This Privacy Policy addresses how we handle Personal Data that we collect in relation to our LINK VENTURES website (the “Site,” at https://www.linkventures.com) and related services – such as when you choose to receive emails or texts from us – or when you interact with us as a representative of a portfolio company, a vendor, or a business partner (together with our Site, the “Services”). By using or accessing our Services in any manner, you will be accepting the practices and policies outlined below, and you hereby consent to the collection, use, and sharing of your information as described in this Privacy Policy.
Please note that your use of the Services is at all times subject to our Terms of Use, into which this Privacy Policy should be deemed incorporated. Any terms used but not defined in this Privacy Policy shall have the meanings given to them in the Terms of Use.
You may generate a hard copy of this Privacy Policy by using the “Print” function on your web browser. If you do not have access to a printer, or if you have a disability or other limitation that prevents you from fully reviewing this version of the Privacy Policy, you may contact us at privacy@linkventures.com to request it in an alternative format.
Privacy Policy Coverage
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual. It also includes what is referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of entities Link does not own or control or people Link does not manage. In addition, this Privacy Policy does not apply to information we collect about job candidates or employees.
Categories of Personal Data Collected
The categories of Personal Data we may collect include the following:
Device/Internet Protocol (“IP”) Data
Usage Analytics (such as interactions with our Site and other Services)
Demographic Data
Geolocation Data (such as IP address-based location information)
Other Voluntarily Shared Identifying Information (in emails you send us or otherwise)
Personal Data Sources
The Personal Data we may collect could come from any of the following sources:
You
— When you share such information directly with us; and/or
— When Personal Data is automatically collected in connection with your use of the Services (see “Automatic Information Collection” below).
Third Parties
— Vendors (e.g., third parties we engage to analyze how you interact with the Services, or to provide customer support); and/or
— Advertising Partners (i.e., third parties who assist us with marketing or promotional services related to your interactions with our Services).
Automatic Information Collection
Small pieces of data – usually text files – are placed on your computer, smartphone or similar device when you access our Services on it. We use those and similar technologies (together, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you used our Services. Such information allows us to analyze trends, learn about our user base, and operate and improve our Services. It may also be supplemented with information we receive from third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services may not support “Do Not Track” requests sent from a browser.
We use the following types of Cookies:
Essential Cookies, which are required in order to provide you with requested features or services. For example, certain Cookies enable you to log into secure areas of our Services.
Functional Cookies, which are used to record your choices and settings (e.g., language or region), to maintain your preferences over time, and to recognize you when you return to our Services.
Performance/Analytics Cookies, which allow us to understand how visitors use our Services, and to help us measure the performance of our advertising campaigns. The Services may contain not only our own Performance/Analytics Cookies, but also some from third-party analytics services.
You can generally decide whether or not to allow Cookies through your web browser’s settings. Most browsers have an option to turn off Cookies, which would prevent any new ones from being accepted. Some browser software also allows you to make individualized decisions regarding the acceptance of Cookies. In addition, you can delete all Cookies that are already on your device. If you take that step, you may have to manually adjust certain preferences every time you visit the Site, and some of the Services may not work well.
To learn more about Cookies, including ways to manage and delete them, you can visit sites such as http://www.allaboutcookies.org/.
How Your Personal Data Is Used
We process Personal Data to operate, improve, and personalize our Services. We may also collect and use it in order to:
Accomplish the purpose(s) for which you provided the information to us;
Communicate with you about the Services (including updates or offers);
Provide support and assistance in connection with the Services;
Create and manage your account or user profile;
Personalize Site content and communications based on your preferences;
Deliver our email or text newsletters or feeds;
Facilitate events;
Protect our proprietary information and intellectual property;
Respond to and fulfill user requests;
Improve and develop the Services;
Guard against or deter fraudulent, illegal or harmful actions;
Maintain the safety, security and integrity of our Services;
Comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use;
Respond to law enforcement requests, as required by applicable law, court order, or governmental regulations; and/or
For any other business purpose(s) expressed when collecting your Personal Data, or as otherwise set forth in applicable data privacy laws.
Without first providing notice, we will not collect additional categories of Personal Data or use the Personal Data we have collected for materially different, unrelated, or incompatible purposes. We use sensitive Personal Data – if at all – only as permitted by applicable laws, or otherwise with your consent.
As noted in the list above, we may communicate with you if you provide us with the means to do so. For example, if you have given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive such communications from us, please indicate your preference by emailing us at privacy@linkventures.com.
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business. However, we will not share such data in a manner that could identify you. Nor will we attempt to reidentify any de-identified data, other than for the purposes of determining whether our de-identification processes satisfy the requirements of applicable law.
With Whom Your Personal Data Is Shared
We may share your Personal Data with certain parties as follows:
Approved Service Providers
— Categories of Personal Data Shared: All categories of Personal Data.
— Purposes for Sharing: Our approved service providers help us provide the Services and operate our business. They could include ad networks, analytics providers, security and fraud prevention providers, hosting and other technology and communications providers, and staff augmentation and contract personnel. We also use third-party service providers to help us manage and operate our email and text services (e.g., for news feeds and event registration). When we share your Personal Data with such service providers, they may use it only for the specific purposes related to assisting us with running our business.
Successors to Our Business
— Categories of Personal Data Shared: All categories of Personal Data.
— Purposes for Sharing: If we undergo a merger, acquisition, bankruptcy, or other transaction in which a third party assumes control of our business (in whole or in part), the Personal Data we have collected from you may be transferred to that third party.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using physical, technical, organizational, and administrative security measures appropriate to the type of Personal Data and how we are processing it (e.g., industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data). You should help protect your own data by carefully selecting and protecting your login information, limiting access to your computer or device and browser, and logging out after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no methods of storing data or transmitting it over the internet are completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as is reasonably necessary for the business purposes specified in this Privacy Policy, based on considerations such as whether retention is necessary to maintain our relationship or provide the Services, comply with our legal obligations, resolve disputes or collect fees owed, enforce our contractual agreements, or protect our rights, property or business (all if and as otherwise permitted or required by applicable law, rule or regulation). We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Children’s Personal Data
We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at privacy@linkventures.com.
California Resident Rights
If you are a California resident, you may have certain rights as described in this section. However, such rights are not absolute, and in certain cases we may decline a request from you as permitted by law. (Please see “Exercising Your Rights” below.) Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@linkventures.com.
Access
You have the right to request certain information about our collection, use and disclosure of your Personal Data. In response to such a valid request, we will provide you with the following information:
The categories of Personal Data that we have collected and disclosed about you;
The categories of sources from which that Personal Data was collected;
The business or commercial purpose(s) for collecting your Personal Data;
The categories of third parties with whom we have shared your Personal Data; and
The specific pieces of Personal Data that we have collected about you.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you.
Correction
You have the right to request that we correct any inaccurate Personal Data that we maintain about you.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or an agent authorized by that person, including without limitation your name and email address, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.
We will work to respond to your Valid Request within forty-five (45) days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request is manifestly unfounded or excessive. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by emailing us at privacy@linkventures.com, or by sending us a hard copy, via U.S. certified mail, return receipt requested, to Link Ventures, One Kendall Square, Suite B2201, Cambridge, Massachusetts 02139.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of that written permission if and when the Authorized Agent makes a request on your behalf.
We will not discriminate against you for exercising your rights under the California Consumer Privacy Act and the regulations promulgated thereunder.
Updates to this Privacy Policy
As we strive to improve our Services over time, we may need to update this Privacy Policy. We will alert you to any such updates by publishing the latest version on the Site, by sending you an email, and/or by some other means. Please note that if you have opted not to receive legal notice emails from us (or you have not provided us with an email address to which such notices can be sent),our legal notices will still govern your use of the Services, and you will remain responsible for reading and understanding them. If you use the Services after any updates to the Privacy Policy have been published, you will be agreeing to the entire Policy as modified. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please feel free to contact us at privacy@linkventures.com.
Introduction
This Privacy Policy addresses how we handle Personal Data that we collect in relation to our LINK VENTURES website (the “Site,” at https://www.linkventures.com) and related services – such as when you choose to receive emails or texts from us – or when you interact with us as a representative of a portfolio company, a vendor, or a business partner (together with our Site, the “Services”). By using or accessing our Services in any manner, you will be accepting the practices and policies outlined below, and you hereby consent to the collection, use, and sharing of your information as described in this Privacy Policy.
Please note that your use of the Services is at all times subject to our Terms of Use, into which this Privacy Policy should be deemed incorporated. Any terms used but not defined in this Privacy Policy shall have the meanings given to them in the Terms of Use.
You may generate a hard copy of this Privacy Policy by using the “Print” function on your web browser. If you do not have access to a printer, or if you have a disability or other limitation that prevents you from fully reviewing this version of the Privacy Policy, you may contact us at privacy@linkventures.com to request it in an alternative format.
Privacy Policy Coverage
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual. It also includes what is referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of entities Link does not own or control or people Link does not manage. In addition, this Privacy Policy does not apply to information we collect about job candidates or employees.
Categories of Personal Data Collected
The categories of Personal Data we may collect include the following:
Device/Internet Protocol (“IP”) Data
Usage Analytics (such as interactions with our Site and other Services)
Demographic Data
Geolocation Data (such as IP address-based location information)
Other Voluntarily Shared Identifying Information (in emails you send us or otherwise)
Personal Data Sources
The Personal Data we may collect could come from any of the following sources:
You
— When you share such information directly with us; and/or
— When Personal Data is automatically collected in connection with your use of the Services (see “Automatic Information Collection” below).
Third Parties
— Vendors (e.g., third parties we engage to analyze how you interact with the Services, or to provide customer support); and/or
— Advertising Partners (i.e., third parties who assist us with marketing or promotional services related to your interactions with our Services).
Automatic Information Collection
Small pieces of data – usually text files – are placed on your computer, smartphone or similar device when you access our Services on it. We use those and similar technologies (together, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you used our Services. Such information allows us to analyze trends, learn about our user base, and operate and improve our Services. It may also be supplemented with information we receive from third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services may not support “Do Not Track” requests sent from a browser.
We use the following types of Cookies:
Essential Cookies, which are required in order to provide you with requested features or services. For example, certain Cookies enable you to log into secure areas of our Services.
Functional Cookies, which are used to record your choices and settings (e.g., language or region), to maintain your preferences over time, and to recognize you when you return to our Services.
Performance/Analytics Cookies, which allow us to understand how visitors use our Services, and to help us measure the performance of our advertising campaigns. The Services may contain not only our own Performance/Analytics Cookies, but also some from third-party analytics services.
You can generally decide whether or not to allow Cookies through your web browser’s settings. Most browsers have an option to turn off Cookies, which would prevent any new ones from being accepted. Some browser software also allows you to make individualized decisions regarding the acceptance of Cookies. In addition, you can delete all Cookies that are already on your device. If you take that step, you may have to manually adjust certain preferences every time you visit the Site, and some of the Services may not work well.
To learn more about Cookies, including ways to manage and delete them, you can visit sites such as http://www.allaboutcookies.org/.
How Your Personal Data Is Used
We process Personal Data to operate, improve, and personalize our Services. We may also collect and use it in order to:
Accomplish the purpose(s) for which you provided the information to us;
Communicate with you about the Services (including updates or offers);
Provide support and assistance in connection with the Services;
Create and manage your account or user profile;
Personalize Site content and communications based on your preferences;
Deliver our email or text newsletters or feeds;
Facilitate events;
Protect our proprietary information and intellectual property;
Respond to and fulfill user requests;
Improve and develop the Services;
Guard against or deter fraudulent, illegal or harmful actions;
Maintain the safety, security and integrity of our Services;
Comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use;
Respond to law enforcement requests, as required by applicable law, court order, or governmental regulations; and/or
For any other business purpose(s) expressed when collecting your Personal Data, or as otherwise set forth in applicable data privacy laws.
Without first providing notice, we will not collect additional categories of Personal Data or use the Personal Data we have collected for materially different, unrelated, or incompatible purposes. We use sensitive Personal Data – if at all – only as permitted by applicable laws, or otherwise with your consent.
As noted in the list above, we may communicate with you if you provide us with the means to do so. For example, if you have given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive such communications from us, please indicate your preference by emailing us at privacy@linkventures.com.
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business. However, we will not share such data in a manner that could identify you. Nor will we attempt to reidentify any de-identified data, other than for the purposes of determining whether our de-identification processes satisfy the requirements of applicable law.
With Whom Your Personal Data Is Shared
We may share your Personal Data with certain parties as follows:
Approved Service Providers
— Categories of Personal Data Shared: All categories of Personal Data.
— Purposes for Sharing: Our approved service providers help us provide the Services and operate our business. They could include ad networks, analytics providers, security and fraud prevention providers, hosting and other technology and communications providers, and staff augmentation and contract personnel. We also use third-party service providers to help us manage and operate our email and text services (e.g., for news feeds and event registration). When we share your Personal Data with such service providers, they may use it only for the specific purposes related to assisting us with running our business.
Successors to Our Business
— Categories of Personal Data Shared: All categories of Personal Data.
— Purposes for Sharing: If we undergo a merger, acquisition, bankruptcy, or other transaction in which a third party assumes control of our business (in whole or in part), the Personal Data we have collected from you may be transferred to that third party.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using physical, technical, organizational, and administrative security measures appropriate to the type of Personal Data and how we are processing it (e.g., industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data). You should help protect your own data by carefully selecting and protecting your login information, limiting access to your computer or device and browser, and logging out after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no methods of storing data or transmitting it over the internet are completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as is reasonably necessary for the business purposes specified in this Privacy Policy, based on considerations such as whether retention is necessary to maintain our relationship or provide the Services, comply with our legal obligations, resolve disputes or collect fees owed, enforce our contractual agreements, or protect our rights, property or business (all if and as otherwise permitted or required by applicable law, rule or regulation). We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Children’s Personal Data
We do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at privacy@linkventures.com.
California Resident Rights
If you are a California resident, you may have certain rights as described in this section. However, such rights are not absolute, and in certain cases we may decline a request from you as permitted by law. (Please see “Exercising Your Rights” below.) Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@linkventures.com.
Access
You have the right to request certain information about our collection, use and disclosure of your Personal Data. In response to such a valid request, we will provide you with the following information:
The categories of Personal Data that we have collected and disclosed about you;
The categories of sources from which that Personal Data was collected;
The business or commercial purpose(s) for collecting your Personal Data;
The categories of third parties with whom we have shared your Personal Data; and
The specific pieces of Personal Data that we have collected about you.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you.
Correction
You have the right to request that we correct any inaccurate Personal Data that we maintain about you.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or an agent authorized by that person, including without limitation your name and email address, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.
We will work to respond to your Valid Request within forty-five (45) days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request is manifestly unfounded or excessive. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by emailing us at privacy@linkventures.com, or by sending us a hard copy, via U.S. certified mail, return receipt requested, to Link Ventures, One Kendall Square, Suite B2201, Cambridge, Massachusetts 02139.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of that written permission if and when the Authorized Agent makes a request on your behalf.
We will not discriminate against you for exercising your rights under the California Consumer Privacy Act and the regulations promulgated thereunder.
Updates to this Privacy Policy
As we strive to improve our Services over time, we may need to update this Privacy Policy. We will alert you to any such updates by publishing the latest version on the Site, by sending you an email, and/or by some other means. Please note that if you have opted not to receive legal notice emails from us (or you have not provided us with an email address to which such notices can be sent),our legal notices will still govern your use of the Services, and you will remain responsible for reading and understanding them. If you use the Services after any updates to the Privacy Policy have been published, you will be agreeing to the entire Policy as modified. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please feel free to contact us at privacy@linkventures.com.