Privacy Policy
This Privacy Policy explains what information SIC collects from prospective and active participants, how we use it, how long we keep it, and the rights you have under PIPL (China) and other applicable privacy frameworks. We collect only what we need to run the program, and we keep it only as long as the program needs it.
Scope & Who This Covers
This Privacy Policy applies to all prospective and active participants in the Student Investment Challenge (SIC) — students, parents, school coordinators, and mentor candidates who interact with the SIC program desk via WhatsApp or this website. The program is operated by SKT, endorsed by CEE, and academically supported by ACME; this policy covers data handled by SKT in the operation of SIC.
What We Collect
During WhatsApp intake, eligibility review, and active participation, SIC collects the following categories of information:
- Identity & contact: WhatsApp number, name, age or grade, school name, country/region of residence, parent or guardian contact (for minors).
- Eligibility documentation: school consent letter or parent consent form (uploaded during intake for grades 6–9), proof of grade level if requested.
- Program participation data: division track (Junior or Senior), team membership (Senior teams), weekly thesis log entries, simulated trading activity, submission drafts, and final Global Stage entries.
- Communications: WhatsApp conversations with the program desk, mentor office-hour exchanges, written rubric feedback.
- Technical: minimal browser fingerprint (user agent, language) for site analytics; WhatsApp-provided technical identifiers as part of WhatsApp integration.
How We Use It
We use the information we collect only for the purposes of running the SIC program:
- Eligibility & intake — confirming you meet program requirements, sending consent paperwork, registering your division track.
- Program operations — pairing Senior teams with mentors, scheduling office hours, sending bulletins, organizing the Omaha Dialogue Summit.
- Judging & rubric application — scoring submissions, producing rubric scorecards, determining Featured Cohort recognition.
- Archive & publication (with explicit permission) — publishing Featured Cohort entries in the Hall of Fame with the participant’s chosen name-display preference.
- Aggregate program reporting — anonymized aggregate statistics shared with CEE and ACME for governance and academic review.
We do not use participant data for advertising, marketing to third parties, or any commercial purpose unrelated to running the program.
How Long We Keep It
Retention periods are tied to the legitimate purposes for which the data was collected:
- Intake conversations & inactive prospects: retained for up to 12 months after the conversation closes, then deleted.
- Active participant program data: retained for the duration of the season plus 3 years for transcript verification and admissions reference letters.
- Featured Cohort entries (with consent): retained indefinitely in the Hall of Fame archive — participants may request removal at any time.
- Aggregate anonymized statistics: retained indefinitely for historical program reporting; no individual is identifiable from these statistics.
Your Rights
Under PIPL and other applicable privacy frameworks, you have the right to:
- Access — request a copy of the personal information SIC holds about you.
- Correct — ask us to fix incorrect information (e.g., school name, contact details).
- Delete — ask us to delete your personal information, subject to record-keeping obligations for program submissions you authored. Featured Cohort archive entries can be removed on request.
- Withdraw consent — for any optional data processing (such as Hall of Fame publication).
- Object or restrict — to certain processing activities, in line with applicable law.
To exercise any of these rights, reach the SIC program desk via WhatsApp — the advisor will route your request to the privacy contact and respond within 30 days.
Children & Minors
SIC participants in grades 6 through 9 are typically minors. For these participants:
- Both parent/guardian consent and school awareness are required before intake completes.
- Communications about a minor’s participation are shared with both the participant and the listed parent/guardian.
- Featured Cohort publication requires explicit, separate parental consent in addition to participant consent.
- Parents may request access to all data SIC holds about their minor child at any time.
SIC’s data handling for minors complies with PIPL provisions on children’s data (Chapter II Section 3) and aligns with international standards including COPPA (United States) and the GDPR’s special-category protections for minors.
Cross-Border Data Transfers
SIC is a global program with participants from multiple jurisdictions. Participant data may be processed across borders as part of normal program operations — for example, a Senior team with members in three countries necessarily involves data flows across those countries.
SIC stores primary program data within mainland China (on Bloom platform infrastructure). Where mentor or judging activity involves access by individuals located outside China, that access is governed by program-staff confidentiality agreements and limited to the specific submission(s) being reviewed.
Where Chinese law requires cross-border transfer assessments for specific data categories, SIC conducts those assessments and obtains separate consent before transfer. The WhatsApp intake conversation flags any such consent requirements for participants in affected jurisdictions.
Cookies & Tracking
This website uses minimal cookies:
- Functional cookies required for WhatsApp code rendering on the contact page.
- Anonymous analytics measuring page-view aggregates (no individual identification, no cross-site tracking).
We do not use advertising cookies, retargeting pixels, or third-party tracking scripts. You can disable cookies in your browser settings without losing access to the site’s content.
Privacy Contact
For privacy-related questions, requests under §06 (your rights), or concerns about how SIC handles your data, reach the SIC program desk via WhatsApp at the QR code on our Contact page. The advisor will route privacy inquiries to the designated privacy contact at SKT.
For formal privacy complaints that cannot be resolved with the program desk, participants in China may also file with the Cyberspace Administration of China (CAC); participants in other jurisdictions may file with their local data protection authority.