Privacy Policy

1. Who We Are

Civic Compute LLC is a software company incorporated in the United States. We license the 3COL Civic Compute Cooperative Orchestration Layer — a shared GPU infrastructure platform designed for educational institutions, including community colleges, polytechnics, and technical colleges. Our registered address and primary point of contact for privacy matters is listed at the bottom of this Policy.

2. Information We Collect

We collect information in the following categories:

A. Information You Provide

• Account registration information: name, institution affiliation, job title, email address, and phone number for institutional administrators and designated contacts.
• Contact form submissions: name, email, institution, and any message content you submit through our website contact forms.
• Billing and contract information: organization name, address, and payment details for institutional subscribers (processed through our payment processor; we do not store full payment card numbers).
• Support requests: information you provide when submitting a support ticket or contacting us for assistance.

B. Information Collected Automatically

• Usage data: pages visited, features used, session duration, and navigation patterns on our website and platform.
• Log data: IP address, browser type and version, operating system, referring URLs, and timestamps.
• Device information: device type, screen resolution, and general hardware identifiers.
• Cookies and similar technologies: session cookies for authentication, preference cookies for user settings, and analytics cookies (see Section 7).

C. Information from Institutional Partners

• When an educational institution deploys 3COL, the institution provisions end-user accounts (students, faculty, staff) through their own identity and access management systems. Civic Compute receives only the data elements necessary to authenticate and authorize those users on the platform — typically a username or institutional email, role designation, and institutional identifier.
• Job metadata: job submission timestamps, resource allocation requests, job duration, and completion status. We do not inspect the content of GPU workloads.
• Usage metrics provided to host institutions for revenue-share reporting: aggregate GPU hours consumed per institution, per allocation period.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the 3COL platform and associated services.
• Authenticate users and enforce institutional access policies set by the licensing institution.
• Process institutional subscriptions, calculate cooperative revenue-share distributions, and manage billing.
• Respond to inquiries, support requests, and communications from institutional administrators and contacts.
• Send transactional communications: account confirmations, service alerts, maintenance notices, and license renewal reminders.
• Monitor platform performance, diagnose technical issues, and improve system reliability.
• Analyze aggregated, anonymized usage patterns to improve platform features and user experience.
• Comply with applicable legal obligations, including tax reporting and financial record-keeping.
• Protect against fraud, unauthorized access, and other security threats.

We do not sell your personal information. We do not use student data for advertising, behavioral profiling, or any purpose unrelated to providing the educational services contracted by the licensing institution.

4. Student Data — FERPA and Educational Records

When Civic Compute processes data on behalf of an educational institution that is subject to the Family Educational Rights and Privacy Act (FERPA), we act as a “school official” with a “legitimate educational interest” as defined under FERPA, pursuant to the terms of our Data Processing Agreement with that institution. In that capacity:

• We use student data solely to perform the services described in the applicable service agreement.
• We do not disclose student records to third parties except as directed by the institution or as required by law.
• We do not use student data to build profiles for commercial purposes, serve advertising, or sell data to data brokers.
• Institutions retain ownership of and control over student records hosted on or processed by the 3COL platform.
• Upon contract termination, we return or destroy student data as directed by the institution in accordance with the Data Processing Agreement.

Institutions are responsible for obtaining any required consents from students and for ensuring their own FERPA compliance in connection with their use of the Platform.

5. How We Share Your Information

We do not sell, rent, or trade personal information. We may share information in the following limited circumstances:

• Service providers: We engage trusted third-party vendors to support platform operations, including cloud hosting (data remains within the United States), payment processing, email delivery, and analytics. These vendors are contractually bound to use data only as directed by Civic Compute and in accordance with this Policy.
• Institutional administrators: Usage reports and account activity summaries may be shared with the designated administrators at the licensing institution, consistent with their role as the data controller for their users.
• Legal compliance: We may disclose information if required by law, subpoena, court order, or government regulation, or if we believe disclosure is necessary to protect the rights, property, or safety of Civic Compute, our users, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, user information may be transferred as part of that transaction. We will notify affected institutions in advance.
• With your consent: We may share information for any other purpose with your explicit consent.

6. Data Retention

We retain personal information only as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active account data is retained for the duration of the institutional subscription plus a 90-day wind-down period following termination.
• Job metadata and usage logs are retained for 24 months for billing verification and cooperative revenue-share reconciliation, then deleted or anonymized.
• Contact form and support ticket data is retained for 36 months, then purged.
• Financial and billing records are retained for 7 years to satisfy tax and accounting requirements.

7. Cookies and Tracking Technologies

Our website and platform use the following categories of cookies:

• Strictly necessary cookies: Required for platform authentication, session management, and security. These cannot be disabled without disrupting service functionality.
• Preference cookies: Store your settings such as display preferences. These persist across sessions.
• Analytics cookies: We use aggregated, anonymized analytics to understand how users navigate our website and improve our content. We do not use third-party advertising trackers.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Disabling strictly necessary cookies will impair platform functionality. We do not currently respond to browser Do Not Track signals, but we do not use your data for targeted advertising regardless.

8. Data Security

We implement administrative, technical, and physical safeguards designed to protect your information against unauthorized access, alteration, disclosure, or destruction. Safeguards include:

• Encryption of data in transit (TLS 1.2+) and at rest using AES-256.
• Role-based access controls limiting internal access to personal data to personnel with a business need.
• Multi-factor authentication required for all administrative and privileged platform access.
• Regular security assessments, penetration testing, and vulnerability management.
• Incident response procedures with notification timelines consistent with applicable law.

No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

9. Your Rights and Choices

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention requirements and contractual obligations.
• Portability: Request your data in a structured, machine-readable format.
• Objection or restriction: Object to or request restriction of certain processing activities.
• Withdrawal of consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us using the information in Section 14. For requests related to student records, please contact your institution’s designated administrator, as the institution is the data controller for student data. We will respond to verified requests within 30 days.

10. Children’s Privacy

The 3COL platform is intended for use by post-secondary educational institutions and their students, faculty, and staff. We do not knowingly collect personal information from individuals under the age of 13. If you believe we have inadvertently collected such information, please contact us immediately and we will take steps to delete it.

For institutions serving students between 13 and 18, the institution is responsible for obtaining any parental or guardian consent required under COPPA or applicable state law.

11. Third-Party Links

Our website may contain links to third-party websites, tools, or resources. This Privacy Policy applies only to Civic Compute’s own services. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or platform features. When we make material changes, we will update the “Last Updated” date at the top of this page and, where required by law or where the change materially affects institutional users, we will provide advance notice by email to designated institutional contacts.

Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

13. Governing Law

This Privacy Policy is governed by the laws of the State of California, United States, without regard to its conflict-of-law provisions. Any disputes arising under this Policy shall be resolved in the courts of competent jurisdiction in Los Angeles County, California.

14. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please reach out to us. We are committed to working with you to resolve any privacy-related concerns promptly.