- Personal Data We Collect
- How We Use Personal Data
- How We Share Personal Data
- HOW YOU MAY SHARE PERSONAL DATA
- Handling of Personal Data
- Cookies & OTHER Technologies
- CHILDREN’S PRIVACY
- Changes To This PICOCTF PRIVACY STATEMENT**
- Questions or Complaints Handling**
picoCTF Privacy Statement
Carnegie Mellon University (“CMU,” “we,” “us,” or “our”) is committed to privacy and data protection regarding the picoCTF platform. This picoCTF Privacy Statement applies to all personal data CMU collects from you, from your child if you are registering as a parent or guardian, of from your students if you are registering as a teacher, academic administrator, or other educational supervising party (collectively “you” or “your”) through the picoCTF platform (currently https://picoctf.org or https://picoctf.com/).
Through the picoCTF platform, CMU expects to make available certain educational materials, resources and activities related to computer security that are targeted at middle and high school students aged 13 or older. From time to time, CMU may also run various competitions related to these games. Any and all information, materials and services provided or accessed through the picoCTF platform and otherwise provided or accessed in connection with the picoCTF site are collectively referred to as the “Services.”
CMU is the controller of the personal data collected through the Services. Any questions or concerns regarding CMU’s privacy and data protection practices can be directed to our Data Protection Officer, Melanie Lucht, Associate Vice President and Chief Risk Officer at GDPRfirstname.lastname@example.org.
Personal Data We Collect
CMU collects data to provide the Services you request, ease your navigation on our websites, communicate with you, and improve your experience using the Services. Some of this information is provided by you directly, such as when you register for the Services (or by someone with a relationship to you that has, or has obtained, the appropriate authority to provide the information on your behalf). Some of the information is collected through your interactions with the Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with Services running on your device.
The data we collect depends on the Services and features thereof that you use, and includes the following:
Name and Contact information. We may collect your name, email address, and other similar contact data. We may use this information to contact you or provide you with information on CMU or the Services.
Demographic Information. We may collect your age range (e.g. 18 or older, or 13-17), your country of residence and your status (e.g., middle/high school student, teacher, etc), and information about your school (if applicable). We may use this information to verify your eligibility to use the Services (including but not limited to eligibility to participate in certain competitions) and/or use it as part of aggregated data about the users of the Services.
Sensitive personal data. Under certain circumstances, we may ask you to provide sensitive personal data such as through optional questions about your gender identity and/or racial/ethnic identity. Providing sensitive personal data is voluntary you have you have the choice of whether to disclose any requested information.
Credentials. We process username, password, and related security information used for authentication and account access and information security purposes.
Financial and Tax Information. If you participate in and win a competition hosted by us, we may request certain financial and tax information to process your prize. For example, we may process your name, signature, social security or government identification number, bank account number, credit card number, debit card number, or other financial information.
Usage data. We collect personalized information about your use of the Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of the Services and interest thereto. If you participate in optional competitions, we may also track the performance of you and your team through your usernames and/or team names.
Information on the web pages you visit on the Services and the search terms you enter on the Services.
Service information based on your use of the Services. This includes the games in which you participate, the types and frequency of tools and commands being used, the size and nature of solutions to the games, and the frequency and duration of use.
Information regarding the performance of the Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
Data about your device and the network you use to connect to the Services, including IP address, device identifiers, and regional and language settings.
Web requests. We collect information regarding every web request sent to our servers. This information is used to provide support, as well as to assess usage and performance of the Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, and request time and duration.
Location data. We collect your country of residence and the name and zip code of your school. We may also collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for user relationship management purposes.
Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services. We will collect and utilize any data files you send to us for troubleshooting and improving the Services.
Competitions, Surveys and Studies. We may ask you to participate in a survey or study or provide an opportunity to participate in competitions; and may request information from you. Participation is voluntary, and you have the choice of whether to disclose any requested information in order to participate in those activities.
How We Use Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following lawful purposes:
Where we receive your consent (“consent”).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“legitimate business interest”).
Where we need to comply with a legal or regulatory obligation (“legal obligation”).
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
CMU uses information that we collect from customers and visitors for the purposes of:
providing the Services (performance of a contract, consent, and legitimate business interest);
providing ongoing support (performance of a contract);
processing prizes and other competition awards (performance of a contract);
communicating with you, including promotional communications (legitimate business interest);
providing information about other Services (legitimate business interest and consent);
helping us run our organization, for example to improve the Services or our security, train staff or perform marketing activities (legitimate business interest);
complying with our legal obligations (legal obligation); and
accounting and other administrative purposes (legitimate business interest and legal obligation).
Examples of the uses of information include:
Providing Services. We use data to carry out your transactions with us and to provide Services to you. Often, this includes personal data such as email, name and address. We may collect additional information when you register to use the services, including contact information and credentials. We may use this data to diagnose and address problems and provide other support services.
Financial and Tax Information. We use financial and tax information to process prizes and other awards you may win in connection with a competition pursuant to that competition’s rules. We will only collect financial and tax information if you win a competition.
Improving the Services. We use data to continually improve the Services, including adding new features or capabilities. Data is collected throughout your interactions with the Services that enable us to understand customer usage and tailor future capabilities.
We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of the Services or utilize specific areas of the Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on the Services.
Please note that we use IP addresses to analyze trends, to administer the site, and to collect general information for aggregate use.
Services Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means to notify you of changes in information and updates to the Services or to our picoCTF Privacy Statement.
Marketing and event communication: We use personal data to deliver informational, marketing, and event communications to you across various platforms, such as email, direct mail, social media, and online via the Services. We also may send you invitations to events relating to the Services that occur nearby you, based on your address.
If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. For information about managing email subscriptions and promotional communications, please visit the Your Rights Regarding Your Personal Data section of this privacy statement. Please remember that even if you opt out of receiving marketing emails, we may still send you important Services information related to your accounts and subscriptions.
Impact Assessment. We may use de-identified aggregate or other statistical information about you (which could include demographic data about you, such as your location, grade level and, if you provide it, your gender identity and/or racial/ethnic identity) for various purposes such as assessing the breadth of use of picoCTF.
How We Share Personal Data
Parents, Guardians, and Educators
We may share the Personal Data of individuals under the age of 18 (“minors”) with the parent or guardian who consented to the minor’s participation in the Services. If you are participating in the Services as part of an educational or learning program, we may share your Personal Data with your teachers, administrators, supervising parties, and the affiliated school or organization of the educational or learning program in which you are participating.
Service Providers and Other Third-parties
It is the practice of CMU to protect users’ information. Access to our users’ information is restricted to only those employees or agents, contractors or subcontractors of CMU who have valid reasons to access this information to perform any service you have requested or authorized, or for any other purpose described in this picoCTF Privacy Statement. The information you provide will not be sold or rented to third parties.
We may provide your personal data to:
Outsourced service providers who perform functions on our behalf. For example, your personal information may be stored on cloud hosting services such as Amazon Web Services or may be processed through email services such as SendGrid or visualized using Tableau.
our authorized agents and representatives, located inside or outside of your country of residence (in such case, we will use appropriate legal framework to operate data transfers), who provide services on our behalf, such as training service providers;
anyone expressly authorized by you to receive your personal data;
anyone to whom we are required by law to disclose personal data, upon valid and enforceable request thereof.
We will access, disclose and preserve personal data, when we have a good faith belief that doing so is necessary to:
comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
operate and maintain the security of the Services, including to prevent or stop an attack on our computer systems or networks.
We may also share de-identified aggregate or other statistical information about you which could include demographic data about you, such as your location, grade level and, if you provide it, your gender identity and/or racial/ethnic identity) with our sponsors or other funding agencies who are interested in the breadth of use and impact of the Services and/or to fulfill any reporting obligations under our relevant sponsorship or other funding agreements.
Please note that some of the Services may direct you to services of third parties whose privacy practices differ from those described in this picoCTF Privacy Statement. If you provide personal data to any of those services, your data is governed by their privacy statements or policies. Carnegie Mellon University is not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.
HOW YOU MAY SHARE PERSONAL DATA
Certain features of the Services (such as features that enable you to join a team for a competition under the relevant competition rules) may allow you to share information with other users. Please do not share your personal data or the personal data of others through any of these sharing features. You are the controllers of personal information you share through the sharing features of the Services.
Handling of Personal Data
Security of Personal Data
CMU is committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.
These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, CMU will provide any such notice that CMU must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
Storage and Transfer of Personal Data
Personal data collected by CMU through the Services may be stored and processed in your region, in the United States or in any other country where CMU, its affiliates or contractors maintain facilities, including outside the EU. We take steps to ensure that the data we collect under this picoCTF Privacy Statement is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.
CMU also collaborates with third parties such as cloud hosting services and suppliers located around the world as needed for the Services. In some cases, we may need to disclose or transfer your personal data within CMU or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
Retention of Personal Data
CMU retains personal data in a form which permits identification of data subjects for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations).
Your Rights Regarding Your Personal Data
CMU respects your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with the Services, you may decline. However, if you choose not to provide data that is necessary to provide the Services, you may not have access to certain features of the Services.
We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you relating to the picoCTF Services is incorrect, incomplete or out-of-date, please contact other@picoCTF.com.
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the Services you requested, e.g. to send an invoice to your email address, or that it is required by the applicable law.
Portability: If you reside within certain jurisdictions, you may have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and would be subject to any relevant legal requirements and exemptions, including identity verification procedures.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about CMU Services and events that may be of interest to you.
Marketing e-mail communications you receive from CMU will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. You can also request changes to your contact preferences by contacting CMU via email at other@picoCTF.com.
Please remember that even if you opt out of receiving marketing emails, we may still send you important Services information related to your accounts and subscriptions.
California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to GDPRemail@example.com or write us at: Carnegie Mellon University, Attn: Data Protection Officer, 5000 Forbes Avenue, Pittsburgh, PA 15213.
Cookies & OTHER Technologies
While this information on its own may not constitute your “personal data”, we may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use the Services to improve them.
Types of Cookies
We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Services can be grouped into the following categories:
Strictly Necessary: These Cookies are necessary for the Services to work properly. They include any essential authentication and authorization Cookies for the Services.
Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing the Services, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Services. They help us understand which areas you use and what we can do to improve them.
Targeting: These Cookies are used to deliver relevant information related to the Services to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit the Services. Some of these types of Cookies on the Services are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to the Services.
Here is a representative list of the Cookies we use in connection with the Services.
|Performance / Analytical||2 years after inactivity||These Cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The Cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google.|
Cookies Set by Third Parties
To enhance our content and to deliver a better online experience for our users, we sometimes embed content from other websites on the Services. We currently use, and may in the future use, Facebook, Twitter and Discord. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using Cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these Cookies are used and how you can control them.
You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org/) and DAA website (http://www.aboutads.info/choices/).
How to Control and Delete Cookies
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.
If you are using a mobile device to access the Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.
Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to the Services. CMU shall not be liable for any impossibility to use the Services or degraded functioning thereof, where such are caused by your settings and choices regarding Cookies.
To learn more about Cookies and web beacons, visit http://www.allaboutcookies.org.
We also embed social sharing icons throughout the Services. These sharing options are designed to enable users to easily share content from the Services with their friends using a variety of different social networks. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal data shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.
Do Not Track
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including this picoCTF website, do not respond to DNT signals.
IF YOU ARE UNDER THE AGE OF 13, DO NOT USE THE SERVICES.
The Services are intended to be used by individuals who are at least 13 years old. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.
California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: GDPRfirstname.lastname@example.org. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
If you reside within the EU you may be entitled to other rights under the GDPR. These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to your personal data that we collect and store:
the right to withdraw your consent to data processing at any time (please note that this might prevent you from using certain aspects of the Services);
the right of access your personal data;
the right to request a copy of your personal data;
the right to correct any inaccuracies in your personal data;
the right to erase your personal data;
the right to data portability, meaning to request a transfer of your personal data from us to any other person or entity as chosen by you;
the right to request restriction of the processing of your personal data; and
the right to object to processing of your personal data.
You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above-listed rights may be made to: GDPRemail@example.com.
If you reside within the EU, you have the right to lodge a complaint with a Data Protection Authority about how we process your personal data at the following website: https://edpb.europa.eu/about-edpb/board/members_en.
Processing EU Personal Data
In the event that your personal data is subject to the GDPR, we will only use your personal data for the original purpose for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your EU personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We require third parties to only use your EU personal data for the specific purpose for which it was given to us and to protect the privacy of your personal data. If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that data.
International Transfers of Personal Data
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
European Commission Standard Contractual Clauses: We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU.
Privacy Shield. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
For additional information on the mechanisms used to protect your personal data, please contact our Data Protection Officer at GDPRfirstname.lastname@example.org.
Changes To This PICOCTF PRIVACY STATEMENT**
We may update this picoCTF Privacy Statement based upon evolving laws, regulations and industry standards, or as we may make changes to our business including the Services. We will post changes to our picoCTF Privacy Statement on this page and encourage you to review our picoCTF Privacy Statement when you use the Services to stay informed. If we make changes that materially alter your privacy rights, CMU will provide additional notice, such as via email or through the Services. If you disagree with the changes to this picoCTF Privacy Statement, you should discontinue your use of the Services. You may also request access and control of your personal data as outlined in the Your Rights Regarding Your Personal Data section of this picoCTF Privacy Statement.
Questions or Complaints Handling**
We understand that you may have questions or concerns about this Privacy Statement or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:
Email: <GDPRemail@example.com> Mail: Carnegie Mellon University Attention: Data Protection Officer 5000 Forbes Avenue Pittsburgh, PA 15213
If you are not satisfied with our answer or how CMU manages your personal data, you may also have the right to make a complaint to a data protection regulator. If you reside within the EU, a list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Effective Date: February 16, 2021