PRIVACY POLICY

Updated October 15, 2020.

This Privacy Policy explains what personal data is collected when you join the Inclusive Startups LLC community (the “Community”), how such personal data will be used, shared.
 

BY JOINING THE COMMUNITY, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE AT LEAST 18 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Community. In such case, you must (a) delete your account using the functionality found in Slack, or contact us and request deletion of your data; (b) cancel any subscriptions using the links in the bottom of each email; and (c) email community@inclusivestartups.com to request deletion.
 

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Economic Area.

“Process,” in respect of personal data, includes collecting, storing, and disclosing to others.


TABLE OF CONTENTS
 
  1. CATEGORIES OF PERSONAL DATA WE COLLECT

  2. PURPOSES FOR PROCESSING PERSONAL DATA

  3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

  4. WITH WHOM WE SHARE YOUR PERSONAL DATA

  5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

  6. AGE LIMITATION

  7. INTERNATIONAL DATA TRANSFERS

  8. CHANGES TO THIS PRIVACY POLICY

  9. CALIFORNIA PRIVACY RIGHTS

  10. DATA RETENTION

  11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

  12. CONTACT US

 

  1. CATEGORIES OF PERSONAL DATA WE COLLECT
    We collect data you give us voluntarily (for example, when you enter your name, email, location or information about your business). We also may receive data about you from third parties (for example, when you update your profile via Slack or when you accept cookies for website tracking). Finally, we collect data automatically (for example, anonymously we can see your general location, by region, in aggregate with other users in Google Analytics, which helps us understand how to best support your needs, for example by considering ways to improve our community like inviting startup funders who invest in your local area).
     

  2. PURPOSES FOR PROCESSING YOUR PERSONAL DATA
    We process your personal data:

    1. To provide our Service (Inclusive Community Emails, Chat and Slack)
      This includes enabling you to use our Service in a seamless manner so that the features serve your goal(s) work, seeking ways to improve the community by better serving you and preventing or addressing Service errors or technical issues.

    2. To customize your experience
      We process your personal data, such as your email and any personal data you share via a Typeform signup form, to send you messages. As a result of such processing, you get access, for example, to timely information, exclusive emails and content and supportive resources.

    3. To manage your account and provide you with customer support
      We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

    4. To communicate with you regarding your use of our Service
      We communicate with you, for example, through group Slack messages to invite you to events, inform you of guidance that Inclusive Startups shares, or to help connect you with resources like funders. These may include Slack notifications, reminders, and messages in groups. As a result, you may, for example, receive a push notification regularly at a particular time with a daily feed summary. To opt out of receiving notifications, you need to update your notification preferences in Slack. 

    5. To research and analyze your use of the Service
      This helps us to better understand your needs, maintain, improve, innovate, plan, design, and develop supportive resources for the community. We also use such data for statistical analysis purposes to test and improve our offers. This enables us to better understand what the community needs, what types of founders use our Service. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that most users want a certain addition to the Service, we may develop and introduce new ways to support founders in the community to address this need.

    6. To send you marketing communications
      Depending on your answers to the Typeform, we may process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our offerings, such as for example, special invitations and supportive resources. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails.
      We may also share special content like invitations to a funder panel or special news for the community in our Service. We may also send you notifications for marketing purposes, which are configured by you in your Slack preferences. To opt out of receiving push notifications, you need to change your settings in Slack.

    7. To personalize our ads
      We and our partners, including Facebook and Google, use your personal data to tailor ads, exclude you, and possibly even show an ad to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.
      How to opt out or influence personalized advertising:
      On any device: delete all cookies from your browser and install https://www.ghostery.com/ghostery-browser-extension/
      iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
      Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
      To learn even more about how to affect advertising choices on various devices, please look at the information available here.
      In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
      • Network Advertising Initiative – http://optout.networkadvertising.org/
      • Digital Advertising Alliance – http://optout.aboutads.info/
      • Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
      • Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
      • DAA AppChoices page – http://www.aboutads.info/appchoices

    8. Your Representations and Warranties 
      You represent and warrant that: (i) your participation in the Inclusive Startups Community will not conflict with any of your existing agreements or arrangements, (ii) you have sufficient rights to share all Your Content with us for our use and with other users of the Inclusive Startups Community, and that you are not violating any confidentiality obligations by submitting Your content to the Inclusive Startups Community, and (iii) that Your content does not violate or constitute the infringement of any intellectual property right, right of privacy, right of publicity or other proprietary right.

    9. Indemnification 
      You will indemnify, defend and hold us harmless, at your expense, against any third-party claim, suit, action, or proceeding (each, an "Action") brought against us (and our officers, directors, employees, agents, service providers, licensors, and affiliates) by a third party to the extent that such Action is based upon or arises out of (a) your use of the Inclusive Startups Community, (b) your disclosure or solicitation of personal information, (c) any use of personal information that you disclosed, whether this use is by you or a third party, (d) your noncompliance with or breach of this Agreement, or (e) your use of Third-Party Products or Third-Party Sites. We will: notify you in writing within thirty (30) days of our becoming aware of any such claim; give you sole control of the defense or settlement of such a claim; and provide you (at your expense) with any and all information and assistance reasonably requested by you to handle the defense or settlement of the claim. You shall not accept any settlement that (i) imposes an obligation on us; (ii) requires us to make an admission; or (iii) imposes liability not covered by these indemnifications or places restrictions on us without our prior written consent.

    10. Disclaimers; Limitations of Liability
      a. Disclaimer of Warranties. WE AND OUR AFFILIATES AND AGENTS MAKE NO REPRESENTATIONS OR WARRANTIES ABOUT THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, SECURITY OR ACCURACY OF THE INCLUSIVE STARTUPS PRODUCTS OR SERVICES, THE INCLUSIVE STARTUPS COMMUNITY, OR THE COMMUNITY CONTENT FOR ANY PURPOSE. TO THE EXTENT PERMITTED BY LAW, THE INCLUSIVE STARTUPS COMMUNITY IS PROVIDED "AS IS" WITHOUT WARRANTY OR CONDITION OF ANY KIND. WE DISCLAIM ALL WARRANTIES AND CONDITIONS OF ANY KIND WITH REGARD TO THE INCLUSIVE STARTUPS COMMUNITY AND THE COMMUNITY CONTENT, INCLUDING ALL IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. THE INCLUSIVE STARTUPS COMMUNITY AND COMMUNITY CONTENT MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS.
      b. No Indirect Damages. TO THE EXTENT PERMITTED BY LAW, IN NO EVENT SHALL WE BE LIABLE FOR ANY INDIRECT, PUNITIVE, OR CONSEQUENTIAL DAMAGES, INCLUDING LOST PROFITS OR BUSINESS OPPORTUNITIES.
      c. Limitation of Liability. IF, NOTWITHSTANDING THE OTHER TERMS OF THIS AGREEMENT, WE ARE DETERMINED TO HAVE ANY LIABILITY TO YOU OR ANY THIRD PARTY, THE PARTIES AGREE THAT OUR AGGREGATE LIABILITY WILL BE LIMITED TO FIVE HUNDRED DOLLARS.
      d.  Third Party Products and Sites.  WE DISCLAIM ALL LIABILITY WITH RESPECT TO THIRD-PARTY PRODUCTS AND THIRD-PARTY SITES THAT YOU USE. OUR LICENSORS SHALL HAVE NO LIABILITY OF ANY KIND UNDER THIS AGREEMENT.
      YOU UNDERSTAND AND AGREE THAT ABSENT YOUR AGREEMENT TO THIS LIMITATION OF LIABILITY, WE WOULD NOT PROVIDE THE INCLUSIVE STARTUPS COMMUNITY TO YOU.
      General
      a. Amendment; No Waiver. We may update and change any part or all of this Agreement. If we update or change this Agreement, the updated Agreement will be posted at inclusivestartups.com/terms. The updated Agreement will become effective and binding on the next business day after it is posted. When we change this Agreement, the "Last Modified" date above will be updated to reflect the date of the most recent version. We encourage you to review this Agreement periodically. If you do not agree with a modification to this Agreement, you should not use the Inclusive Startups Community.
      b. Applicable Law. This Agreement shall be governed by the laws of the State of California, without regard to the conflict of laws provisions thereof. In the event either of us initiates an action in connection with this Agreement or any other dispute between the parties, the exclusive venue and jurisdiction of such action shall be in the state and federal courts in Alameda, California.
      c. Force Majeure. Neither party will be responsible for failure or delay of performance if caused by: an act of war, hostility, or sabotage; act of God; electrical, internet, or telecommunication outage that is not caused by the obligated party; government restrictions; or other event outside the reasonable control of the obligated party. Each party will use reasonable efforts to mitigate the effect of a force majeure event.
      d. Relationship of the Parties. Both you and we agree that no joint venture, partnership, employment, or agency relationship exists between you and us as a result of this Agreement.
      e. Compliance with Applicable Laws. You shall comply with all applicable foreign and domestic laws (including without limitation, export laws), governmental regulations, ordinances, and judicial administrative orders. Export laws and regulations of the United States and any other relevant local export laws and regulations may apply to the Community Content and the Inclusive Startups products and services. You will comply with the sanctions programs administered by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury. You will not directly or indirectly export, re-export, or transfer the Community Content or the Inclusive Startups products and services to prohibited countries or individuals or permit use of the Community content or the Inclusive Startups products and services by prohibited countries or individuals.
      f.  Correction of Errors and Inaccuracies. The Community content may contain typographical errors or other errors or inaccuracies and may not be complete or current. We therefore reserve the right to correct any errors, inaccuracies or omissions and to change or update the Community content and Your content at any time without prior notice. However, we do not guarantee that any errors, inaccuracies or omissions will be corrected.
      g. Severability. If any part of this Agreement is determined to be invalid or unenforceable by applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of this Agreement will continue in effect.
      h. Notices. Notice will be sent to the contact address set forth herein (as such may be changed by notice given to the other party), and will be deemed delivered as of the date of actual receipt.

    11. To enforce our Terms and Conditions of Use and to prevent and combat fraud
      We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

    12. To comply with legal obligations
      We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
       

  3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
    In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.
    We process your personal data under the following legal bases:

    1. to perform our contract with you;
      Under this legal basis we:
      • Provide our Service (in accordance with our Terms and Conditions of Use)
      • Customize your experience
      • Manage your account and provide you with customer support

    2. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
      We rely on legitimate interests:
      • to communicate with you regarding your use of our Service
      This includes, for example, sending you messages about events. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you of peer-based community, resources, mentorship, and support.
      • to research and analyze your use of the Service
      Our legitimate interest for this purpose is our interest in improving our Service so that we understand your preferences and those of the community and are able to provide you with a better experience (for example, to make the use of the Service easier and more supportive, or to introduce and test new features).
      • to send you marketing communications
      The legitimate interest we rely on for this processing is our interest to promote our Service to help you grow your community of founders.
      • to personalize our ads
      The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
      • to enforce our Terms and Conditions of Use and to prevent and combat fraud
      Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.

    3. your consent
      For EEA-based users who tell us they do not consent emails, we ensure your data is only shared with our Service and necessary processors set up your community membership, but not processed for email marketing purposes.

    4. to comply with legal obligations.

  4. WITH WHOM WE SHARE YOUR PERSONAL DATA
    We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

    1. Service providers
      We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
      • cloud storage providers
      • data analytics providers
      • measurement partners
      • marketing partners (in particular, social media networks, website platforms, and email delivery services)

    2. Law enforcement agencies and other public authorities
      We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

    3. Third parties as part of a merger or acquisition
      As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

  5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
    To be in control of your personal data, you have the following rights:
    Accessing / reviewing / updating / correcting your personal data. If you would like to review, edit, or change the personal data that you had previously provided to us or request a copy of the personal data collected from you during your use of the Service, please contact community@inclusivestartups.com.
    Deleting your personal data. You can request erasure of your personal data by sending us an email at community@inclusivestartups.com.
    When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.
    Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by requesting its erasure as described above or sending a request at community@inclusivestartups.com.
    Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
    The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
    The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above (or send respective request to community@inclusivestartups.com). The data will be made available to you in the .txt or .json file format.

  6. AGE LIMITATION
    We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at community@inclusivestartups.com.

  7. INTERNATIONAL DATA TRANSFERS
    Inclusive Startups LLC does business globally. We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
    In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

  8. CHANGES TO THIS PRIVACY POLICY
    We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

  9. CALIFORNIA PRIVACY RIGHTS
    California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
    To obtain this information from us, please send an email message to community@inclusivestartups.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
    Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

  10. DATA RETENTION
    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with our Service. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
    Except as otherwise stipulated in this Privacy Policy, this Service does not support “Do Not Track” requests. To determine whether any of the third-party services the Service uses honor the “Do Not Track” requests, please read their privacy policies.


CONTACT US
You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at community@inclusivestartups.com.