Effective
date: 03/17/2020
1. Introduction
Welcome to Poseidon Labs, Inc.
Poseidon
Labs, Inc. (“us”, “we”, or “our”) operates https://comradery.io and
Comradery mobile application (hereinafter referred to as “Service”).
Our Privacy
Policy governs your visit to https://comradery.io and Comradery mobile
application, and explains how we collect, safeguard and disclose information
that results from your use of our Service.
We use your
data to provide and improve Service. By using Service, you agree to the
collection and use of information in accordance with this policy. Unless
otherwise defined in this Privacy Policy, the terms used in this Privacy Policy
have the same meanings as in our Terms and Conditions.
Our Terms
and Conditions (“Terms”) govern all
use of our Service and together with the Privacy Policy constitutes your
agreement with us (“agreement”).
2. Definitions
SERVICE means the https://comradery.io
website and Comradery mobile application operated by Poseidon Labs,
Inc.
PERSONAL
DATA means data
about a living individual who can be identified from those data (or from those
and other information either in our possession or likely to come into our
possession).
USAGE
DATA is data
collected automatically either generated by the use of Service or from Service
infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your
device (computer or mobile device).
DATA
CONTROLLER means a natural or legal person who (either alone
or jointly or in common with other persons) determines the purposes for which
and the manner in which any personal data are, or are to be, processed. For the
purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR
SERVICE PROVIDERS) means any natural or legal person who processes the
data on behalf of the Data Controller. We may use the services of various
Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the
subject of Personal Data.
THE USER is the individual using our Service. The
User corresponds to the Data Subject, who is the subject of Personal Data.
3. Information
Collection and Use
We collect
several different types of information for various purposes to provide and
improve our Service to you.
4. Types
of Data Collected
Personal
Data
While using our Service, we may ask you
to provide us with certain personally identifiable information that can be used
to contact or identify you (“Personal
Data”). Personally identifiable information may
include, but is not limited to:
(a)
Email
address
(b)
First
name and last name
(c)
Phone
number
(d)
Address,
State, Province, ZIP/Postal code, City
(e)
Cookies
and Usage Data
We may use your Personal
Data to contact you with newsletters, marketing or promotional materials and
other information that may be of interest to you. You may opt out of receiving
any, or all, of these communications from us by following the unsubscribe
link or by emailing at founders@comradery.io.
Usage
Data
We may also
collect information that your browser sends whenever you visit our Service or
when you access Service by or through a mobile device (“Usage Data”).
This Usage
Data may include information such as your computer's Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that
you visit, the time and date of your visit, the time spent on those pages,
unique device identifiers and other diagnostic data.
When you
access Service with a mobile device, this Usage Data may include information
such as the type of mobile device you use, your mobile device unique ID, the IP
address of your mobile device, your mobile operating system, the type of mobile
Internet browser you use, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about
your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service,
to improve and customize our Service.
You can
enable or disable location services when you use our Service at any time by way
of your device settings.
Tracking Cookies Data
We use
cookies and similar tracking technologies to track the activity on our Service
and we hold certain information.
Cookies are
files with a small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your
device. Other tracking technologies are also used such as beacons, tags and
scripts to collect and track information and to improve and analyze our
Service.
You can
instruct your browser to refuse all cookies or to indicate when a cookie is
being sent. However, if you do not accept cookies, you may not be able to use
some portions of our Service.
Examples of Cookies we use:
(a)
Session Cookies: We use Session Cookies to operate
our Service.
(b)
Preference Cookies: We use Preference Cookies to
remember your preferences and various settings.
(c)
Security Cookies: We use Security Cookies for
security purposes.
(d)
Advertising Cookies: Advertising Cookies are used to
serve you with advertisements that may be relevant to you and your interests.
Other
Data
While using our Service, we may also
collect the following information: sex, age, date of birth, place of birth,
passport details, citizenship, registration at place of residence and actual
address, telephone number (work, mobile), details of documents on education,
qualification, professional training, employment agreements, non-disclosure
agreements, information on bonuses and compensation, information on marital
status, family members, social security (or other taxpayer identification)
number, office location and other data.
5. Use
of Data
Poseidon Labs, Inc. uses the
collected data for various purposes:
(a)
to
provide and maintain our Service;
(b)
to
notify you about changes to our Service;
(c)
to
allow you to participate in interactive features of our Service when you choose
to do so;
(d)
to
provide customer support;
(e)
to
gather analysis or valuable information so that we can improve our Service;
(f)
to
monitor the usage of our Service;
(g)
to
detect, prevent and address technical issues;
(h)
to
fulfill any other purpose for which you provide it;
(i)
to
carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collection;
(j)
to
provide you with notices about your account and/or subscription, including
expiration and renewal notices, email-instructions, etc.;
(k)
to
provide you with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you
have already purchased or enquired about unless you have opted not to receive
such information;
(l)
in
any other way we may describe when you provide the information;
(m) for any other purpose with your consent.
6. Retention
of Data
We will retain your Personal
Data only for as long as is necessary for the purposes set out in this Privacy
Policy. We will retain and use your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and enforce our
legal agreements and policies.
We will also retain Usage
Data for internal analysis purposes. Usage Data is generally retained for a
shorter period, except when this data is used to strengthen the security or to
improve the functionality of our Service, or we are legally obligated to retain
this data for longer time periods.
7. Transfer
of Data
Your
information, including Personal Data, may be transferred to – and maintained on
– computers located outside of your state, province, country or other
governmental jurisdiction where the data protection laws may differ from those
of your jurisdiction.
If you are
located outside United States and choose to provide information to us, please
note that we transfer the data, including Personal Data, to United States and
process it there.
Your
consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.
Poseidon
Labs, Inc. will take all the steps reasonably necessary to ensure that
your data is treated securely and in accordance with this Privacy Policy and no
transfer of your Personal Data will take place to an organisation or a country
unless there are adequate controls in place including the security of your data
and other personal information.
8. Disclosure
of Data
We may disclose personal information
that we collect, or you provide:
(a)
Disclosure for Law Enforcement.
Under
certain circumstances, we may be required to disclose your Personal Data if
required to do so by law or in response to valid requests by public
authorities.
(b)
Business Transaction.
If we or
our subsidiaries are involved in a merger, acquisition or asset sale, your
Personal Data may be transferred.
(c) Other
cases. We may disclose your information also:
(i)
to
our subsidiaries and affiliates;
(ii)
to
contractors, service providers, and other third parties we use to support our
business;
(iii) to fulfill the purpose for which you
provide it;
(iv) for the purpose of including your
company’s logo on our website;
(v)
for
any other purpose disclosed by us when you provide the information;
(vi) with your consent in any other cases;
(vii)if we believe disclosure is necessary or appropriate to
protect the rights, property, or safety of the Company, our customers, or
others.
9. Security
of Data
The security of your data is
important to us but remember that no method of transmission over the Internet
or method of electronic storage is 100% secure. While we strive to use
commercially acceptable means to protect your Personal Data, we cannot
guarantee its absolute security.
10. Your
Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are
a resident of the European Union (EU) and European Economic Area (EEA), you
have certain data protection rights, covered by GDPR. – See more at
https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to
take reasonable steps to allow you to correct, amend, delete, or limit the use
of your Personal Data.
If you wish
to be informed what Personal Data we hold about you and if you want it to be
removed from our systems, please email us at founders@comradery.io.
In certain circumstances, you have the
following data protection rights:
(a)
the
right to access, update or to delete the information we have on you;
(b)
the
right of rectification. You have the right to have your information rectified
if that information is inaccurate or incomplete;
(c)
the
right to object. You have the right to object to our processing of your
Personal Data;
(d)
the
right of restriction. You have the right to request that we restrict the
processing of your personal information;
(e)
the
right to data portability. You have the right to be provided with a copy of
your Personal Data in a structured, machine-readable and commonly used format;
(f)
the
right to withdraw consent. You also have the right to withdraw your
consent at any time where we rely on your consent to process your personal
information;
Please note that we may ask
you to verify your identity before responding to such requests. Please note, we
may not able to provide Service without some necessary data.
You have the right to
complain to a Data Protection Authority about our collection and use of your
Personal Data. For more information, please contact your local data protection
authority in the European Economic Area (EEA).
11. Your
Data Protection Rights under the California Privacy Protection Act (CalOPPA)
CalOPPA is
the first state law in the nation to require commercial websites and online
services to post a privacy policy. The law’s reach stretches well beyond
California to require a person or company in the United States (and conceivable
the world) that operates websites collecting personally identifiable
information from California consumers to post a conspicuous privacy policy on
its website stating exactly the information being collected and those
individuals with whom it is being shared, and to comply with this policy. – See
more at:
https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA we agree to the
following:
(a) users can visit our site anonymously;
(b) our Privacy Policy link includes the
word “Privacy”, and can easily be found on the page specified above on the home
page of our website;
(c) users will be notified of any privacy
policy changes on our Privacy Policy Page;
(d) users are able to change their personal
information by emailing us at founders@comradery.io.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not
track, plant cookies, or use advertising when a Do Not Track browser mechanism
is in place. Do Not Track is a preference you can set in your web browser to
inform websites that you do not want to be tracked.
You can enable or disable Do Not Track
by visiting the Preferences or Settings page of your web browser.
12. Service
Providers
We may
employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on
our behalf, perform Service-related services or assist us in analysing how our
Service is used.
These third parties have
access to your Personal Data only to perform these tasks on our behalf and are
obligated not to disclose or use it for any other purpose.
13. Analytics
We may use third-party Service Providers
to monitor and analyze the use of our Service.
Google Analytics
Google
Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of
our Service. This data is shared with other Google services. Google may use the
collected data to contextualise and personalise the ads of its own advertising
network.
For more
information on the privacy practices of Google, please visit the Google Privacy
Terms web page: https://policies.google.com/privacy?hl=en
We also
encourage you to review the Google's policy for safeguarding your data:
https://support.google.com/analytics/answer/6004245.
Fathom Analytics
Fathom
Analytics is analytics service provided by Conva Ventures Inc. You can find
their Privacy Policy here: https://usefathom.com/privacy/
Mixpanel
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for
analytics purposes by opting-out. To opt-out of Mixpanel service, please visit
this page: https://mixpanel.com/optout/
For more information on what type of information Mixpanel
collects, please visit the Terms of Use page of Mixpanel:
https://mixpanel.com/terms/
14. CI/CD
tools
We
may use third-party Service Providers to automate the development process of
our Service.
GitHub
GitHub is
provided by GitHub, Inc.
GitHub is a
development platform to host and review code, manage projects, and build
software.
For more
information on what data GitHub collects for what purpose and how the
protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.
15. Behavioral
Remarketing
Poseidon
Labs, Inc. uses remarketing services to advertise on third party websites
to you after you visited our Service. We and our third-party vendors use
cookies to inform, optimise and serve ads based on your past visits to our
Service.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by
Google Inc.
You can opt-out of Google Analytics for Display Advertising
and customize the Google Display Network ads by visiting the Google Ads
Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics
Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your
web browser. Google Analytics Opt-out Browser Add-on provides visitors with the
ability to prevent their data from being collected and used by Google
Analytics.
For more information on the privacy practices of Google,
please visit the Google Privacy Terms web page:
https://policies.google.com/privacy?hl=en
Twitter
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by
following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies
of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from
Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these
instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for
Online Behavioural Advertising established by the Digital Advertising Alliance.
You can also opt-out from Facebook and other participating companies through
the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/,
the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/
or the European Interactive Digital Advertising Alliance in Europe
http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook,
please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
16. Payments
We may
provide paid products and/or services within Service. In that case, we use
third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details.
That information is provided directly to our third-party payment processors
whose use of your personal information is governed by their Privacy Policy.
These payment processors adhere to the standards set by PCI-DSS as managed by
the PCI Security Standards Council, which is a joint effort of brands like
Visa, Mastercard, American Express and Discover. PCI-DSS requirements help
ensure the secure handling of payment information.
The payment processors we work with are:
Stripe:
Their
Privacy Policy can be viewed at: https://stripe.com/us/privacy
17. Links
to Other Sites
Our Service
may contain links to other sites that are not operated by us. If you click a
third party link, you will be directed to that third party's site. We strongly
advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for
the content, privacy policies or practices of any third party
sites or services.
18. Children's
Privacy
Our Services are
not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect personally
identifiable information from Children under 13. If you become aware that a
Child has provided us with Personal Data, please contact us. If we become aware
that ce have collected Personal Data from Children without verification of
parental consent, we take steps to remove that information from our servers.
19. Changes
to This Privacy Policy
We may
update our Privacy Policy from time to time. We will notify you of any changes
by posting the new Privacy Policy on this page.
We will let you know via
email and/or a prominent notice on our Service, prior to the change becoming
effective and update “effective date” at the top of this Privacy Policy.
You are advised to review
this Privacy Policy periodically for any changes. Changes to this Privacy
Policy are effective when they are posted on this page.
20. Contact
Us
If you have any questions about this
Privacy Policy, please contact us:
By email:
founders@comradery.io.