Privacy Policy
Effective as of 9/11/2022
This Privacy Policy describes how Portal Venture Partners International LLC and our subsidiaries and affiliates (collectively “Portal,” “we”, “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website (collectively, the “Service”), as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy.
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), see the Notice to European users below.
Index
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfers
- Children
- Changes to this Privacy Policy
- How to contact us
- Notice to European users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
- Demographic data, such as your city, state, country of residence, and postal code.
- Professional data, such as your professional title, company name, and industry.
- Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Private sources, such as data providers, social media platforms, and data licensors.
- Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Data about others. We may offer features that help users invite their contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
How we use your personal information.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and business operations. We may use your personal information to:
- provide, operate and improve the Service and our business;
- facilitate your referral to contacts who you want to inform about the Service;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
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.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities. Where required by applicable law, we may also need to transfer your personal information to law enforcement, government authorities, courts and private parties for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Portal or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your choices
In this section, we describe the rights and choices available to all users.
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), see the Notice to European users below. 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. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ a number of technical, organizational 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 transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), see the Notice to European users below.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
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 or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
- Email: help@ascendwithportal.com
- Mail: Portal Venture Partners International LLC
1160 Battery St., Suite 100, San Francisco, California 94111
Notice to European users
The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom (“UK”) and the European Economic Area (“EEA”) (hereafter collectively referred to as “Europe”).
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller. Portal Venture Partners International LLC is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.
Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. If you have questions about the legal basis of how we process your personal information, contact us at help@ascendwithportal.com.
|
Processing purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”. |
Legal basis |
|
Processing is necessary to perform the contract governing our provision of our Service or to take steps that you request prior to signing up for the Service. |
|
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you. |
|
We may need to process your personal information for additional purposes, such as:
|
We rely on our legitimate interests to process your personal information when performing these processing activities. We do not use your personal information for these purposes where our interests are overridden by the impact on you. |
|
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. |
|
Processing is necessary to comply with our legal obligations. |
|
To comply with applicable law |
Processing is necessary to comply with our legal obligations. |
|
Actions we take with your consent:
|
In these scenarios, the processing of the personal information you voluntarily provide to us 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. |
Use for new purposes. 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.
Retention. We apply a general rule of keeping personal information only for so long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations, business needs and to provide the Service, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal information from closed Accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Service terms and take other actions as permitted by law.
Special Categories of data / Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, 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 Service, or otherwise to us.
Your rights. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Right of information – You have the right to obtain information about how and on what basis your personal information is processed and a copy of these information.
- Your right of access – You have the right to ask us for copies of your personal Information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal Information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
- Your right to object – You have the right to object to our reliance on our legitimate interests as the basis of our processing of your personal information in certain circumstances.
- Your right to withdraw consent – You have the right to withdraw your consent at any time where we rely on your consent to process your personal information.
- Cross-Border Data Transfer – You can obtain a copy of or access safeguards under which your personal information is transferred outside of the EEA.
- Direct marketing – If your personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of personal information concerning you for such marketing, which may include profiling to the extent that it is related to such direct marketing. In this case your personal information will no longer be processed for such purposes by us.
You may submit these requests by email to help@ascendwithportal.com or our postal address provided above. We reserve the right to charge a fee where permitted by law. 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. We may share your personal information with third parties who may be based outside of the EEA and/or UK. In such circumstances, those parties’ processing of your personal information will involve a transfer of your personal information outside of the EEA and/or UK. Whenever we transfer your personal information out of the EEA and/or UK, we try to ensure a similar degree of protection is afforded to it by making sure at least one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) from time to time.
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) and the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries – for example, there is currently no such decision in respect of the United States.
- However, in these cases:
- we may use specific appropriate safeguards approved by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable), which are designed to give personal information the same protection it has in the EEA and/or UK; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’.
You can obtain a copy of or access safeguards under which your personal information is transferred outside of the EEA.