matters, and comply with applicable legal and partner requirements.

Children Under 13

Generation Connect is not intended for children under 13, and children under 13 may not create a participant account or directly provide personal information through the GC platform.

If we learn that we have collected personal information directly from a child under 13 without legally required parental authorization, we will take appropriate steps to delete it.

A parent or guardian who believes a child under 13 has provided personal information to GC should contact us using the information at the end of this Policy.

5. GC Tech Support Information

When you request or participate in GC Tech Support, we may collect:

• the technology topic or problem for which assistance is requested;
• appointment date and time;
• assigned Tech Navigator;
• session status;
• session history;
• support notes or logs;
• rescheduling or cancellation information;
• screen-sharing activity when voluntarily used;
• ratings and reviews;
• escalation or coverage information; and
• payment and transaction information when applicable.

GC may use Tech Navigator certification, experience, availability, ratings, and other relevant information to make appropriate matches and assignments.

Protecting Sensitive Credentials

You should never provide a Tech Navigator with:

• passwords;
• Social Security numbers;
• full payment-card numbers;
• banking credentials;
• PINs;
• authentication or verification codes;
• cryptocurrency private keys or seed phrases; or
• other credentials that could allow someone to impersonate you or control a financial account.

When a password, PIN, or verification code must be entered, you should enter it yourself without revealing it to the Tech Navigator.

6. Video and Audio Recordings

GC Tech Support

All GC Tech Support sessions are recorded for purposes such as:

• participant safety;
• accountability;
• quality assurance;
• incident investigation;
• dispute resolution;
• training and service improvement; and
• enforcement of GC safety and conduct rules.

Before a participant enters their first recorded GC Tech Support session, GC requires affirmative consent to recording.

For subsequent recorded Tech Support sessions, GC provides a clear recording notice before entry. By proceeding to join the session after receiving that notice, the participant acknowledges and consents to the recording of that session.

GC maintains records associated with recording consent and session participation as reasonably necessary to document consent and administer the service.

If you do not consent to recording, GC may be unable to provide GC Tech Support through the recorded service.

Guided Program Sessions

Generation Connect does not necessarily record entire guided program sessions.

GC may record portions of group program sessions. A facilitator will notify participants before recording begins.

Participants who do not wish to appear in a recorded portion may turn off their camera and refrain from participating during the recorded portion or follow other instructions provided by the facilitator.

Marketing and Promotional Use

Consent to an operational, safety, training, or quality-assurance recording does not automatically authorize Generation Connect to use your name, image, voice, likeness, testimonial, or identifiable recording for advertising or promotional purposes.

GC will obtain separate authorization when required before using identifiable participant content for marketing or promotional purposes.

7. Screen Sharing

Screen sharing during GC Tech Support may be available but is optional.

If you choose to share your screen, other authorized people in the session may be able to see information displayed on your device.

Before sharing your screen, we recommend closing, hiding, or minimizing information you do not want viewed, including:

• bank accounts;
• medical information;
• passwords;
• private email or messages;
• payment-card information;
• tax records;
• government identifiers; and
• other confidential information.

Screen sharing does not authorize a Tech Navigator to request or retain passwords, banking credentials, authentication codes, or other prohibited sensitive information.

8. Payments and Financial Information

When you purchase a GC service or subscription, we may collect:

• billing name;
• transaction amount;
• product or service purchased;
• transaction status;
• subscription status;
• refunds;
• credits;
• tips; and
• limited payment-method information supplied by our payment processor.

Payments may be processed by third-party payment processors such as Stripe.

GC generally does not receive or store your complete payment-card number. Payment processors handle payment credentials according to their own security and privacy requirements.

Optional tips may be processed after GC Tech Support sessions.

9. Surveys, Assessments, Ratings, and Program Evaluation

GC may collect surveys, assessments, ratings, and other feedback to evaluate our programs and improve participant experiences.

Depending on the activity, feedback may relate to:

• the overall session;
• a Tech Navigator;
• a Seasoned Adult;
• a Session Facilitator;
• a Teen Trainer;
• an On-Site Technical Coordinator;
• GC Tech Support; or
• the overall Generation Connect experience.

GC may use this information for:

• program evaluation;
• quality assurance;
• training and coaching;
• recognition;
• staffing and assignments;
• Tech Navigator eligibility;
• partner and sponsor reporting;
• service improvement;
• impact measurement; and
• research related to GC programs.

GC Tech Support ratings provided by Seasoned Adults may contribute to a Tech Navigator’s average rating.

Where reasonably possible, external impact reporting uses aggregated or de-identified information rather than information identifying individual participants.

10. Usage, Device, and Analytics Information

When you use the GC website or platform, GC and its service providers may automatically collect technical information such as:

• IP address;
• browser type;
• operating system;
• device type;
• pages or screens viewed;
• dates and times of access;
• referring pages;
• session and interaction information;
• errors and performance data;
• approximate location derived from technical information;
• authentication activity; and
• cookies or similar technologies.

GC may use analytics and monitoring services, including Google Analytics, PostHog, or similar tools.

We use this information to:

• operate the platform;
• authenticate users;
• diagnose errors;
• improve usability;
• understand how services are used;
• detect security threats or misuse;
• measure performance; and
• improve GC programs and services.

GC does not use analytics features for cross-site behavioral advertising and does not authorize analytics providers to use GC participant information for their own advertising purposes.

11. Cookies and Similar Technologies

GC and its service providers may use cookies, local storage, and similar technologies for:

Essential functions, including authentication, security, and maintaining user sessions.

Preferences, including remembering user settings.

Analytics, including understanding how the platform performs and how people interact with GC.

Generation Connect does not use personal information for cross-context behavioral advertising.

If our practices materially change, we will update this Privacy Policy and provide any choices or opt-out mechanisms required by applicable law.

Where required by law, GC will recognize applicable browser-based opt-out preference signals, including Global Privacy Control.

12. Communications

GC may communicate with participants through:

• email;
• SMS/text;
• push notifications;
• in-platform notifications; and
• telephone when appropriate.

Communications may concern:

• account verification;
• passwords and account security;
• applications;
• parental consent;
• program enrollment;
• session reminders;
• appointment confirmations;
• cancellations and rescheduling;
• training;
• certification;
• Tech Support;
• safety matters; and
• other administrative communications.

SMS/Text Messaging

Providing GC with a telephone number does not automatically constitute consent to receive SMS/text messages.

Where consent is required, SMS consent is separate, affirmative, and optional.

Consent to receive optional SMS messages is not a condition of purchasing or participating in GC services.

You may withdraw consent to SMS communications using the instructions included with the messages, including replying STOP when applicable.

Message and data rates may apply.

Opting out of optional SMS messages does not prevent GC from communicating with you through other lawful methods when necessary to administer your account or provide services you requested.

13. How We Use Personal Information

Generation Connect may use personal information to:

• create and administer accounts;
• authenticate users;
• process applications;
• verify eligibility;
• obtain parental or guardian consent;
• obtain and contact references;
• conduct Community Safety Screening;
• enroll participants in programs;
• administer attendance;
• provide training;
• administer assessments and certifications;
• match or assign Tech Navigators;
• schedule and provide GC Tech Support;
• facilitate live video sessions;
• document recording consent;
• process payments and subscriptions;
• issue refunds or credits;
• calculate compensation or community-service hours;
• communicate with participants;
• maintain participant safety;
• prevent and investigate misconduct or fraud;
• provide customer support;
• administer partner-sponsored programs;
• analyze participation and outcomes;
• improve curriculum, programs, and services;
• maintain, secure, and troubleshoot the platform;
• comply with contracts and legal obligations;
• establish, exercise, or defend legal rights; and
• protect GC, participants, and the public.

We will not use personal information for materially unrelated purposes without providing additional notice or obtaining consent when required.

14. When We Disclose Personal Information

Generation Connect does not sell your personal information for money.

GC also does not share personal information for cross-context behavioral advertising.

We may disclose information in the circumstances described below.

Service Providers

We may provide personal information to service providers that perform functions on GC’s behalf, including providers of:

• website and platform hosting;
• database infrastructure;
• video calling;
• payment processing;
• authentication;
• email;
• SMS;
• push notifications;
• safety screening;
• electronic signatures;
• analytics;
• technical monitoring; and
• cloud infrastructure.

These providers receive information as reasonably necessary to perform services for GC and are subject to applicable contractual and legal requirements.

Program Partners and Sponsors

If you participate in Generation Connect through a school, government agency, workforce provider, community organization, funder, or other partner, GC may provide that organization with information reasonably necessary to administer, fund, evaluate, or report on the sponsored program.

Depending on the program and agreement, this may include:

• enrollment;
• attendance;
• participation;
• service or work hours;
• program completion;
• certification;
• aggregate program outcomes; or
• other information reasonably required for the program.

GC uses role-based access controls designed to limit partner access to participants, programs, and information associated with that partner’s organization.

Legal, Safety, and Protective Purposes

We may disclose personal information when reasonably necessary to:

• comply with applicable law or legal process;
• respond to a valid government or law-enforcement request;
• protect a child or vulnerable person;
• report or investigate suspected abuse;
• investigate fraud, misconduct, or threats;
• respond to an emergency;
• enforce our Terms of Use;
• protect the rights, property, or safety of GC or another person; or
• establish, exercise, or defend legal claims.

Business Transactions

If Generation Connect is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction, personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

15. Access to Information Within Generation Connect

Not every GC employee, contractor, facilitator, trainer, Tech Navigator, or partner has access to every participant record.

GC uses role-based access controls intended to limit information access according to a person’s responsibilities and legitimate operational need.

Administrative personnel may have broader access when required to operate and protect the platform.

Facilitators, trainers, and other program personnel generally receive access associated with their assigned programs and responsibilities.

GC Tech Support records and support logs are restricted to personnel whose roles require access.

Partners generally receive access only to information associated with their organization and applicable programs.

Tech Navigators do not receive unrestricted access to Seasoned Adult records.

GC may periodically review and modify access permissions as services, roles, and security needs change.

16. Teen Privacy

Generation Connect recognizes that information about teens deserves particular care.

GC does not sell personal information about Tech Navigators or other minors.

GC does not knowingly share the personal information of users under 16 for cross-context behavioral advertising.

Information concerning Tech Navigators may be used for:

• application and eligibility;
• parental consent;
• program participation;
• safety;
• training;
• certification;
• community-service documentation;
• workforce opportunities;
• GC Tech Support eligibility;
• compensation when applicable;
• coaching and evaluation; and
• other purposes described in this Policy.

Access to information concerning minors is limited according to role and operational need.

17. Sensitive Personal Information

Some information processed by GC may qualify as sensitive personal information under applicable privacy laws.

Generation Connect seeks to minimize the collection of sensitive information.

In particular, GC’s Community Safety Screening process intentionally avoids requiring Social Security numbers, driver’s-license numbers, credit information, banking information, immigration documentation, or citizenship documentation.

GC does not use sensitive personal information to infer characteristics about participants for advertising.

Where applicable law provides a right to limit certain uses or disclosures of sensitive personal information, GC will honor that right.

18. Data Retention

Generation Connect retains personal information only for as long as reasonably necessary for the purpose for which it was collected and for legitimate safety, operational, contractual, accounting, and legal purposes.

Retention periods may vary depending on the type of information.

In determining how long information is retained, GC considers:

• whether an account remains active;
• the purpose for which the information was collected;
• the duration of a program or partner contract;
• participant safety and incident-review needs;
• payment and accounting requirements;
• certification and service-hour recordkeeping;
• contractual requirements;
• applicable statutes of limitation;
• legal or regulatory requirements;
• disputes, investigations, or litigation holds; and
• whether information can instead be aggregated or de-identified.

Certain records may therefore be retained after an account is closed or a participant completes a program.

When personal information is no longer reasonably necessary for a legitimate purpose, GC will delete, de-identify, or otherwise dispose of it in accordance with its data-retention practices and applicable law.

GC does not retain personal information indefinitely merely because storage is technically possible.

19. Data Security

Generation Connect uses reasonable administrative, technical, and organizational safeguards designed to protect personal information.

Depending on the information and system involved, safeguards may include:

• secure password hashing;
• authentication controls;
• role-based access;
• password requirements;
• encrypted transmission;
• restricted administrative permissions;
• activity logging;
• secure hosting;
• service-provider security controls;
• monitoring;
• access review; and
• backup and recovery measures.

No website, database, transmission, or electronic system can be guaranteed to be completely secure.

If GC experiences a security incident involving personal information, we will investigate and provide notification when required by applicable law.

20. Your Privacy Choices

Depending on your relationship with GC and applicable law, you may be able to:

• access and update profile information;
• change communication preferences;
• opt out of SMS messages;
• manage push-notification preferences;
• cancel a subscription;
• request correction of inaccurate information;
• request deletion of certain information; or
• request closure of your account.

Some information may need to be retained after a request—for example, to comply with legal requirements, document financial transactions, maintain necessary safety or participation records, investigate misconduct, resolve disputes, or satisfy contractual obligations.

21. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act, as amended (“CCPA”), when the law applies to Generation Connect and the personal information at issue.

Depending on the circumstances, those rights may include:

• the right to know what personal information is collected, used, and disclosed;
• the right to access specific personal information;
• the right to delete personal information, subject to legal exceptions;
• the right to correct inaccurate personal information;
• the right to opt out of the sale or sharing of personal information;
• the right to limit certain uses or disclosures of sensitive personal information; and
• the right not to receive discriminatory treatment for exercising legally protected privacy rights.

Sale and Sharing

GC does not sell personal information for money.

GC does not use or share personal information for cross-context behavioral advertising.

GC does not knowingly sell or share for cross-context behavioral advertising the personal information of users under 16.

If GC’s practices change in a manner that triggers an opt-out requirement under California law, GC will provide the required notice and opt-out mechanism.

Where required by applicable law, GC will recognize qualifying opt-out preference signals such as Global Privacy Control.

Submitting a Privacy Request

California residents may submit a privacy request using the contact information in Section 26 below.

GC may need to verify your identity before completing certain requests.

Where permitted by law, an authorized agent may submit a request on your behalf. GC may require appropriate evidence that the agent is authorized to act for you.

GC will not discriminate against you for exercising a legally protected privacy right.

22. Privacy Rights in Other States

Residents of other U.S. states may have additional privacy rights under applicable state law.

Depending on the law and whether it applies to GC, these may include rights to:

• access personal information;
• obtain a copy of personal information;
• correct inaccurate information;
• delete certain information;
• opt out of certain uses of personal information; or
• appeal a decision concerning a privacy request.

GC will honor applicable privacy rights as required by law.

23. De-Identified and Aggregated Information

Generation Connect may create aggregated or de-identified information that cannot reasonably be linked to a particular individual.

GC may use this information for purposes including:

• program evaluation;
• impact measurement;
• grant and funder reporting;
• partner reporting;
• research;
• fundraising;
• service improvement; and
• public communications.

For example, GC may report the number of participants served, program-completion rates, certification rates, or aggregate survey outcomes without identifying individual participants.

GC will not attempt to re-identify information that it maintains as de-identified except as permitted by law, including when necessary to test whether de-identification measures are effective.

24. Third-Party Websites and Services

The GC platform may contain links to third-party websites, applications, products, or technology resources.

When you intentionally leave the GC platform or interact directly with a third-party service, that provider’s privacy policy and terms may apply.

Generation Connect is not responsible for the independent privacy practices of third parties that are not processing information on GC’s behalf.

25. Changes to This Privacy Policy

Generation Connect may update this Privacy Policy as our services, technology, business practices, or legal obligations change.

The Last Updated date at the beginning of the Policy identifies the most recent revision.

When a change materially affects how we collect, use, or disclose personal information, GC will provide additional notice or obtain consent when required by applicable law.

26. Contact Generation Connect

If you have questions about this Privacy Policy, want to exercise an applicable privacy right, believe personal information about you is inaccurate, or have concerns about GC’s privacy practices, please contact:

Generation Connect, Inc. Email: info@generationconnect.io Telephone: 877-839-3360 California, United States

Parents and legal guardians may also use this contact information for questions or requests concerning a minor’s personal information.

Policy version 2026-09-07