Depending on the circumstances and which Service you use, we may collect, obtain or otherwise acquire the following types of Personal Information about you, and we make and retain inferences drawn from such information
(1) Identifiers, such as your name, signature, postal address, zip code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.
(2) Certain characteristics protected by applicable law, such as gender, marital status, nationality, and country of origin.
(3) Commercial information, such as purchase history.
(4) Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.
(5) Geolocation data, such as the precise physical location of your Device.
(6) Audio, electronic, visual, thermal, olfactory, or similar information, such as voice recordings, video recordings, physical characteristics or description, and photos.
(7) Professional or employment-related information, such as occupation, employment history and record, and resume.
(8) Education information such as academic record.
(9) While we generally do not obtain other Personal Information that is often considered “sensitive,” such as biometric information (e.g., fingerprints, facial recognition images), financial account information (e.g., bank account, credit, debit or other payment card numbers or other financial information), government issued identification numbers (e.g., social security number, drivers’ license number, passport number, or state identification card number), insurance policy number, or medical, health or insurance related information, we may do so when such Personal Information is necessary to offer you certain Services.
a. Personal Information You Provide
We often receive Personal Information because you provide it to us. For instance, when you enter a
contest, complete a survey, purchase a Product, or register and/or set up an account/profile or
attend a conference or event, you may be provided, or required to choose, a password and/or User ID,
and you may provide a credit, debit, or payment account number, or other payment information, as
well as your name, telephone number(s), email and/or street address. Other Personal Information such
as your age, gender, and preferences may also be requested. In addition, we may acquire your
Personal Information when you contact us by telephone, postal mail, social media interaction or
messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire Personal Information
that you provide about other people, for example, when you use our “refer-a-friend” email feature or
purchase one of our Products as a gift.
b. Personal Information Automatically Collected
The Service also automatically collects certain information, some of which may be deemed Personal
Information. The information collected may include, without limitation, information about your
Device, such as the make, model, settings, specifications (e.g., CPU speed, connection speed,
browser type, operating system, device identifier) and geographic location of you and/or your
Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time
of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or
service(s) you arrived from, and other clickstream data. The Service may collect such information
even if the Service is not open on your Device or you’re not logged in. See Section VI for more
information on cookies and other technologies used to automatically collect information on or
through the Service.
c. Personal Information Acquired Elsewhere
We may also acquire your Personal Information offline, from third parties, or otherwise outside of
the Service. For example, we may purchase or otherwise acquire Personal Information from third party
consumer data suppliers/resellers, data enrichment providers and aggregators, business contact
databases, government entities, and our affiliates.
d. Social Network Integration
If you choose to access, visit and/or use any third party social networking service(s) that may be
integrated with the Service, we may receive Personal Information that has been made available to
those services, including Personal Information about your contacts on those services. For example,
some social networking services allow you to push Content from our Service to your contacts or to
pull information about your contacts so you can connect with them on or through our Service. Some
social networking services also will facilitate your registration for our Service or enhance or
personalize your experience on our Service. You should make sure you are comfortable with your
Personal Information the third party social networking services may make available to us by visiting
those services’ privacy policies and/or modifying your privacy settings directly with those
services. We treat Personal Information that we receive through third-party social networking
services in the same ways as all of your Personal Information we receive through our Service (as
described in Section IV below).
e. Be Careful Publicly Posting Personal Information
Please be aware that Content and Personal Information that you disclose in publicly accessible
portions of the Service may be available to other users, and may also be made available outside the
Service by third parties, so you should be mindful of all Personal Information, especially sensitive
Personal Information, that you may wish to post.
a. Processing Your Requests
We use your Personal Information to process your request for Content, to process your attendance at
an event or conference, and/or to process your request for Product(s). For example, if you subscribe
to any of our Products we may use your e-mail address to send you a confirmation notice and your
mailing address to send you the Product. Similarly, if you enter a contest, we will use your
Personal Information to notify you if you are a winner. If you enter a contest or submit Content to
us (e.g., a “letter to our editors” or online review or comment), we may also publish your name,
screen name, home town and other Personal Information you have provided to us.
b. Administering the Service
We also use and share your Personal Information for any lawful purpose in connection with
administering the Service, including without limitation for customer service, to help diagnose
problems with servers, to improve Products that we offer by tailoring them to perceived preferences,
to gather broad demographic information, to analyze trends, to seek compatible advertisers,
sponsors, clients and customers, and to track users’ movements around the Service and elsewhere on
the web or across apps and/ devices. Your geolocation data may specifically be used to show you
Content (including advertising and sponsored messaging) based on geographic location.
c. Access by Third Party Providers
(1) Service Providers. We allow access to your Personal Information by Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services. For example, Service Providers help us with technical maintenance, database management, market research, community and forums management, auctions, e-commerce, personal/job search, list rental, data coop management, our Products and Product recommendations, and other advertising functionality, including OBA (as defined in Section VII below), as well as credit/debit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. While we may seek to require Service Providers to follow appropriate privacy policies and will not authorize them to use your Personal Information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
(2)There are also times when you provide Personal Information to us in areas of the Service that may be managed or participated in by one or more Third Party Business(es). Moreover, we rent, sell, share, and transfer Personal Information to (i) list buyers who market their goods and services (commonly known as “list rental”); (ii) our advertising, marketing and sponsorship clients to market their goods and services; (iii) “data coops”, which are pooled databases containing the customer information of multiple publishers to enable the marketing use of such customer information by participating publishers; (iv) consumer data suppliers/resellers, data enrichment providers and aggregators, and other entities in the online behavioral advertising ecosystem for purposes of OBA (as described in Section VII below), data optimization, lead generation and other data driven projects; (v) social media and social networking services; and (vi) companies that help us with our Products and Product recommendations. In all such cases, the Personal Information may be used by us and by such Third Party Business(es) for their own purposes, each pursuant to its own policies. While we may seek to require Third Party Businesses to follow appropriate privacy policies, we do not bear any responsibility for any actions or policies of third parties.
(3) Related Entities. We share your Personal Information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section IV.
(4) Categories of Third Parties. For the sake of clarity, here is a list of recipients to whom we
disclose Personal Information:
d. Marketing Communications
We may also use your Personal Information to communicate with you about new features, events or
Products offered by us and Third Party Businesses, including our advertising, marketing and
e. Health, Safety, and Legal Requests
We may access, use, and share with others your Personal Information for purposes of health, safety
and other matters in the public interest. We may also provide access to your Personal Information in
order to cooperate with official investigations or legal proceedings brought by or otherwise
involving governmental and/or law enforcement officials, as well as private parties, including, for
example, in response to subpoenas, search warrants, court orders, or other legal process. We may
also use Personal Information to protect our rights and property and those of our agents, customers,
f. Employment Opportunities
If you provide your Personal Information to us in connection with an employment inquiry, we will use
your Personal Information to evaluate your job application, and for related recruiting, reporting
and recordkeeping purposes. We may maintain your Personal Information on file, whether we hire you
or not, to administer your relationship with us and/or for job applicant related reporting and
recordkeeping for as long as required or permitted by law.
g. Transfer or Sale of Our Business
As our business changes, we may buy or sell various assets owned or controlled by us. In the event
all or a portion of the assets are sold, assigned, transferred or acquired by another company due to
merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy
or otherwise, your Personal Information may be among the transferred assets.
h. Combining Information
We may merge, co-mingle, or otherwise combine information, including Personal Information, in
furtherance of the purposes above.
a. How to Opt-Out of Sharing for Marketing.
California residents, see Section X(a)(2) below. For all others, if you do not
wish to have Personal Information such as your name, email address, postal address or phone number
But note that, in order for us to properly administer the Service, we must continue to share your
Personal Information with Service Providers as described in Section IV(c)(1)
above (if you object to such sharing, you should not use the Service).
b. How to Opt-Out of Marketing Messages from Us.
If you do not wish to receive future marketing or other commercial messages from us, simply follow
the unsubscribe instructions contained within the message you receive. But note that you may
continue to receive certain communications from us that are necessary for the Service, such as
renewal notifications, invoices, technical notices, updates, security alerts, and support and
administrative service bulletins.
c. How to Update Your Personal Information.
If you have registered or created an account on any part of the Service, please use the mechanism or
contact information on the Service that allows you to change or update your member preferences, if
available, to keep all such Personal Information accurate and up-to-date. If no such mechanism or
changes by email or as described at the end of this
a. Cookies/Local Device Storage
The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Businesses may independently or in conjunction use Local Device Storage in connection with the Service in a way that collects Personal Information for the purposes described in the respective privacy policies, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control and tailor the display of ads to you based on your preferences, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage.
b. You May Disable Local Device Storage
If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.
c. Tracking Technologies
In addition to Local Device Storage, we and/or Third Parties may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”) on the Service, including in our communications with you, such as within e-mail and text messages and push notifications. We and Third Party Businesses use Tracking Technologies to determine which messages have been opened by recipients, and for all or some of the same lawful purposes described above for use of Local Device Storage.
d. Do Not Track (DNT)
Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitor’s browser. As discussed below, you may opt out of the use of your Personal Information for online behavioral advertising by third parties at any time. To find out more about DNT, please visit http://allaboutdnt.com.
a. How OBA Works
b. Opt-Out of OBA
If you do not want OBA, you may be able to opt-out by visiting http://www.aboutads.info,
http://www.networkadvertising.org, http://www.youronlinechoices.com/uk/ and/or by clicking the “Ad Choices” icon that appears in advertising served through OBA. Please note
that the option to opt-out applies only to tracking by Third Party Businesses across this Service and other sites, applications, destinations, and services, and not tracking among pages within the Service itself. Residents of California have additional options as described below in Section X(a)(2) to exercise choice with respect to OBA.
Your Personal Information may be processed, transferred to, and maintained on, servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
a. Security Measures
We take reasonable security measures to protect against unauthorized access to, or unauthorized
alteration, disclosure or destruction of, Personal Information.
b. No Liability for Breach
Because no data transmission is completely secure, and no system of physical or electronic security
is impenetrable, we cannot guarantee the security of your Personal Information or the security of
servers, networks or databases, and by using the Service you agree to assume all risk in connection
with your Personal Information. We are not responsible for any loss of such Personal Information or
the consequences thereof.
c. Breach Notification
In the event that we believe the security of your Personal Information in our possession or control
may have been compromised, we may seek to notify you. If notification is appropriate, we may notify
you by e-mail, push notification, or otherwise.
a. Consumer Privacy
The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of
California certain rights with respect to their Personal Information and requires us to provide such
individuals with certain information, described in this Section X(A).
We reserve the right to take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity to a reasonable or a reasonably high degree of certainty by matching information that you submit alongside your request with information that we have on our records. We may ask for supplemental information as needed to establish your identity.
(2) California residents also have the right to opt-out of the “sale” of their Personal Information. We put sale in quotation marks because the CCPA considers some transfers of Personal Information to third parties in exchange for value as sales, even if no money changes hands, such as when cookies and other Tracking Technologies are shared with Third Party Businesses to further their own commercial purposes such as generating and/or adding to profiles about individuals for OBA. California residents can exercise this right by doing both of the following:
(4) Certain of our Services involve the “sales” of Personal Information of California residents over 12 years of age and under 16 years of age. Where we have actual knowledge that a California resident is older than 12 and younger than 16, we will request affirmative authorization from the minor before selling the minor’s Personal Information.
Note that we can still share Personal Information with third parties if those transfers aren’t sales, such as with our Service Providers.
(5) The CCPA requires businesses to provide additional disclosures regarding the third parties to which we transfer Personal Information for business purposes and to whom we sell Personal Information. We provide those disclosures in the following table.
|Category of Personal Information||Categories of third parties to which we may have disclosed the Personal Information for a business purpose||Categories of third parties to which we may have “sold” the Personal Information|
|Internet or other electronic network activity information||
|Audio, electronic, visual, thermal, olfactory, or similar information||
|Professional or employment-related information||
|Financial, medical, or health insurance information||
|Inferences drawn from the above categories||
b. Shine the Light
California’s “Shine the Light” law, Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place as discussed above in X(A)(2).
c. Online Erasure
If you have any concerns or questions about any aspect of this policy, please feel free to contact
2925 Woodside Road
Woodside, CA 94062
Make sure to include enough information for us to help you, including for example your name, contact information, and the specific website, mobile site, application, and/or other service you’re contacting us about.
For communications on other matters, please contact us through the means described on the Service, if
available (for example, in the “Contact Us” section).
“Agreement” means all rules, restrictions, limitations, terms and/or conditions that apply to the
the Service, or otherwise communicated to users of the Service.
“Content” means all text, articles, photographs, images, graphics, illustrations, creative, copy,
artwork, video, audio, music, podcasts, ringtones, games, trademarks, trade names, service marks,
and other brand identifiers, designs, plans, software, source and object code, algorithms, data,
statistics, analysis, formulas, indexes, registries, repositories, and all other content,
information, and materials available on or through the Service, whether posted, uploaded,
transmitted, sent or otherwise made available by us, our licensors, vendors, and/or service
providers, or by you, and/or other users or third parties, including any such Content uploaded
manually or bookmarked by you and/or other users.
“Device” means any computer, tablet, mobile phone, television, or any other device capable of
accessing the Service.
“Personal Information” means information that identifies, relates to, describes, is reasonably
capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer, Device, or household, as further described in Section II(A) of this Privacy
Policy. Anonymous, de-identified, or aggregate information is not Personal Information as used
“Product” means any merchandise, item, product and/or service, including without limitation Content,
contests and surveys, magazines and other publications that may be featured, mentioned, reviewed,
described, auctioned, given away, rented, sold, distributed, or otherwise available on or through
the Service, either by us or third parties.
“Service” means each website, mobile site, application, email/text/SMS campaign, event, and/or other
activity, offering, or publication (regardless of how distributed, transmitted, published, or
broadcast) provided by us that links to, or references, this document, including without limitation
all Content, features and functionality thereof, such as widgets, plug-ins, and embeddable
“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit
legal entity to whom we disclose Personal Information for processing on our behalf for a “business
purpose” (as defined in the CCPA) pursuant to a written contract.
“Third Party Business” means any third party unaffiliated with us to whom we disclose Personal
Information for their own purposes, including without limitation our advertising, marketing and
sponsorship clients, list buyers, data coops, consumer data suppliers/resellers, data enrichment
providers and aggregators, and other entities in the online behavioral advertising ecosystem.
“We”, “Us”, “Our” and “GSV Bootcamp” means GSV, its parent, certain subsidiaries and/or affiliates, and each of their respective officers, directors, members, employees, independent and sub-contractors, agents, representatives, successors and assigns.
“You” or “Your”, whether capitalized or not, means all those who access, visit and/or use the
Service, whether acting as an individual or on behalf of an entity, including you and all persons,
entities, or digital engines of any kind that harvest, crawl, index, scrape, spider, or mine digital
content by an automated or manual process or otherwise. “You” and “Your” also includes your
administrators, executors, successors and assigns.