CONDUCTO, INC.

PRIVACY POLICY

Last Updated: October 13, 2020

This “Privacy Policy” describes the privacy practices of Conducto, Inc. (collectively, “Conducto”, “we”, “us”, or “our”) in connection with the www.conducto.com website, the Conducto Platform (the “Platform”), and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information. Conducto may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

This Privacy Policy applies to the personal information we process as a data controller, that is, as the party that determines what personal information to collect and for what purposes. You provide some of this information directly, and we get some of it by collecting information about your interactions, use, and experiences with the Service as further explained in this Privacy Policy.

If you use the Service through an enterprise customer of Conducto, such as your employer, the processing of your personal information is determined by that customer. This Privacy Policy does not apply to the processing of personal information that we handle on behalf of our enterprise customers. If you use the Service through a Conducto enterprise customer and you have questions about how and why your personal data is collected, the legal basis for processing, or requests regarding your personal data, please refer to such customer’s privacy policy and direct your inquiries to such customer or its administrator.

Personal Information We Collect

We collect personal information from users and authorized account administrators for a variety of reasons, and not all of the below categories of information or sources of information will be relevant to all users. Rather, the scope and sources of information are dependent upon your engagement and relationship with Conducto.

Information you provide to us. Personal information you provide to us through the Service may include:

  • Business and personal contact information, such as your first and last name, email address, and company name.

  • Content you choose to upload to the Service, such as text, images, audio, video, and code, along with the metadata associated with the files you upload.

  • Profile information, such as your username and password that you may set to establish an online account.

  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

  • Transaction information, such as information about payments to and from our customers, and other details regarding the services a customer has purchased through the Service.

  • Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the Service or otherwise submit to us, and information you provide when you use any interactive features of the Service.

  • Marketing information, such as your preferences for receiving communications about our Service and future offerings, and details about how you engage with our communications.

  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for the Service on social media platforms, such as Facebook, Twitter, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Slack username, or user ID. You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section.

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.

Referrals

Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or as described at the time of collection:

To operate the Service. We use your personal information to:

  • Provide operate and improve the Service;

  • provide information about our products and services;

  • establish and maintain your user profile on the Service;

  • facilitate your login to the Service via third-party identity and access management providers;

  • enable security features of the Service, such as by sending you security codes via email, and remembering devices from which you have previously logged in;

  • facilitate social features of the Service, such as by connecting you with other users within your organization;

  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;

  • understand your needs and interests, and personalize your experience with the Service and our communications;

  • provide support and maintenance for the Service; and

  • respond to your requests, questions and feedback.

For research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying your use of the Service.

To send you marketing and promotional communications. We may send you Conducto-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing communications section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services).

Affiliated Customers. We may share your personal information, including any content you upload or provide to the Service, with our customers with whom you are affiliated. Your employer may be one of our customers. We do not control how the affiliated customer uses your personal information. Please review your employer’s privacy policy to learn more about how it handles your personal information.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging into the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we may display your name, or username with the content you submit. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of SMS Communications. If you provide your phone number through the Service, we may send you notifications by SMS, such as to provide you with password recovery services or two-factor authentication. You may opt out of SMS communications by contacting us at privacy@conducto.com.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@conducto.com. You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the websites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Privacy settings. We may make available certain privacy settings on the Service. Your Platform settings may provide the ability for you to make certain content private, and other content accessible to other Platform users.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

Other Sites, Mobile Applications and Services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@conducto.com. You may also write to us via postal mail at:

Conducto, Inc.
Attn: Legal – Privacy
15 E 26th St
3rd Floor
New York, New York 10022

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