Warmintro (Warmintro Inc.) Privacy Policy.

Last updated: February 19, 2020
We value data privacy a lot and want people to know we implement tag best practice protections to keep your data safe. The Warmintro platform for community management (the “Service(s)”) is provided by Warmintro Inc. All visitors to our Service (“Visitors”) who register with the Service and join a Community are Members or Hosts. Hosts are the organizers of Warmintro. Members register and participate in Warmintro. Hosts decide who can join their Community and whether they choose to run advertising or paid Member subscriptions on their Community. This Privacy Policy describes how we, Warmintro Inc., obtain and use information about you and your visits to our website at warmintro.ai and your participation in a Community and your use of Warmintro mobile applications. To offer the personalized experience of a Community, we collect personal information about you (“Personal Data”). This policy describes how we collect, use, and share your Personal Data with your Host and other Members in connection with your use of the Service, including our mobile applications. Unless defined here, capitalized words have the same meaning as in the Warmintro Terms of Use, which this Privacy Policy is part of. 1. Information we collect and how we use it When you visit our website, join or create a Community, interact with us or your Host through the Service, or use our mobile applications, we, as the service provider for your Host, collect Personal Data and other information from you (collectively, “Data”). We use your Personal Data to be able to provide the Service to you: We collect Personal Data when you share it voluntarily. We collect some Personal Data automatically when you visit our website, use the Service or use our Warmintro mobile applications. We and your Hosts use your Personal Data to provide and improve the Service, understand how you and other Members are using Warmintro and to inform you about products and services that may be of interest to you. Data does not include content you create (“Your Content”) or User Generated Content. As we explain in our Terms of Use, you (and the people you license Your Content from) keep complete ownership of all Your Content. By posting Your Content on the Service, you grant us a license to use it, but you and your licensors still own it. A. Personal Data you provide directly ‘Personal Data or Personal Information’ means any information relating to you from which you can be identified, directly or indirectly, including your name, identification number, location, online identifier such as your IP address or device ID, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. ‘Special Categories of Personal Data’ means data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and data concerning your health, sex life or sexual orientation. ‘Aggregated Data’ is data in a summary form for statistical analysis. A common purpose of aggregation is to get more information about particular groups based on specific variables such as age, profession, or income level. ‘Pseudonymisation’ means the processing of your personal data in a way that the personal data can no longer identify you without the use of additional information, so long as the additional information is kept separately and is subject to technical and organizational measures to prevent you from being identified or identifiable. We store and use your Personal Data when you join a new Community. Name and Email Address. When you register as a Host or Member of a Community, we ask you for your real name and your email address. Both we and the Host of the Community receive access to this information and use it to communicate with you about the Service. In addition, we and your Host may use this address to email you about products or services believed to be of interest to you. If you are a paying Host or Member, we may also collect your mailing address and zip code for billing purposes. Hosts may decide to collect your mailing address, via our Services. Social Media Profiles. You can also register with your LinkedIn or other social media account. When you register this way, you give us permission to access your LinkedIn profile and photo. Your profile and photo will become part of your Community profile and you retain the option to have us update your profile through these services. See below for more information on Integrated Services like Facebook and LinkedIn and Google. Profiles and Topics. When you join a Community, you will be prompted to add a profile, including a short bio, and to choose tags and interests (“Topics”). From this information, Warmintro personalizes your experience in each Community. Your Host can also choose and customize categories of Personal Data to collect from you including, if you agree, Special Categories of Personal Data. Your Location. We may ask you for your location so that we can facilitate interactions with other Members in your geographic area. Other Personal Data You Provide Directly. You may also provide us Personal Data when you use certain features of the Service such as participating in conversations or polls in your Communities, contact us with inquiries, or respond to one of our surveys. B. Personal Data and Information we collect automatically You have the option of registering using an Integrated Service, such as Facebook. If you choose to do this, your profile picture and other Personal Data in your profile on the Integrated Service will become part of your profile on Warmintro. Please see the section below on Integrated Services for more detail. Information About Your Use of the Service. Our servers automatically record your visits to the Service. Like all other website and mobile app servers, ours compiles a log that records the date, time, browser (e.g., Firefox), device type (e.g., iPhone), operating system (e.g., Android), and originating IP address of each page you visit. We use cookies to collect information about your visits to our website and Service. Cookies are text files placed on your computer by websites to collect standard log information and visitor behavior information. Our cookies collect the following information about you: which website or ad you visited right before ours, which pages you visited on our Service, and how much time you spent on each section of our Service. We may also collect other data about your visit, such as search requests and results. We use this information for our legitimate interests to track usage of our Service, to measure the number of unique visitors to the different sections of our Service, to understand how Members find and join Warmintro, and to help us make our Service more valuable to every Host and Member. The use of this information is called “analytics.” Often information used for analytics is aggregated. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Service features may not work properly without cookies. Most browsers accept cookies automatically but allow you to disable them. For more information about cookies visit https://www.allaboutcookies.org. Information About Your Location. From your IP address, we can tell generally where you are when you are accessing our Service, such as which city. We start by choosing a location for you based on the IP address of your Internet connection. You can update or remove this location at any time by logging in to your account on the Service. C. Personal Data and Information Third Parties collect automatically Third-Party Cookies for Site Use Analysis. We use third parties such as Google to help us analyze how people are using our Service. We also use the Google Analytics service to provide us with demographic data about our Hosts and Members, such as age and gender. Google uses a cookie that can be recognized by Google or its affiliate DoubleClick when you visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners website at https://www.google.com/policies/privacy/partners/. Third-Party Cookies Used to Target Ads to You When You Use the Service or are on Other Websites. “Beacons” are transparent pixel images that are used in collecting information about website usage across websites and over time. Our Hosts may use their own or third party cookies or beacons to target Host ads to you when you visit other websites. Our Hosts may also work with other companies who use their cookies or beacons to target third party ads to you on other websites based on your prior visits to the Host’s Community on our website Service. This is called online behavioral advertising (“OBA”), because you receive ads based on your prior online behavior. We do not have access to these cookies; it is third parties who engage in OBA. 2. Our Sharing of your Personal Data and other information We consider personalizing your Warmintro experience an important part of our Service. We want you to understand what Personal Data gets shared with your Hosts, other Members of your Warmintro, other Hosts or Members of our Service, and other third parties as part of the Service. ‘Third Party’ means a person or company who is not a Host or another Community Member, and government bodies and public agencies and authorities. Third Parties include our service providers whom we authorize, through a data processing agreement, to process your personal data or information to help us with: development, maintenance, and support of our websites and mobile applications, marketing and advertising, marketing research and analysis, communications, and customer service. We do not permit our Third Party service providers to use your personal data for any other purpose. We do not share Personal Data with any person or company unless we have an agreement with them that controls their use of the data. WE DO NOT SELL YOUR PERSONAL DATA. ‘Processing’ or ‘Process’ means any operation or set of operations performed on personal data or on sets of personal data, including by automatic methods, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing, transmitting, sharing or otherwise making available, aligning or combining, restricting, erasing or destroying. ‘Consent’ or ‘Agree’ means your freely given, specific, informed and unambiguous expression of your wishes through a statement or other clear affirmative action such as checking a box which indicates your agreement to our processing of personal data relating to you. If you are not comfortable with this type of sharing, don’t use our Service. A. Personal Data shared within the Service Your Host, or Hosts if there are more than one, will have access to your name, email address, and all personal or contact information that you provide when you register for that Host’s Community. In order to facilitate Member engagement, our Host will also have access to Data regarding your usage activity, in both aggregated and personally identifiable forms. For example, Hosts will be able to see aggregated Member activity within a Community, as well as specific information like how many people cheered in response to a comment you made. Your Host also will be able to associate Your Content, and any Personal Information it contains, with your contact information. If you have agreed, your Hosts may communicate with you outside of the Service about the Community or relevant topics of interest to you, and may retain your personal information after you leave the Community. You should only join a Community if you are comfortable sharing your personal information with the Host of that Community. Searching and Messaging by Others. Visitors to our Service may be able to search for you by your name and location if you are a Member of a Community. Members of your Community can search for you by location, Topics, or other personal information so that they may get introduced to you within the Community. Only Hosts and other Members can see Profiles, Your Content, and activity. Any Visitor can find the Community, but cannot enter without an invitation or membership request approval. Personal Information Included in Your Content. If you include personal information in Your Content, it will be displayed to other Members based on the privacy levels defined above. B. Personal Data and Information shared with Third Parties Integrated Services. If you have used the option to register using an Integrated Service, such as LinkedIn, we may share your information with the operators of the Integrated Service. More information is in the sections below entitled “Integrated Services.” Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets. Agents, Consultants and Third Parties Whom We Have Contracts With. Warmintro Inc., like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include emailing information to you, maintaining our website, databases and mobile applications, processing payments, marketing and advertising, marketing research and analysis, and customer service. When we employ another company to perform a function of this type, we only provide them with the Personal Data and Information they need to perform their specific function and we do not authorize these service providers to use or disclose your personal information except as necessary to perform the tasks we have asked them to do for us or to comply with legal requirements. If you would like a list of the Third Parties we use to assist us with our personal data or information needs, please email us at support@warmintro.ai Legal Requirements. We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) cooperate with a legal investigation or a request from a government authority, (iii) protect and defend the rights or property of Warmintro Inc., (iv) protect the legal rights, safety, and security of users of our website and the Service, (v) protect our legal rights and legitimate interests, and those of our business partners, service providers, and customers; (vi) prevent fraud; (vii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (v) protect against legal liability. C. Aggregated data shared We disclose aggregated statistics, such as number of Hosts and Members, in order to describe our Service to current and prospective business partners, and to our Third Party service providers for our legitimate interests and other lawful purposes. 3. Your Personal Data Rights You have rights regarding the Personal Data and Information we have about you. You may object to, or restrict, our collection, use, sharing, transfer and/or storage of your personal information. You may also request a copy of the information that we have about you. You may also ask us to correct or remove personal information you think is incorrect. If a Host (the data controller) is using the Service to process your personal information, you may contact the Host to object, restrict, access, correct or delete your personal information. If you need help finding contact information for your Host’s privacy officer, please contact us using our contact information below. If you have a registered account in the Service, you may object, restrict, access, correct, or request deletion or a copy of some or all of your Personal Data or Information by logging in to your account. If you do not have a registered account in the Service and you would like to object, restrict, access, correct, delete, or request a copy of some or all of your personal information, please email, or write us at the following address: support@warmintro.ai. Warmintro Inc., 2647 Buchanan St Apt 1 San Francisco CA We will respond to your request within a reasonable period of time. Please note, we will keep your personal information for as long as necessary for us to provide the Service to you. We will also keep and use your personal data or information to comply with laws including tax laws and other applicable laws. We will also keep your Personal Data and Information as necessary for backup, archiving, audit, preventing fraud, resolving disputes, and troubleshooting problems. If you are located in the European Union (EU), European Economic Area (EEA) or Switzerland, please see also the EU-US and Swiss-US Privacy Shield section below about how to make complaints regarding personal data collected in the EU and transferred to the U.S. under the Privacy Shield Frameworks. You may also make a privacy or data use complaint about us to the Data Protection Authority in the EU/EEA Member State where you live or work by visiting the Office of the Data Protection Commissioner list of Data Protection Authorities at https://www.dataprotection.ie/docs/European-Functions-Useful-Links/b/99.htm. Our Data Protection Officer is at support@warmintro.ai. 4. Your choices A. Join Warmintro and Hosts you trust You get to decide the Warmintro you want to join. You also get to decide whether you trust your Host with the information sharing described in this policy. B. Public, Private, or Secret Community settings A Host can choose to make a Community Public, Private, or Secret as described above. C. Adjust your notification settings In your account settings, you can control the frequency, type, and mode of notifications you receive through the Service. You can choose to be notified by email or mobile alerts, both, or neither. You can choose to turn on or off your notifications by type, such as cheers on your posts, and questions you can help answer. D. Opt out of email We would like to send you information about our services that you may be interested in. If you have agreed to receive marketing messages from us, you may opt-out at any time. We provide an opt-out link at the bottom of each email message. Because we plan our communications in advance, it may take several weeks for your opt-out request to take effect. If you continue to receive marketing messages from us or a Host after you opt-out, please let us know so that we can investigate the situation. E. Opt out of Google Analytics To prevent your data from being used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout for more instructions. G. Opting out of tracking Please see our Cookie Policy for important information about non-Google cookies that are placed by us or by our business partners on your computer, mobile phone or other device and how to opt out. We do not have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad Communities, or any other non-affiliated third parties. If you would like to learn more about OBA or to opt out of having this information used by companies that are part of the Community Advertising Initiative to deliver targeted ads, please visit https://www.Communityadvertising.org/managing/opt_out.asp, or if you are located in the European Union/European Economic Area, please visit European Interactive Digital Advertising Alliance (EDAA) Your Online Choices website at http://www.youronlinechoices.eu/. Please note you will continue to receive generic ads. H. Deleting cookies To manage or delete browser cookies, please see your browser’s privacy settings. 5. Account termination You can leave one or more of your Warmintro communities, or delete your account. As soon as you leave, we stop collecting your Personal Data for that Community. See this article for more information: https://faq.warmintro.ai/hc/en-us/articles/204991129. 6. Exclusions This Privacy Policy does not apply to any Personal Data collected by Warmintro Inc. outside the Service, such as a telephone call. This Privacy Policy does not apply to any unsolicited information you provide to Warmintro Inc. through the Service or through any other means, such as information posted to any public areas of the Service, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Warmintro Inc. shall be free to reproduce and use such Unsolicited Information without limitation or attribution. We respect your copyrights in Your Content, as outlined in our Terms of Use. If your Host has an additional privacy policy covering the Host’s use of Personal Data, you should review it carefully, because it may be different than this Privacy Policy. 7. Disputes with Hosts or other Members Warmintro cannot control the actions of Hosts or other Members; if you have a privacy-related dispute with a Host or another Member, you should contact that person directly. You should alert us support@warmintro.ai if you believe that a Host or another Member has violated this Privacy Policy or our Acceptable Use Policy. 8. Children Warmintro does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not use the Service or submit any Personal Data through the Service. If you have reason to believe that a child under the age of 13 has provided Personal Data to Warmintro through the Service, please contact us at support@warmintro.ai and we will look to delete that information from our databases. 9. Links to other web applications This Privacy Policy applies only to the Service. The Service may contain links to other websites not operated or controlled by Warmintro Inc. (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Service do not imply that Warmintro Inc. endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices. 10. Integrated services One of the special features of the Service is that it allows you to enable various online Third Party services, such as social media and social communication services like Facebook and LinkedIn and Google (each, an “Integrated Service”), to integrate directly into your Community. By directly integrating these services, we make your use of Warmintro richer and more personalized. To enable Integrated Services, we will ask you to authorize Warmintro to access the Integrated Services (or vice versa). When you add an Integrated Service account to a Community (or vice versa), your log-in information, Personal Data, non-personal data, location information, Your Content, your Community name, your Community location, your Community affiliation, profile photo, Facebook Connect ID, Profile (if you are integrating your Facebook account) and other relevant personal information may be passed through to, or received from, the Integrated Service in connection with your use of the Service. We may import, use, disclose, and retain such data and information to, among other things, customize and improve the Service for you and others. Note that Integrated Services may also import, use, and retain this information. You may be able to control how certain information is shared with us in your privacy settings within the Integrated Services. However, please remember that the manner in which Integrated Services collect, use, store, and disclose your information is governed solely by the policies of the companies operating those Integrated Services, and we shall have no liability or responsibility for the privacy practices or other actions of any Integrated Service that may be enabled within the Service. When you integrate with Google you may opt to give Warmintro the ability and permission to compose and send emails and compose drafts on your behalf. Introductions and other emails you specify will be processed through your gmail account and sent out through your connected email rather than Warmintro. During and after email composition, we may store the content of your draft email message. This is a purely optional service made for your benefit and you can disconnect and turn off this feature at any time. With regards to this service we do not share this data with other users or Third Party Services, unless necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. Warmintro's use of information received from Gmail APIs will adhere to Google's Limited Use Requirements. If, and only if, you have elected to integrate your Warmintro with an Integrated Service, we may share your information with Integrated Services. This may happen when you first register with Warmintro, when you log into Warmintro from time to time, or in emails or other communications we may send you consistent with this Privacy Policy. We may from time to time transfer your Personal Data, anonymous data and your use of certain features on Warmintro to Integrated Services to facilitate and enhance your use of certain features of the Service and of the Integrated Services. However, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. We limit your use of this data to providing or improving user-facing features that are prominent in the requesting application's user interface, and only transfer the data to Integrated Services if necessary to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. We do not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising. Please keep in mind that services provided by Integrated Services are not provided by us and therefore your use of the Integrated Services will be governed by the Integrated Services’ Terms of Use and other policies, and that the collection, use, and disclosure of information provided by you or us to Integrated Services is not governed by this Privacy Policy. 11. Security of Your Personal Data We use appropriate technical and organizational measures including encryption, aggregation, and pseudonymization to protect your Personal Data provided via the Service from loss, misuse, and unauthorized access or use, disclosure, alteration, or destruction. We neither rent nor sell your Personal Information to anyone. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our applicable terms of use and other agreements; or protect the rights, property, or safety of Warmintro, our employees, our users, or others. “Phishing” is a scam designed to steal your Personal Data or Information. If you receive an e-mail that looks like it is from us asking you for information about you, please contact us. 12. Your California data privacy rights California law permits Visitors who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their personal information for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to support@warmintro.ai. EU-US and Swiss-US Privacy Shield Warmintro Inc. strives to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of your Personal Information transferred from the European Union and Switzerland transferred into the United States under the Privacy Shield Frameworks. We adhere to the Privacy Shield Principles of the EU-US and Swiss-US Privacy Shield Frameworks. To learn more, please visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov. As explained above in this Privacy Policy in Section II(b), we sometimes employ other companies and people to perform tasks on our behalf and need to share your information with them, including in some cases the Personal Information you have provided to us, in order to make the Services and certain features of Services available to you. For example, we may use third party hosting providers or software developers to help implement and maintain the Services. However, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us, and use of this integrated service data complies with the terms as stated in Section 10. Our business model does not allow us to share your Personal Information with Third Parties who are not our service providers. If that changes, we will seek your consent to share your Personal Information with them. See also Section IV(e), (f) and (g) for how to opt out of cookies. If we share Personal Information we have received under the Privacy Shield Frameworks with a Third Party, that Third Party’s access, use, and disclosure of your Personal Information must also comply with our Privacy Shield obligations. We may be liable for any failure by any of our Third Parties to comply with the Privacy Shield Principles unless we prove that we are not responsible for the event giving rise to the damage. Under the Privacy Shield Frameworks, we are subject to the regulatory and enforcement authority of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information requested by government authorities, including for national security or law enforcement purposes. In compliance with the Privacy Shield Principles, Warmintro Inc. commits to resolve complaints about our collection or use of your Personal Information. If you are located in the European Union (EU), Switzerland or European Economic Area (EEA), and have a question or complaint regarding data collected in the EU, EEA or Switzerland and subsequently transferred to the U.S. under the Privacy Shield Frameworks, you should first direct your question or complaint to support@warmintro.ai. You can also write or email us at the following address: Warmintro Inc., 2647 Buchanan st Apt 1 San Francisco CA, Email: support@warmintro.ai Warmintro Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information or to file a complaint. The services of the BBB EU Privacy Shield are provided free of charge to you. Finally, as a last resort and in limited circumstances, EU & Swiss individuals with residual complaints may be eligible to request binding arbitration before a Privacy Shield Panel described on the Privacy Shield Annex I website found at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. 14. Access to information; contacting us We acknowledge the right of EU and Swiss individuals to access their personal data under the Privacy Shield. Section III (“Your Personal Data Rights”) explains how to contact us to access your data. To keep your Personal Data accurate, current, and complete, please update your account settings or contact us at the email address below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service. Please also feel free to contact us if you have any questions about Warmintro’ Privacy Policy or the information practices of the Service. Our email address for privacy issues is support@warmintro.ai. Our postal address is Warmintro Inc., 2647 Buchanan st Apt 1 San Francisco CA. 15. Changes to Warmintro’ Privacy Policy We keep this Privacy Policy under regular review, and we will notify you when we make changes in the future. Please review this policy periodically, and especially before you provide any Personal Data to us. We will also place any updates on our website. This privacy policy was last updated on the date indicated at the top of this document. We have no liability or responsibility for the privacy policies or practices of our Hosts or other actions of any Integrated Service that may be enabled within the Service.