Introduction
COMDUIT provides a platform of services for the startup community.
Our registered users (“Members”) may open an account as a “Cofounder or Collaborator” (for users who are seeking cofounders or collaborators to join their startup, for users who seeking to join a startup, for users who are looking for startup or career reinvention coaching services and an introduction to potential investors), as an “Investor” (who must complete our accredited investor questionnaire), as a “Coach” (who must complete the coach application and complete a profile providing coaching experience, educational, professional and other background information).
Services
This Privacy Policy applies to your use of our Services and applies to all COMDUIT LLC sites, apps, communications and services (“Services”).
Data Controllers and Contracting Parties
We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
If you reside in the “Designated Countries”: a EU-based COMDUIT affiliate will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
If you reside outside of the Designated Countries: COMDUIT LLC will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services; you are entering into the Terms Agreement with COMDUIT LLC.
As a Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.
Change
Changes to the Privacy Policy apply to your use of our Services after the 10th June of 2020.
COMDUIT LLC (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
1. Data We Collect
1.1 Data You Provide to Us
You provide data to create an account with us.
Registration
To create an account, you need to provide data including your name, email address and/or mobile number, and a password. If you register for a premium service, you will need to provide payment (e.g., credit card) and billing information.
You create your COMDUIT profile and Project profile (a complete personal and project profile helps you get the most from our Services).
Personal and Project Profile
You have choices about the information on your personal profile, such as your education, work experience, skills, photo, city or area and endorsements. If you add a project profile you have choices about the project stage, industry, logo, description and type of collaborators you are seeking. You don’t have to provide additional information on your personal or project profile; however, profile information helps you to get more from our Services, including helping cofounders, collaborators and investors 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.
Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out the sign-up form, create a project profile or pitch deck or upload a pitch deck. 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 with our Services, we will collect your address book information to keep growing your endorsements.
1.2 Service Use
We log your visits and use of our Services.
We log usage data when you visit or otherwise use our Services, including our platform technology such as when you view another member’s profile or project. We use logins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.3 Cookies, Web Beacons and Other Similar Technologies
We collect data through cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.
1.4 Your Device and Location
We receive data from your devices and networks, including location data.
We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP.
1.5 Other
We are improving our Services, which means we get new data and create new ways to use data.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.
2. How We Use Your Data
We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.
Our Services help you connect with others, find and be found for startup collaboration, coaching and investment opportunities. We use your data to authorize access to our Services.
2.1 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.
2.2 Marketing
We promote our Services to you and others. We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.
2.3 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).
2.4 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.
2.5 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.
3. How We Share Information
3.1 Our Services
You understand and agree that any data that you include on your personal and project profile and any content you upload or social action (e.g. endorsements, follows, shares) you take on our Services will be seen by others.
Personal and Project Profile and Pitch Deck
Your personal and project profile is fully visible to all Members. Subject to your settings, you can change the visibility of your Project Profile.
Follows, Views, Endorsements, Saving Profiles, Messages, Adding Team Members to BMC and Controls for Pitch Deck
Our Services allow viewing and sharing information including:
3.2 Service Providers
We may use others to help us with our Services.
We use others to help us provide our Services (e.g., payments, signature, 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.
3.3 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 COMDUIT, 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.
3.4 Change in Control or Sale
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.
4. Your Choices & Obligations
4.1 Data Retention
We keep most of your personal data for as long as your account is open.
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 cofounder, collaborator or coach every few years, we will retain your information and keep your profile open until you decide to close your account.
4.2 Rights to Access and Control Your Personal Data
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:
You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.
4.3 Account Closure
We keep some of your data even after you close your account.
If you choose to close your COMDUIT 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.
5. Other Important Information
5.1. Security
We monitor for and try to prevent security breaches. We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
5.2. Cross-Border Data Transfers
We store and use your data outside your country. We process data both inside and outside of the United States and rely on legally provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective as the laws of your own country.
5.3 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 COMDUIT 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, please contact us at info@COMDUIT.com
5.4. Direct Marketing and Do Not Track Signals
Our statements regarding direct marketing and “do not track” signals.
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
5.5. Contact Information
You can contact us or use other options to resolve any complaints.
If you have questions or complaints regarding this Policy, please first contact COMDUIT online at privacy@comduit.com. You can also reach us by physical mail at COMDUIT LLC. 210 Central Park South, Ste 5c. New York, N.Y. 10019
Last updated: June 10th, 2020.
