PRIVACY POLICY

CFLAB LLC and CoFoundersLab (“CFLAB”), together with CFLAB affiliates, parent company and subsidiaries (collectively, “we”, “us” or “our”), is the controller of your personal data under this Privacy Notice and is a services company offering subscription memberships for entrepreneurs to connect with others for the purpose of cofounding start- up companies (the “Business”). As a part of our operations and payment process, we gather certain types of information from and about online visitors and users through our website.

This Privacy Policy applies to CoFoundersLab.com, CoFoundersLab-branded apps, CoFoundersLab Learning & Accelerator Programs, CoFoundersLab Advisors Network, and other CoFoundersLab-related sites, apps, communications and services (“Services”).

This Privacy Notice explains our practices with respect to personal data we collect and process. It applies to information collected from and about visitors and users (“you”) through our website operated by us (either directly or through our service providers) the respective web pages, sub-domains, and any other websites (and subdomains thereof) that we operate and that link to this Privacy Notice (collectively, the “Website”). This Privacy Notice also applies to information collected from or about you through email and other electronic submissions and communications between you and us, as well as to information collected at by our Business.

This Privacy Notice does not apply to information collected by any other company or third-party site, application or content (including advertising) that may link to or be accessible from the Website, who may have their own policies that govern their use of your personal data; to the extent your personal data is transferred to us, depending on the purpose and basis on which it was transferred, it will be subject to this Privacy Notice or to the privacy terms of such service provider or partner. Certain transactions offered while using the Services may be processed or provided by service providers and other strategic partners, even though it appears that you may not have left the Website or our Business (e.g., service providers that provide payment processing).

Please read this Privacy Notice carefully. It explains how we process and safeguard personal data about you. By visiting and/or by voluntarily providing personal data to us through or through or in connection with the Business, you acknowledge that you have read and understand the practices contained in this Privacy Notice. If you are providing information through the Website for or on behalf of a third party you hereby represent that you have the right to do so and that you have provided that party with a copy of this Privacy Notice, and all references to “you” or “your” data or personal data herein refers to the data or information of both you and such individual, as applicable.

This Privacy Notice is subject to any agreements, including the Terms of Use posted on our Website, that govern your use of our Website. Depending on your activities when visiting our Website, you may be required to agree to additional terms and conditions. We encourage you to review this Privacy Notice frequently, as it may change from time to time.

• A. TYPES OF INFORMATION COLLECTED ABOUT YOU AND HOW IT IS COLLECTED

We and our service providers collect various types of information from and about you, including:

• “Personal data,” which is information about an identified or identifiable individual. This includes, for example, your name, email address, telephone numbers, company affiliation, title, physical address, screen names, credit card details (including the three or four digit security code on the back of your credit card), bank account or other payment information, credit information, birth date. Personal data also may include information that may not be personally identifiable standing alone (for example, your age), but which may become personally identifiable when combined with other personal data (for example, your age combined with your name).


• “Non-personal data” is information that is about you, but which does not, and cannot be used to, identify you individually and is not linked to any personal data, including: aggregated data, such as information regarding use of our Website (including clickstream data, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website) and traffic patterns relating to the Website. Non-personal data may include personal data that has been anonymized in such a manner that it cannot be used, alone or in connection with other information, to identify you. Non-personal data also may be aggregated with non-personal data about others to create aggregate data.

We may collect this information through various means, including: (a) directly from you when you provide it to us, for example, via forms that you fill out on the Website, through emails and other communications and information that you submit via the Website, and through your other activities on the Website; (b) automatically as you navigate through and interact with the Website, including via server logs, cookies, pixels, beacons, analytics, and other tracking technologies; and (c) from third parties, including without limitation our service providers, analytics providers, intermediaries, analytics providers, and through your interactions with us on or involving social media websites or accounts.

Information You Share With Us

The information we collect may include the following types of personal data that you share with us:

• 1. Information you provide when you register for the Website, make a purchase, participate in an offering made available on the Website, including without limitation your contact information (such as your name, address, zip code, email address, and/or phone numbers), your screen name or username, and your payment information (such as your credit card details, bank and bank account routing information, or other information);


• 2. Your demographic information, such as your age, gender, marital status, number of children, and nationality;


• 3. Information that you share in response to surveys and other market research;


• 4. Information that you include in an email, general comment, or recommendation sent through on our Website, as well as records and copies of that correspondence (including email addresses);


• 5. If you choose to log into the Website through social sign ins, personal data collected from your social media account consistent with your settings within the applicable social media service, such as photos, name, gender, contact information, and other information; and


• 6. Other personal data that you choose to provide to us including but not limited to as outline below.

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You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by syncing your address book or calendar.

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about them, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

Others may post or write about you.

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services

Others may sync their contacts or calendar with our Services.

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.

Others may sync their contacts or calendar with our Services.

If you communicate through our Services, we learn about that. We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a CoFoundersLab connection request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages.

When your employer or school buys a premium Service for you to use, they give us data about you. Others buying our Services for your use, such as your employer or your school, provide us with personal data about you and your eligibility to use the Services that they purchase for use by their workers, students or alumni. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services, such as our recruiting, sales or learning products.

We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your CoFoundersLab account. We receive information about your visits and interaction with services provided by others when you log-in with CoFoundersLab or visit others’ services that include our plugins (such as “Share”), ads, cookies or similar technologies.

Whether you provide this information is your choice; however, please bear in mind that in many instances certain personal data is necessary for you to participate in a particular activity, for us to provide a certain service or benefit to you, or for you to gain access to certain features, services or content on our Website. If you elect not to provide us with certain personal data, you may not be able to participate in a particular activity, realize a benefit we may offer, or gain access to certain content, functionalities or services.

Services

Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive. We use your data to authorize access to our Services.

Stay Connected

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you will “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your settings, when you connect with other Members, you will be able to search each others’ connections in order to exchange professional opportunities.

We will use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event).

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or watch related learning content to help you towards that new skill. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your settings we may notify others that you have updated your profile, posted a blog, took a social action made new connections or mentioned in the news.

Career

Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to partner or be hired by you. We will use your data to recommend jobs or mentees, show you and others who work at a company, in an industry, function or location or have certain skills and connections. You can signal that you are interested in changing jobs and share information with job recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to profile and provide recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members and schedule and prepare meetings with them. If your settings allow, we scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, drafting responses, summarizing messages or recommending next steps.

Premium Services

Our premium Services allow paying users to search for and contact Members through our Services, such as searching for and contacting job candidates, sales leads and co-workers, manage talent and promote content through social media.

We sell premium Services that provide our customers and subscribers customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and sales solutions. Customers can export limited information from your profile, such as name, headline, current company, current title, and general location (e.g., Dublin), in order to manage sales leads or talent, unless you opt-out. We do not provide contact information to customers as part of these premium Services without your consent. A premium Services customer can store information he/she has about you in our premium Services, such as a resume or contact information or sales history. The data provided about you by these customers is subject to the policies of those customers.

Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your CoFoundersLab inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example discussion and messages between connections.

Advertising

We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

• Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
• Member-provided information (e.g., profile, contact information, title and industry);
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
• Information from advertising partners and publishers; and Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the CoFoundersLab Services, that action may be mentioned with related ads.

Ad Choices

We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks for their advertising except for: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) data already visible to any users of the Services (e.g. profile). However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Other Research

We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

Customer Support

We use data to help you and fix problems. We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs). We share your data across our different Services and CoFoundersLab-affiliated entities. We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.

Service Providers

We may use others to help us with our Services. We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Aggregate Insights

We use data to generate aggregate insights. We use your data to produce and share aggregated insights that do not identify you. For example we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or demographic workforce insights.

Security and Investigations

We use data for security, fraud prevention and investigations. We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

Automatically-Collected Information

When you visit and as you navigate through and interact with the Website, we and third parties may automatically collect information about your visits to our Website, your equipment, and your browsing action and patterns and your activities on the Website. This information may include, but is not limited to:

• Details of your visits to our Website including mobile apps and the resources that you access, such as traffic data, location data, logs and other communication data, the third-party website from which your visit originated, clickstream data, the search terms you use on our Website, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website.
• Information about your computer or devices and Internet connection, such as your IP address, your general geographic location, your computer or device type and its capabilities and features, the operating system or platform you are using, your browser type, and your Internet Service Provider.
• Information about traffic patterns, number of visits to certain pages, visits from other websites or to third-party websites linked to the Website, and visitors’ use of particular services and interest in services, information or features of the Website


• We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

Automatically-collected information often is processed to create aggregated statistical or demographic data. We may share such aggregated data with third parties.  Automatically-collected information that contains or constitutes personal data, as well as non-personal data that we maintain or associate with personal data collected in other ways or received from third parties, is be treated as personal data and used and shared as disclosed in this Privacy Notice.

Cookies and Other Tracking Technologies

We and third parties may place “cookies”and similar technologies on our Website to collect certain information. A “cookie” or “browser cookie” is a small text file that can be stored on your computer’s hard drive or other device, if your web browser or device settings permit. Certain features of the Website also may use local stored objects (or Flash Cookies) to collect and store information, including information about your preferences and navigation to, from, and on our Website. Cookies allow us and our service providers, for example, to customize your experience and make your visit to the Website easier (for example, recognizing when you return, remembering your viewing preferences, enabling social media sign in functionality, facilitating social sharing, and, if you are a registered user, remembering your password), measure activity on the Website, track conversions, target ads, and provide analytics. While some cookies are deleted when you close your browser, others remain even after you close your browsing session. .

We and other third parties also may use pixel tags, web beacons or clear gifs, which are tiny files with a unique identifier, similar in function to cookies that are placed in the code of a web page or an email. These technologies might be used, for example, to allow us and our service providers to track conversions, to send emails to you in a format you can read, to count users who have visited our Website, seen our ads, opened our emails or clicked on any links in our emails, to inform us what content and advertising is effective, to optimize the Website and its content, to reduce or eliminate messages sent to customers, to enhance Website usability, to provide you with ads and other promotions and content that may be of interest to you based on your online activities, and to collect other information about you and your visit when you use the Website. In addition, when you click on a link in an email, we or our service providers may record the individual response to allow us to customize our offerings to you.

We may analyze the information derived from cookies, pixels and other technologies and match or combine that information with data provided by you or another party. We engage various service providers who may use unique identifiers, cookies, pixels, beacons, and other technologies to provide us with analytics about how and in what ways you interact with us and use the Website, and to deliver advertisements and content that may be of interest to you (known as “interest-based advertising” or “online behavioral advertising”). To the extent third parties are using pixels, cookies, beacons, or other tracking technologies, we do not control the use of those technologies or the resulting information, and we are not responsible for the policies of those companies.

Please keep in mind, however, that you may not be able to access the full functionality of our Website if cookies are disabled.

Information Obtained from Third Parties

We receive personal data from third parties that provide web analytics and usage information to us. In addition, if you choose to interact with us on social media platforms by posting to our social media accounts or pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us depending on the social media platform and your account settings, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

For the purposes of this Privacy Notice, “partners” means licensors, franchisees, vendors, service providers, and other third parties] with which we have a business relationship.

• B. HOW WE PROCESS PERSONAL DATA

 Legal Bases for Processing

We process personal data for, or based on, one or more of the following legal bases:

• Performance of a Purchase. We use personal data to enter into and to perform under, an agreement between us, such as when you make a purchase.


• Legitimate Interests. We use personal data for our legitimate interests, including contact information, buying history and inquiry history, and website usage data.


• Compliance with Legal Obligations and Protection of Individuals. We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.


• Your Consent. We process certain personal data because you have given us your consent to process it in that manner.


• Operational Processing of Personal Data
  

We may process non-personal data (including aggregated information) for any lawful purpose.  In addition, we may use personal data collected from or about you as described in this Privacy Policy for the purposes disclosed to you or as otherwise permitted or required by law, including:

• To provide, track, and process the purchases and transactions that you request;
• To validate your identity, to verify communications from you, and to respond to your emails, questions, comments, requests for information, and complaints and to provide customer service;
• To send you updates and information, such as communications about purchases, programs you have joined, and changes to our terms, conditions and policies;
• To conduct customer satisfaction, market research or quality assurance surveys ;
• To conduct market research;
• To conduct and administer sweepstakes, prize draws and other contests;
• For marketing purposes, including without limitation interest-based advertising, other targeted promotions, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities, including for select marketing partners of ours;
• To send you marketing communications about the products, marketing partners and other third parties;
• To cross-reference, supplement and combine with other information that we have acquired about you or may acquire about you through other sources, except where prohibited by applicable law or regulation;
• To monitor, track, and analyze Website usage and trends, to personalize and improve the Website, and to increase the Website’s functionality;
• To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Website;
• To protect the security or integrity of our network, systems, Website, and business;
• To prevent fraud and other prohibited or illegal activities, to investigate and resolve disputes and problems, and to otherwise comply with applicable laws and regulations;
• To enforce our Terms of Use and other contractual obligations;
• For any other purpose that is disclosed to you at the point of collection of the personal data;
• For any purpose for which you provide your prior consent; and
• In other ways naturally associated with the circumstances in which you provided the personal data, and for any other lawful purpose.
  

In addition, we use IP addresses for purposes of system administration, for Website optimization, Website security assessments, to report non-personal aggregate information to others, to track the use of our Website, and to get a sense of where our Website visitors are located. We also we use your IP address to personalize content on the Website and to identify you.

How We Share Your Information

We may share non-personal data with any third parties for any lawful purpose. Unless otherwise prohibited by law, we disclose personal data collected from or about you as described in this Privacy Notice to the following types of third parties and for the following purposes:

• Affiliated Companies: We may share your information with our affiliated companies and other business ventures that are licensed, owned, operated, and/or managed by us and other companies under common control, who may use personal data for any of the purposes disclosed in or consistent with the terms of this Privacy Notice


• Marketing Partners: We may share your personal data with our co-promotional partners and other business partners with whom we have marketing or other relationships for joint marketing purposes and your use of the Website acknowledges or consents to the direct provision of your personal data to such parties when you provide it to us.


• Service Providers:  We may share your information with our service providers who assist us by performing core services (such as hosting, billing, fulfillment, data storage, security, processing credit card payments, customer service, credit reporting, accounting, administering sweepstakes, surveys, email and mailing services, and delivering packages) related to the operation of the Business and the operation of the Website, the processing and fulfillment of product orders, and/or by making certain Website functionality available to our users.


• Transactions: In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data collected from or about you provide, and other information concerning your relationship with us. Any successor may use your information for the same purposes set forth in this Privacy Notice.


• Legal: We reserve the right to your personal data to identify you and, where permitted or required by law or applicable regulation, we will provide any information about or relating to you, including any personal data about you, to third parties if we reasonably believe that such action is necessary to: (a) comply with a court order, subpoena or other legal or regulatory requirements; (b) otherwise fulfill a government request for information; (c) protect or defend our legal rights, our Website, or other online users; (d) respond to claims that any posting or other content of our Website violates the rights of third parties, including without limitation providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act; (e) in an emergency, to protect the health and safety of our Website’s users or the general public; or (f) enforce compliance with our Terms of Use or other contracts.


• Purpose Fulfillment: We disclose personal data to fulfill the purpose for which you provide it.


• Consent: We disclose personal data with your consent and/or when you request that we do so.


• C.RETENTION OF PERSONAL DATA

We retain personal data for as long is necessary or appropriate to fulfil the purpose for which it was collected, as well to the extent necessary or appropriate to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. We consider multiple factors, including legal requirements, the scope and nature of the personal data, and potential risk of harm to data subjects from a data breach, in determining the appropriate retention period. If you have a specific question regarding retention of your personal data, you may contact us.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new CoFoundersLab every few years, we will retain your information and keep your profile open until you decide to close your account.

If you choose to close your CoFoundersLab account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through messages, updates or discussion posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

• D. YOUR RIGHTS REGARDING PERSONAL DATA

You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.

These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:

• The right to know whether, and for what purposes, we process personal data about you;
• The right to be informed about the personal data we collect and/or process about you;
• The right to learn the source of personal data about you we process, where we obtain that personal data from a source other than you.
• The right to access, modify, and correct personal data about you.
• The right to know with whom we have shared personal data about you, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);
• Where processing of personal data about you is based on consent, the right to withdraw your consent to such processing; and
• The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

Accessing, Modifying, Rectifying, and Correcting Collected Personal data

We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

In accordance with applicable law, you may obtain from us certain personal data in our records. You can contact us as described below to access, review, update, or correct certain personal data. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.

Your Privacy Rights

In addition to the above-listed rights, certain laws provide individuals with enhanced rights in respect of their personal data. These rights may include, depending on the facts and circumstances surrounding, and in certain cases the legal basis for, the processing of personal data, following:

• The right to be informed of whether we hold personal data about you.
• The right to object to decisions based on profiling or automated decision making that produce legal or similarly significant effects on you;
• The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (a) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (b) performance of a task in the public interest;
• The right to challenge the accuracy and completeness of your personal data and have it amended as appropriate;
• The right to be provided with information about our policies and practices with respect to the management of personal data, including: (a) the name or title, and address, of the person who is accountable for our privacy policies and practices; (b) the means of gaining access to personal data; (c) a description of the type of personal data held by us, including a general account of its use; (d) a copy of any brochures or other information that explain our policies, standards, or codes; and (e) what personal data is made available to related organizations;
• The right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and
• The right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.

Where required by applicable law, we will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging. Note that we may need to request additional information from you to validate your request.

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.  For personal data that we have about you:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Your California Privacy Rights

California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personal data for direct marketing purposes

We are only required to respond to a customer request once during any calendar year per person. To make such a request you should send an email to info@cofounderslab.com in the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Requests are free of charge.

Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

E. YOUR CHOICES

In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, you can agree to receive some communications but not others. At any time, you also may opt-out of receiving future commercial emails from us by following the “Unsubscribe” instructions contained in any commercial emails that you receive from us.  You also may contact us if you want to opt-out from receiving future commercial correspondence, including marketing emails, from us. If applicable and appropriate, make the requested change in our active databases within a reasonable timeframe in compliance with applicable law. Please remember that we may not be able to fulfill certain requests while allowing you access to certain benefits and features. Even if you unsubscribe from our marketing communications, you may continue to receive certain communications from us, such as transactional, customer service or other relationship messages, messages about your account and profile, and emails in response to communications or requests for information that we receive from you.

If you want to limit or prevent our ability to collect location information from you, you can deny or remove the permission for the Website to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.

F. INTEREST-BASED ADVERTISING

We may allow third parties to collect information about your online activities on our Website through unique identifiers, cookies, pixels, beacons and other technologies (as described above). These third parties include advertising networks that may use unique identifiers, cookies, pixels, beacons, and other technologies to track and collect information about your interests when you visit our Website and other websites or view or interact with one of the advertisements they place on various websites or mobile platforms. The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our Website and across the Internet tailored to your apparent interests.

G. ANALYTICS

We engage service providers to provide analytics data for the purposes of understanding and optimizing web usage, for business and market research purposes, measuring conversion tracking, and measuring the effectiveness of our content and online advertising campaigns. These service providers may use cookies alone or in conjunction with unique identifiers, pixels, beacons and other tracking technologies to collect information about you when you use the Website.

H. PUBLIC FORUMS

We may offer blogs, message boards, bulletin boards, or similar public forums where you and other users of our Website can communicate. Unless otherwise required by applicable law or regulation, the protections described in this Privacy Notice do not apply to information (including personal data) that you post to these public forums.

We may use personally identifiable and non-personal data about you to identify you through your postings in a public forum. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Notice. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Website.

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in our help center, your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

• When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
• In a discussion, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
• Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
• When you follow a person or organization, you are visible to others and that “page owner” as a follower.
• We let senders know when you act on their message, subject to your settings where applicable.
• Subject to your settings, we let a Member know when you view their profile.
• When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.

Communication Archival

Regulated Members may need to store communications outside of our Service. Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by those Members outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look-up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your CoFoundersLab contacts into its own service. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user a “mini” CoFoundersLab profile of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

I. CHILDREN

The Website is a general audience site, and the features, programs, promotions and other aspects of our Website requiring the submission of personal data are not intended for anyone under 18 years of age.  If you are under 18, you may not access, use or register on the Website. We do not knowingly collect personal data from individuals under 18. If you are a parent or guardian of an individual under 18 and believe he or she has disclosed personal data to us without your permission, please contact us at info@cofounderslab.com.  A parent or guardian of a child under the age of 18 may request deletion of such child’s personal data as well as prohibit the use thereof.

• J. SECURITY

We take reasonable steps to protect against the loss, misuse and alteration and protect the confidentiality, integrity, availability, and resilience of the information under our control, including Secure Sockets Layer (SSL) technology to encrypt the transmission of non-public personally identifiable financial and transaction information over the Internet, provided you are using an SSL-enabled device. We also utilize other reasonable security measures such as firewalls, security patches, and anti-virus programs, to protect non-public personal data. We also take steps to ensure personal data is backed up and remains available in the event of a security incident. We periodically test, assess, and evaluate the effectiveness of our safeguards and security controls.

Despite these efforts, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks), and we cannot and do not guarantee or warrant the security of any information you disclose or transmit to us via the Internet, and are not responsible for the theft, destruction, or inadvertent disclosure of your personal data. For your own privacy protection, we recommend that you do not include any non-public personal or sensitive personal data such as passwords, social security numbers, credit card details, or bank account information, in any emails that you send to us. We will not contact you by email or text message to ask for such information.

K. OTHER WEBSITES/LINKS

As a convenience, our Website may reference or provide links to third-party websites and/or services that we do not control or maintain. When you access these third-party websites or services, you leave our Website, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access such third-party websites and services at your own risk. Be aware that those third-party websites collect information and operate according to their own privacy practices. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave the Website and to read the privacy statements of all third-party websites to understand how they collect, use and disclose personal data before submitting any personal data to those websites.

L. INTERNATIONAL USE AND DATA TRANSFERS

Your personal data will be stored and processed in the United States. If you are using the Website or other Services from outside the United States, by your use of the Website or other Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States. For transfers of data out of the European Economic Area, we use standard contractual clauses, and, as appropriate, other applicable mechanisms.

M. Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of CoFoundersLab, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

N. Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the CoFoundersLab Services you have requested)) and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data.

O. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Website. We may change or update this Privacy Notice in the future. You can identify the date that this Privacy Notice was last updated by looking at the date at the top of this Privacy Notice. Any revisions to this Privacy Notice will take effect upon posting to the Website. We will notify you of any material changes to this Privacy Notice either by sending an email to the email address that you provided to us and/or by placing a notice on the homepage of the Website. We encourage you to regularly review the current version of this Privacy Notice on the Website. Your use or continued use of the Website following posted changes constitutes your acknowledgement of the revised Privacy Notice then in effect.

P. CONTACT US

If you have any questions, comments or concerns about this Privacy Notice, or if you would like to exercise the choices discussed above, please contact us (a) by email info@cofounderslab.com (b) by postal mail in the U.S. at 1925 Century Park E., Floor 16th, Los Angeles, CA, 90067, U.S.A.

If you are located in the European Economic Area, and you wish to raise a concern regarding our use of your personal data, you have the right to do so with our lead supervisory authority, the U.K. Information Commissioner’s Office (the “ICO”) at www.ico.org.uk , or your local supervisory authority. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Consult our Cookie Notice for more information about analytics, as well as how to control and/or opt out of certain web tracking technologies, including cookies and certain analytics providers.