PRIVACY POLICY
Welcome, and thank you for your interest in LIFT99 (“Lift”, “we,” or “us”), our website at www.lift99.co and mobile devices applications, and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the site, our “Service”).
This Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the site, or by using the Service, you accept the privacy practices described in this Policy.
1. INTRODUCTION
We are a premium network to match our members with top talent mentoring and coaching activities to create successful future founders. Our invited and registered users (“Members”) share their general information and professional identities.
We are using behavioral data, relevant skills, feedback and patterns to predict right matches for the right community members to meet. Pre-validated network keeps the quality of discussions high, engaged and relevant to the skills and topics.
2. DATA WE COLLECT
We collect different types of information from or through the Service. The legal bases for Lift’s processing of personal data are that the processing is necessary for providing the Service. We may also process data upon your consent, asking for it as appropriate.
When you use the Service, you may provide, and we may collect personal data. Examples of personal data include name, email address, mailing address, mobile phone number, education, work experience, skills, photo, interests. You may provide your company name, stage, website, information about founding rounds. Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with personal data in various ways on the Service. For example, when you register for an account, use the Service.
When a Member uses the Service, we may automatically record certain information from the Member’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, operating system, proxy server, device type and/or ISP or your mobile carrier the web pages or sites visited just before or just after using the Service, the pages or other content the Member views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Member’s interaction with email messages, such as whether the Member opens, clicks on, or forwards a message. This information can be gathered from any Members.
You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), otherwise have the option to authorize an Integrated Service to provide personal data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.
We may obtain information, including personal data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with personal data that we collect through the Service, we will treat the combined information as personal data in accordance with this Policy.
3. HOW WE USE THE INFORMATION WE COLLECT
We use the information that we collect in a variety of ways in providing the Service and operating our business.
We use the information - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.
We may use a Member’s email address or other information – to contact that Member for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the personal data posted on the Service or with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications through contacting us by email privacy@lift99.co.
Our Services also allow to improve a Member professional skills, or learn new ones. We use the data we have about a Member to recommend relevant content and conversations on our Services, suggest skills a Member may have to add to their profile and skills that they might need to pursue their next opportunity.
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: personalize our Service, such as remembering a Member’s information so that a Member will not have to re-enter it during a visit or on subsequent visits; monitor and analyze the effectiveness of Service and third-party marketing activities; monitor aggregate site usage metrics such as total number of visitors and pages viewed; and track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
We may use third-party Service Providers to monitor and analyze the use of our Service:
Google Analytics to measure and evaluate access to and traffic on the app, and create user navigation reports. Google operates independently from us and has its own privacy policy, which we strongly suggest you review - https://support.google.com/analytics/answer/6004245
Amplitude - is provided by Amplitude, Inc. Amplitude operates independently from us and has its own privacy policy, which we strongly suggest you review: https://amplitude.com/privacy
Bugsnags - is provided by Bugsnag, Inc. Bugsnags operates independently from us and has its own privacy policy, which we strongly suggest you review: https://docs.bugsnag.com/legal/privacy-policy/
Elasticsearch - is provided by Elasticsearch, Inc. Elasticsearch operates independently from us and has its own privacy policy, which we strongly suggest you review: https://www.elastic.co/legal/privacy-statement
OneSignal - is provided by OneSignal, Inc. OneSignal operates independently from us and has its own privacy policy, which we strongly suggest you review: https://onesignal.com/privacy_policy
4. HOW WE SHARE INFORMATION
Except as described in this Policy, we will not intentionally disclose the personal data that we collect or store on the Service to third parties without the consent of the applicable Member. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
The Member profile is fully visible to all Members of our Services who are invited to using the app or who will be invited.
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process personal data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including compliance with various reporting obligations; for business or marketing purposes; or to assist such parties in understanding our Members’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
We may disclose personal data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to take precautions against liability, protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
Information about Members, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Members data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.
5. YOUR CHOICES AND OBLIGATIONS
We respect your privacy rights and provide you with reasonable access to the personal data that you may have provided through your use of the Services. We retain your personal data while your account is in existence or as needed to provide Services.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. If you choose to close or delete your account, your personal data will generally stop being visible to others on our services within 24 hours from the moment when we received your notification.
Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate expectation to do so.
You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact at privacy@lift99.co you also have a right to lodge a complaint with data protection authorities.
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email.
6. THIRD-PARTY SERVICES
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
7. THIRD PARTY COOKIES
We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the app. These third parties include business partners, which collect information when you view or interact with one of their advertisements on the app; and advertising networks, which collect information about your interests when you view or interact with one of their advertisements.
The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this app and on other sites across the Internet tailored to your apparent interests.
The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.
We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.
8. CHILDREN’S PRIVACY
Our Service is not directed to children under the age of 13, and we do not knowingly collect personal data from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that personal data has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, then you may alert us at privacy@lift99.co and request that we delete that child’s personal data from our systems.
9. DATA SECURITY
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize personal data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your personal data has been compromised, please contact us privacy@lift99.co
10. DATA RETENTION
We only retain the Personal Data collected from a Member for as long as the Member’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
the contents of closed accounts are deleted within 3 months of the date of closure;
backups are kept for 3 months;
billing information is retained for a period of 7 years as of their provision to Lift in accordance with the Estonian accounting and taxation laws;
information on legal transactions between Member and Lift is retained for a period of 10 years as of their provision to Lift in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.
11. SETTINGS
Although we may allow you to adjust your privacy settings to limit access to certain personal data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
12. DATA TRANSFER
We may transfer, process and store personal data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.
Some parts of our Services are hosted in the United State and some parts in Europe. We will comply with GDPR requirements providing adequate protection for the transfer of personal information outside of Europe. We may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
13.CHANGES AND UPDATES TO THIS POLICY
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
Please contact us with any questions or comments about this Policy, your personal data, our use and disclosure practices, or your consent choices by email at privacy@lift99.co
15. October 2018