High Sierra Industries – genArete Privacy Policy
Introduction (Effective March 1, 2026)
High Sierra Industries (“HSI” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s web site and individuals who use or benefit from the Services as defined below, including genArete learners (“Customers”). This Privacy Policy describes HSI’s privacy practices in relation to the use of the genArete web site and the related application, genArete learning system and services offered by HSI in relation to genArete learning system (collectively, the “Services”).
Our guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your Customer data to third parties. The primary purpose of collecting Customer data is to assist you in generating assessment and learning plans.
This Privacy Policy (the ‘Policy’) explains the Personal Information we collect from Customers, either directly or indirectly, and how we use it. As used in this Policy, “Personal Information” has the meaning provided in the EU General Data Protection Regulation of 2018 (the “GDPR”), and includes any information which, either alone or when combined with other information we hold, identifies an individual, such as name, mailing address, email address, IP address, and telephone number. For legal residents of California, who are covered by the California Consumer Privacy Act (“CCPA”), Personal Information includes any additional elements defined as such by the CCPA. By contrast, “Anonymous Data” means any data that, alone or combined with other information available to us or a third party, has been stripped of identifying data such that an individual cannot reasonably be identified. We collect both Personal Information and Anonymous Data as described below. This Policy also covers the choices you can make about the data we collect, and how you can control these decisions. Please read this Policy carefully to understand how HSI may collect, use, and share your Customer Personal Information. The terms ‘we’, ‘us’, or ‘HSI’ are each intended as reference to HSI.
Changes
We will update this Privacy Policy when necessary to reflect legal changes, customer feedback, and changes in our Services. When we post changes to this Policy, we will revise the “effective” date at the top of the Policy and may describe the changes in a change history. If there are material changes to the Policy or in how HSI will use your Customer Personal Information, we may notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Policy to learn how HSI is protecting your Customer Personal Information. Your continued use of our genArete website and application following the posting of changes constitutes your acceptance of such changes.
California Users
You may opt out of all sales of your Customer Personal Information. We never exchange Personal Information for money or any other consideration (e.g., trade it for free services). However, the CCPA’s definition of “sale” is very broad, and may include situations where, for example, browsing data is sent to a third party. We limit the information sent to what is needed to properly fulfill our contractual obligations.
The Types of Personal Information
We Collect Information you provide to us:
We collect information from you directly that you, such as your name, phone number, mailing address, and email address; for instance, to activate your subscription or when you contact our customer support team for assistance with a Customer request.
Information we collect automatically:
We automatically collect information about you, such as data about your use of the HSI Service. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.
Information obtained from other sources:
We may receive information about you from other sources, including third parties, such as HSI partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from HSI partner websites, for instance, when you interact with us on those sites. We protect data obtained from third parties according to the practices described in this Policy and we also apply any additional restrictions imposed by the source of data.
Information about children:
HSI does not target and is not intended to attract children under sixteen. Although visitors of all ages may navigate through our websites or use our app, we do not knowingly collect or request Personal Information from those under the age of sixteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under sixteen has improperly accessed or used our Services by using false information, we will delete the child’s Personal Information from our records.
Interactions with HSI:
To make the information in this Policy easy to understand, we have highlighted different occasions when HSI could potentially collect Customer Personal Information. The interactions with HSI are broken down into the following segments:
Learning about HSI:
As you gather more information about HSI, you may virtually or physically visit or interact with a site that we own or operate. Examples include browsing our website, calling our in-house sales representatives, or attending HSI-sponsored events. To learn more about HSI Services, you may voluntarily provide Personal Information, such as your name and email address during these interactions. We may also collect information about you online when you visit our websites.
What we collect: name, email address, and IP address.
Why: We use this information to share news about events, products, and services offered by HSI. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our websites for everyone. It is our legitimate interest to process your personal data for these purposes.
Getting Help from HSI:
From time to time, you may decide to contact our customer support team for assistance with generating assessment and learning plans. To be able to offer you the best service possible, we may collect certain Customer data from you.
We collect: This may include contact information, such as your name, email address, phone number, learner information, and the content of your chats and other communications with HSI customer support team.
Why: We collect this information to give you the best and most efficient customer support possible. It is also crucial to ensure the security of your Customer Personal Information and your subscription access. For instance, for inquiries and technical questions, we use contact information to respond to you in your preferred channel (e.g., phone or email).
How We Use Personal Information
HSI uses the data we collect to provide you with the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about, new Services available, security, and other types of updates. HSI uses the data for the following purposes:
Providing our Product Experience
We use data to provide, operate, support, and improve the Services we offer. This processing is necessary for the performance of our agreement we have with you.
Customer Support
We use data to respond to your inquiries, diagnose problems using the Services, and provide other customer care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.
Service Improvement
We continually use data for research purposes and to develop and improve the Services, including maintaining and improving the performance of our Services, developing, and adding new features or capabilities, such as using verification to improve security, and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.
Security, Safety and Dispute Resolution
We use data to protect the security and safety of the Services and our Customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
Business Operations
We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
Communication and Marketing
We use the data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means of electronic communication to inform you about new HSI Services, to update you on a support issue or to invite you to take part in a survey. This processing is necessary to serve our legitimate interest. We do not use cookies or similar tracking such as pixels, tags, web beacons, or other identifiers.
Artificial Intelligence
We may use de‑identified and aggregated information derived from Customer data to develop and improve statistical models, algorithms, and analytic features used in the Services, but we do not use Customer Personal Information in a form that identifies an individual to train generalized artificial intelligence or machine learning models offered to third parties.
How We May Share Personal Information
HSI does not and will not sell Personal Information about our Customers. We only disclose your data as described in this Policy. We may share information with the following types of third parties.
Sale or Merger
We may share your Customer Personal Information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights.
The Legal Bases for Using Personal Information
There are different legal bases that we rely on to use your Customer Personal Information, namely:
Performance of a contract
The use of your Customer Personal Information may be necessary to perform the agreement you have with us. For example, to generate assessments and learning plans, to identify and evaluate language, cognition, and social-emotional learning skills, or to respond to your requests.
Legitimate interests
We may use your Customer Personal Information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve HSI Services, to send you notifications about HSI Services, or to use your Customer Personal Information for administrative, fraud detection or legal purposes. Where we process your Personal Information based on our legitimate interest and no opt-out mechanism is available to you on our website, you may exercise your right to object by sending an email to support.
Security, Storage, and Retention of Personal Information
HSI is committed to protecting the security of your Customer Personal Information. However, while we take reasonable precautions to guard the Personal Information we collect, no security system is impenetrable. We use a variety of appropriate technical and organizational measures and industry standards to protect your Personal Information and help prevent information about Customers from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. We ensure that our data center has adequate security measures. Additionally, Customer data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. Moreover, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including HSI (it can only be reset). You can only access our Service through the use of an individual user login and password. To protect the confidentiality of your Customer Personal Information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Please note, we will never ask you to disclose your password. If you have any questions about the security of your Personal Information, you can contact us at support.
Storage
Personal data collected by HSI may be stored and processed in your region, in the United States (for instance in our data centers), or in any other country where HSI is located or maintains facilities. HSI has put in place adequate mechanisms to protect Personal Information when it is transferred.
Retention
HSI will retain your Customer Personal Information for as long as we deem it necessary to enable you to use the website and your HSI Services, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All Personal Information we retain will be subject to this Privacy Policy and our internal retention guidelines. If you have a question about a specific retention period for certain types of Personal Information we process about you, please send an email to support.
Your Rights
We want you to be in control of how your Customer Personal Information is used by us. Subject to local law, you can do this in the following ways:
• you can ask us for a copy of your Customer Personal Information
• you can inform us of any changes to your Customer Personal Information, or if you want us to correct any of your Customer Personal Information
• in certain situations, you can ask us to erase, block or restrict your Customer Personal Information we hold about you, or object to particular ways in which we are using your Customer Personal Information; and
• in certain situations, you can ask us to send your Customer Personal Information you have given us to a third party. Where we are using your Customer Personal Information on the basis of your consent, you are entitled to withdraw that consent at any time.
Moreover, where we process your Customer Personal Information based on legitimate interest or the public interest, you have the right to object at any time to that use of your Customer Personal Information. We rely on you to ensure that your Customer Personal Information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your Customer Personal Information by contacting support. We will respond to your request as soon as possible but certainly within 30 days. We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your Customer Personal Information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.
Certain state residents are granted certain rights regarding their Personal Information, including the right to access and modify Personal Information held by providers (like us), and to have providers “forget” Personal Information that is no longer relevant. You may always contact us for assistance in exercising these rights, including on behalf of your learners. Please include information about which rights you are seeking to exercise if you contact us. We may need to verify your identity before fulfilling your request. It should not need to be said, but we will never provide worse services to, or in any way punish, anyone who chooses to exercise these rights. Be aware that as the data controller of learner’s Personal Information, you are responsible for authorizing us to access, modify, and delete learner’s Personal Information if requested by the learner or their guardian or representative. Any request in this regard must be directed to you, the data controller.
You have the following rights with respect to your Customer Personal Information that we process.
Withdraw Consent: You may withdraw your consent to our processing of your Customer Personal Information, in whole or in part (i.e., for marketing purposes). Certain Services may be ineffective upon opt out.
Access / Request Information: You may access the Personal Information we hold about Customer at any time by contacting us directly.
Modification: You may modify the Personal Information we hold about Customer at any time via by contacting us directly.
Erase and Forget: In certain situations, for example when the Personal Information we hold about Customer is no longer relevant or accurate, you can request that we erase your Customer’s Personal Information. If you delete your account, all Customer Personal Information will be erased within thirty days of the date of deletion.
Portability: you may request a copy of Customer’s Personal Information and may always move it to other entities as Customer desires.
No Sale of Personal Data (California Users only): Go to the Do Not Sell My Personal Information page to stop all “sale” of your Personal Data.
See above for more information about how this works.
Access To Specific Information and Data Portability Rights
You have the right to request that HSI disclose certain information to you about our collection and use of your Customer Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you. Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that HSI delete any of your Customer Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request , we will delete (and direct our service providers to delete if applicable) your Customer Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the Customer Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 without hindrance. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. 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.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to direct us to not sell your Customer Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of individuals. Individuals who opt-in to Personal Information sales may opt-out of future sales at any time. If you wish to exercise any of these rights, please contact Customer Support (support@genarete.org). In your request, please make clear:
(i) what Personal Information is concerned; and
(ii) which of the above rights you would like to enforce.
For your protection, we will need to verify your identity before fulfilling your request. We will comply with your request promptly, but in any event within thirty (30) days of your request (forty-five (45) days for requests under the CCPA). We may need to retain certain information for recordkeeping purposes or to complete transactions that you began prior to requesting such change or deletion. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please write or email Customer Support (support@genarete.org).
Your Choices Transaction Service Request
If you wish to access, edit or remove service request information, change your password, close your service request, or request deletion of Customer personal data, you can do it by sending a message to Customer Support. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days.
Your Communication, Marketing and Advertising Preferences
You can opt out of receiving direct marketing communications from HSI by following the instructions included in every email sent to you via the “Unsubscribe” link. We respect your choice, and we will stop sending you promotional emails once you unsubscribe. Please note we will continue to communicate with you regarding changes to terms and conditions, policy updates, HSI Service updates, routine customer service messages, service interruptions, data breaches, or other significant information about the service.
How to Contact Us
If you have any questions about the use of Customer Personal Information, please send a message to Customer Support. HSI is a data processor for learner personal data and is otherwise a data controller for non-learner personal data we collect subject to this Privacy Policy. Where a Subscriber is a covered entity or business associate under HIPAA and uses the Services to process PHI, HSI will act as a business associate only to the extent required under a separate executed BAA.
FAQ
The following are basic questions you may have about our Privacy Policy. We encourage you to read the detailed statement above for additional details.
What Customer Personal Information does HSI collect?
Assessor First Name
Assessor Last Name
Assessor Email Address
Assessor Organization
Learner First Name
Learner Last Name
Learner Preferred Name
Learner Date of Birth (MM/YYYY)
Learner Gender
Learner Assigned Assessor
Learner Academic Year
Learner Reference ID
Learner Rates for each pinpoint
Learner Duration for each pinpoint
Learner Score for each pinpoint
Learner Date of Assessment
Organization Name
Organization Phone Number
Organization Address
Organization City
Organization State
Organization Zip code
Why does HSI need my information?
HSI uses the data we collect to provide you the best experience within the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you.
How is my information used?
HSI uses the data we collect for the following purposes:
Authentication To create unique users associated with First & Last Name and organizations email which would require password & multifactor authentication
Roles & Permissions To assign roles and permission levels to each user
Notifications To send notification emails and updates to active users
Billing & User Management To accurately assign Assessor & Learner seats; to bill to correct organization and for correct period
Marketing To send information on possible training, conference, new service offerings
Professional Assessment Support For OUR BCBA staff to provide professional assessment & learning service to client assessors
Data Analytics To analyze all organization and learner data to understand relations between pinpoints; to assess fidelity of assessment across assessors; to improve & develop the domains and pinpoints
Artificial Intelligence To develop and improve statistical models, algorithms, and analytic features used in the Services
UI/UX To improve user experience
Privacy To enhance privacy protection
Customer Support To provide customer support (software technical issues, billing questions, etc.)
How does collecting Customer Personal Information help HSI improve its services?
We use the Customer Personal Information to make sure that we are efficiently expediting the identification of what learners are capable of and planning that helps learners achieve their greatest potential. We also collect service error information, so we can make improvements to eliminate potential bugs and problems. And finally, understanding how and when our Customers collectively use our service helps us design new ways to improve the HSI service.
Does HSI sell Personal Information to third parties?
No. We never have.
Can I opt out of sharing Personal Information to HSI?
Yes, you can opt out of submitting certain types of Personal Information to HSI, but because HSI only collects data necessary to providing the HSI Services, the decision not to submit this information may impact HSI’s ability to provide efficient and effective services.
How do I delete my Customer Personal Information from HSI and what are the consequences?
You can always send us a message to support or contact our Customer Care team and request that any or all of your Customer Personal Information be deleted. Please note, however, that by deleting Customer Personal Information, we may be unable to provide further services or support.
How long does HSI keep my Customer Personal Information?
HSI retains Customer Personal Information for as long as necessary to provide the services, and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly.
How is Customer Personal Information stored and secured on HSI’s servers?
HSI is committed to protecting the security of your Customer Personal Information. We use a variety of security technologies and procedures to help protect Customer Personal Information from unauthorized access, use or disclosure. For example, we store the Customer Personal Information you provide on hosting systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption.
Is HSI using cookies or pixels to gather information?
No. We do not use cookies or similar tracking such as pixels, tags, web beacons, or other identifiers.
Does HSI use interest-based advertising?
No. We do not deliver interest-based advertising.
What safeguards are in place for children who have access to HSI services?
HSI website does not target and is not intended to attract children. HSI does not knowingly solicit Personal Information from children or send them requests for Personal Information. Although visitors of all ages may navigate through our website, we do not intentionally collect Personal Information from persons under the age of sixteen. If following a notification by a parent or guardian, or discovery by other means, that a child under sixteen has improperly accessed or used the site, we will delete the child’s Personal Information from our records.
How can I contact HSI if I have questions regarding HSI’s Privacy Policy?
If you have any questions about the use of your Personal Information, please send a message to Customer Support (support@genarete.org).