Last Revised: June 24, 2021
Union Global, Inc. PBC (“Union”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use and share data, and what choices you have with respect to your data. We have updated this version of our Privacy Policy to reflect changes in data protection law.
Union reserves the right to make updates too and change the content of our Privacy Policy. We encourage you to review it frequently. If we make any material changes to the Privacy Policy, we will post a notice on our website prior to such change taking effect, so we encourage you to review it frequently. If we make any material changes to the Privacy Policy, we will post a notice on our website prior to such change taking effect.
This Privacy Policy applies to all websites owned and operated by Union, including www.union.vc, www.pitch.vc, our applications and/or APIs, and online services (our “Platforms”), as well as our other services, offerings, and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with us (together with our Platforms, collectively referred to as our “Services”). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our Platforms (“Third Party Services”), or any other third party products, services or businesses.
We collect personal information about you in the following ways:
Information that you may provide through the Services or otherwise communicate with us includes:
Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
We may combine other publicly available information, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, with the personal information that you provide to us through our Services.
We also may obtain information from those in the network, as well as your community networks that use our Platforms, such as mentors, investors, partners, community managers and other local representatives, in order to deliver Services. This may include information about potential interest in our programs, company and individual progress, interest in local events, and attendance at other similar events.
We may automatically log information about you and your computer or mobile device when you access our Platforms. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Platforms, the pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Platforms. We collect much of this information about you using cookies. Please refer to the Cookies and Similar Technologies section below for more details.
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at [email protected].
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Platforms.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Platforms; and (2) third party cookies, which are served by service providers on our Platforms, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.
Our Platforms use the following types of cookies for the purposes set out below:
| Type of cookie | Purpose |
|---|---|
| Essential cookies | These cookies are essential to provide you with services available through our Platforms, to enable you to use some of its features and to keep you logged in. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
| Analytics and performance cookies | These cookies are used to collect information about traffic to our Platforms and how users use our Platforms. The information gathered may include the number of visitors to our Platforms, the websites that referred them to our Platforms, the pages they visited on our Platforms, what time of day they visited our Platforms, whether they have visited our Platforms before, and other similar information. We use this information to help operate our Platforms more efficiently, to gather broad demographic information and to monitor the level of activity on our Platforms. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Platforms works. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Platforms by downloading and installing the browser plugin available here. |
| Social media cookies | These cookies are used when you share information using a social media sharing button or “like” button on our Platforms or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. |
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Platforms. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Platforms.
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Platforms to track the actions of users on our Platforms. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Platforms, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users' personal information.
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 these do not track signals. To find out more about “Do Not Track,” please visit allaboutdnt.com.
If you have an account with us or use our Platforms, we use your personal information to:
If you have an account our Platforms, it is because you signed up directly or through an accelerator, incubator, corporate, university innovation program, or other similar community. Your data is shared with the community administrators in the following ways:
If you request information from us, register on our Platforms, or participate in our surveys, promotions or events, we may send you updates, newsletters, surveys, offers, and other promotional materials that may be targeted based on your personal information as permitted by law. We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information or information obtained through our Platforms. You will have the ability to opt out of such communications. If you cannot find the opt out options, please email us at [email protected].
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.
We may use or share your personal information with your consent, such as when you: consent to participate in additional surveys on gender and race/ethnicity (where legally permissible), let us post your testimonials or endorsements on our Platforms, instruct us to take a specific action with respect to your personal information, or opt into third party marketing communications.
We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on industry or demographic trends to measure our objective of having healthy diversity ratios across our Platforms.
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations and we will never sell your data. We disclose personal information to third parties for the following purposes:
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Our Platforms may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
We may make available on our Platforms, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in private or public forums, you may receive unsolicited messages from other parties.
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via email (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Platforms – or a specific announcement on this page or on our blog).
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on our Platforms (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Our Products and Services are not directed to children under the age of 13, and we do not intentionally gather personal information from visitors who are under the age of 13, without their parental or guardian's consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the contact information provided above. We will delete such information from our files as soon as reasonably practicable.
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at [email protected], or write to us at:
Union Global Inc., PBC
700 12th St N.W Suite 700 PMB 95017
Washington, DC 20005
Union is headquartered in the United States and has affiliates and service providers in other countries. Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy.
References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation. We use the following safeguards if Union transfers personal information originating from the European Union to other countries not deemed adequate under applicable data protection law:
Union is the controller of your personal information for purposes of European data protection legislation. See the “Contact Us” section above for contact details.
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below.
| Processing purpose | Legal basis |
|---|---|
| To provide our Services | Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. |
| To communicate with you; To create aggregated or de-identified information; For compliance, fraud prevention and safety | These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). |
| To comply with law | 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 anytime in the manner indicated in the Service or by contacting us at [email protected]. |
We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
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:
You can submit these requests by email to at [email protected] or our postal address provided above. 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 response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
