Effective Date: July 1, 2019
Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.
Personal Information. “Personal Information” is data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.
Our Services. The Services referenced in this Policy include the Services provided by us.
References to “you.” In this Policy, “you” means anyone who uses our websites, applications, or other Services. If you are an employee or applicant that uses our Services, this Policy explains how we collect, use, and disclose your Personal Information in the context of your use of our Services.
Authoritative Version. When the text of this Policy is available in multiple languages, the English version is the authoritative version, except where prohibited by applicable law.
2. INFORMATION WE COLLECT
The Personal Information that we collect and our use of that information depends on your relationship with us and the requirements of applicable law as described below.
We collect information:
- that you provide to us directly.
- that your company, broker, host or relatives provides to us;
- about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies;
- If you opt in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts; and
- that we obtain from other sources.
INFORMATION COLLECTED FROM YOU
Privé requests different types of Personal Information from you and your company or others, depending on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:
- Contact Information, including your name, mailing address, phone number, email address, and other information that enables us to contact you;
- Verification Information, including a photo ID or government issued identification, and date of birth;
- Professional Information, including your company name, title, role, team, and other information about your profession;
- Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;
- Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through automated chatbots, Amazon Echo, other voice assistants, or similar technology, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services;
- Device and Usage Information, including information about your computer or device. This includes:
- Device identifiers, such as IP address, WiFi MAC address, and Bluetooth address.
- Depending on your device settings, we collect geolocation information, such as through your mobile device’s GPS signal or WiFi signal, and information about your contacts;
- Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, and your offline activity, including information about events you attend; and
- Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. We will also process personal information included in content and information that you add to your member network or other community profile. References to “Other Personal Information” in this Policy and the product-specific links below refer to all Personal Information referenced in this Policy.
INFORMATION COLLECTED ABOUT YOU
- Social Media. Privé collects Personal Information to enable you to use online social media resources. If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.
- Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian. We also may receive Personal Information about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.
- Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to coming to the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
- Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Privé enables you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools transmit Personal Information to Privé to enable you to access your user accounts and to enable Privéto track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.
ANONYMOUS, AGGREGATED, AND OTHER INFORMATION
We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.
In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.
3. USE OF PERSONAL INFORMATION
How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:
- provide you with our products and Services, including online and offline events, and other materials you request;
- protect against fraud, abuse, or harm and otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
- respond to or fulfill customer service requests;
- analyze, better tailor, and improve our products and Services;
- comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.
LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others a Secure Environment, and analyzing, improving, and better tailoring our products and Services.
We also generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third-party websites, and in providing promotions, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent.