Effective Date: July 13, 2021
1. COLLECTION OF PERSONAL INFORMATION
1.1 Personal Information You Provide. We may collect the following personal information that you provide through our Services or otherwise:
- Contact information, such as name, email address, mailing address, phone number, title, company name, and location.
- Professional information, such as your area of expertise or business interests.
- Account information, such as the username and password you create when registering for an account and other registration data.
- Preferences, such as your marketing or communication preferences.
- Communications, including information associated with your inquiries to us and any feedback you provide when you communicate with us or on the Services.
1.2 Personal Information Collected Automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device and your activity over time on our Service and other sites and online services, such as:
- Online activity information, such as the website you visited before browsing to the Site or Platform, 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 duration of access.
- Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state or geographic area.
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
For example, we use Google Analytics to help us understand user activity and patterns on the Services. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here.
1.4 Personal Information Received from Business Partners. We may also receive personal information about you from our business partners, including:
- Members. We may receive personal information about you from our accelerators, studios, corporate partners, and other clients. For example, your employer might provide us with your contact information for inclusion in our mentor database.
- Third Party Sources. We may receive personal information about you from other sources and services, such as companies that help provide our Services, data providers, joint marketing partners, and publicly-available sources, such as social media platforms. If you connect to the Services using a third party platform, such as Google, the third party platform may also provide us with your personal information. We may combine the personal information we receive from third party sources with information we have already collected about you.
1.5 Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
1.6 Sensitive Personal Information. Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
2. USE OF PERSONAL INFORMATION
2.1 To Provide the Services. We may use your personal information to:
- provide and operate the Services and our business;
- monitor and improve your experience on the Services;
- create and maintain your account;
- review your requests and facilitate connections between customers, mentors, and partners;
- maintain our database of connections;
- communicate with you about the Services and other related communications;
- respond to your inquiries or support tickets;
- provide products and services you request;
- process your payments and orders; and
- enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.
2.2 Research and Development. We may use your information for research and development purposes, including to improve the Services, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
2.3 Direct Marketing. We may send you GAN-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
2.5 To Comply with Laws and Regulations. We will 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.
2.6 For Compliance, Fraud Prevention, and Safety. We may use your personal data and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
2.7 With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
3. SHARING OF PERSONAL INFORMATION
3.1 Related Companies. We may share information collected about you with any member of our group of companies, including subsidiaries, our ultimate holding company and its subsidiaries. For example, we will share your personal information with our related companies to provide our products and services to you, where other companies within our group perform components of the full service offering.
3.2 Network Members, Investors, and Partners. We may share personal information about you with our accelerators, studios, corporate partners, and other clients as part of the Services. For example, we will share contact information among members to facilitate connections within our network or with our corporate partners when users select any perks they offer via the Services.
3.3 Mentors. We may share personal information with our mentors as part of the Services, including for communications, advice, and other purposes.
3.4 Service Providers. We share personal information with third parties and individuals who perform functions on our behalf and help us run our business. For example, service providers help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, marketing, and other purposes.
3.5 Advertising Partners. We may also share personal information collected about you with third parties who we partner with for advertising campaigns, contests, special offers or other events or activities in connection with our Services, or that collect information about your activity on the Services and other online services to help us advertise our products and service, and/or use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms.
3.6 Business Transferees and Investors. We may disclose personal information collected about you with third parties in connection with any business transaction (or potential transaction) involving a merger, sale of company shares or assets, financing, acquisition, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
3.7 Authorities, Law Enforcement, and Others. We may also disclose information collected about you to law enforcement, government authorities, and private parties, if disclosure is necessary to comply with any applicable law or regulation, in response to a subpoena, court order, governmental inquiry, or other legal process, or as we believe necessary for the compliance and protection purposes described in section titled “Use of Personal Information” above.
3.8 Professional Advisors. We may share your personal information with our professional advisors, such as lawyers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
4. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
GAN is headquartered in the United States and has service providers in other countries, and your personal information may be collected, used, and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.
6. OTHER WEBSITES AND SERVICES
The Services may contain links to other websites and 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 online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites 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 and online services you use.
7. YOUR CHOICES
In this section, we describe the rights and choices available to all users.
7.1 Accessing and Correcting Your Personal Information. You may access or make changes to certain personal information by logging into your account and updating or correcting your profile and registration information. You may also request to change your personal information by contacting us as described below.
7.2 Promotional Emails. 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 as described below. You may continue to receive service-related and other non-marketing emails.
7.3 Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site and Platform may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
We use Google Analytics cookies to help us analyze how the Services are being accessed and used and to get insights regarding users and Services performance. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing a browser plugin available here.
7.4 Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the European Interactive Digital Advertising Alliance (for European users – http://www.youronlinechoices.eu/), and the Digital Advertising Alliance (optout.aboutads.info). The opt-out preferences described here must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
7.5 Do Not Track. Some 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.
7.6 Declining to Provide Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
8. NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code sections 1798.83-1798.84, California’s “Shine the Light” law, California residents who have an established business relationship with GAN are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed below. Please be sure to include “Shine the Light” in the subject line of your request.
9. NOTICE TO EUROPEAN USERS
The information provided in this section applies only to individuals in the European Union, the European Economic Area and the United Kingdom (collectively, “Europe”).
|Processing Purpose (please refer to the corresponding descriptions in the section titled “Use of Personal Information” above for more information)||Legal Basis
|To Provide the Services||Processing is necessary to perform the contract governing our operation of the Site or Platform or the provision of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.|
|Research and Development
For Compliance, Fraud Prevention, and Safety
|Processing is based on your consent where that consent is required by applicable law.
Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and showing you tailored relevant content.
|To Comply with Laws and Regulations||Processing is necessary to comply with our legal obligations.|
|With Your Consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.|
Retention. We will retain your personal data for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at firstname.lastname@example.org or at the mailing address listed below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at email@example.com for further information about any such transfers or the specific safeguards applied.
10. CONTACTING US
Global Accelerator Network, LLC
1031 33rd Street
Denver, CO 80205 United States