Privacy Policy

Last Revised: September [26], 2018

This policy (“Privacy Policy”) describes the practices of _Able Partners NYC, LLC (“_Able”, “we” or “us”) for collecting, using, maintaining, and disclosing information that we collect from you or that you provide to us when you visit our website (our “Site“) and register with us to access any services, offerings and other interactions made available by us (together with our Site, the “Services”). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

We may modify this Privacy Policy from time to time, 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.

Information We Collect and Receive

The information we collect from you falls into two categories: personally identifiable information (“Personal Information”) and non-personally identifiable information (i.e., information that cannot be used to identify who you are) (“Non-Personal Information”). Below are the various ways in which we may collect Personal Information and Non-Personal information from you.

Information you give us

Information that you may provide through the Services or otherwise communicate with us includes:

• Personal and Business Contact information, such as your first name, last name, postal address, email address, telephone number, job title, and employer name.
• Personal information obtained from online transactions, transmitted as part of a form submission or in connection with other activities or Services made available on the Site.
• Content you post on our Site (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address).
• Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our Site, receive customer support or otherwise correspond with us.
• Usage information, such as information about how you use our Site and interact with us.
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.

Information Collected Through Use of the Services

If you use our Services, we may collect information about how you use and interact with the Services and the data and information that is collected or provided by you through or in connection with your use of the Services.

Information from Social Networking Sites

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 Privacy Policy. 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.

Information we get from others

We do not purchase data about you from other individuals or organizations.

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 _Able network such as our event organizers, contractors, and local representatives who have agreed to a relationship with us in order to deliver our 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.

Information automatically collected

We and third-party service providers acting on our behalf, which may include third-party analytics service providers and third-party advertisers, may incorporate technology such as “pixel tags”, “web beacons”, and “cookies” that allow us to track the actions of users of our Services automatically. For example, we may automatically collect information about your location, your internet connection, your browser, when you access the Services, the website address that linked you to our Site, the website that you visit after using our Services, and details of how you used our Services, such as how often you used our Services and which features of the Services you used.

Changes to your personal information

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 emailing us at [info@ablepartners.nyc].

How We Use Your Information

To Deliver the Services

We may use information that we collect about you or that you provide to us, including Personal Information, to measure usage of the Services, to analyze the effectiveness of our Services, to conduct research, to improve and enhance functionality of the Services, to provide support for the Services and respond to requests and inquiries, to provide you with notices, such as updates or changes that we may make to the Services, and to market and advertise the Services where you have agreed to this, including through promotional e-mail messages, directly or in partnership with other parties, and by displaying our advertisements on other websites that you visit or use. We may also use this information to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising).

We may from time to time aggregate information in certain data analysis, reports, or other interpretations of trends for both internal and external purposes.

With your consent

We may use or share your Personal Information with your consent, such as when you: let us post your testimonials or endorsements on our Site, instruct us to take a specific action with respect to your personal information, or opt into third party marketing communications.

To comply with law

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.

For compliance, fraud prevention and safety

We use your Personal Information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (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.

How We Share Your Information

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:

• Partners and User Groups. We may disclose your personal information to our partners with whom we sponsor and deliver programs, and to other users of our Services, solely for the purpose of providing our products and services, including sharing with other members of any program for which you may register (e.g. founders, mentors). For example, when you participate in the wingable program, your personal information may be shared with The Wing to organize and deliver the mentorship and workshop services. Also, when you register for an event through our Services, your personal information may be shared with the event organizers and sponsors in order to communicate with you about the event.
• Affiliates. We may disclose your personal information to any of our affiliates or joint venture partners for purposes consistent with this Privacy Policy.
• Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, email delivery and database management services). These third parties may use your information only as directed by _Able and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• Compliance with Laws and Law Enforcement; Protection and Safety. _Able may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• Business Transfers. We may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Choices About How We Collect, Use and Disclose Your Information

We strive to provide you with choices regarding our collection, use and disclosure of the information you provide to us. The mechanisms listed below aim to provide you with control over such collection, use and disclosure:

• Access, Update, Correct or Delete Your Information. If you wish to access, update, correct or delete any Personal Information in our possession or control, you may contact us at [info@ablepartners.nyc]. We do not guarantee that any Personal Information can be removed completely.
• Email communications. To receive marketing or promotional communications, you can opt-in by checking the relevant box located on the form on which we collect your data or emailing us at [info@ablepartners.nyc]. You may continue to receive service-related and other non-marketing emails.
• Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at [info@ablepartners.nyc].
• Choosing not to share your personal information. Where we are required by law to collect your Personal Information, or where we need your Personal Information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
• Disabling Cookies. You have the option to accept or disable cookies at any time through your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. If you choose to disable your cookies, your user experience may be limited.
• Do Not Track Signals. Third parties may keep track of your browsing activities across third party websites. Certain web browsers enable users to activate a “Do Not Track” signal but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.

Retention

We will only retain your Personal Information for as long as necessary to fulfill 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.

Security

We take reasonable steps to protect the Personal Information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. Please keep this in mind when disclosing any Personal Information to us via the Internet. In the event that personal information is compromised as a breach of security, _Able will notify its users in compliance with applicable law.

Other Sites and Services

Our Site 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.

Storage and Processing in Other Jurisdictions

Personal Information collected through the Services may be stored and processed in which _Able or its affiliates or service providers maintain facilities. If you are located in the European Union or other jurisdictions with laws governing data collection and protection that differ from U.S. law, you acknowledge that we may transfer Personal Information to a country or jurisdiction that has different data protection laws than the data protection laws of the country in which you reside and you expressly consent to the transfer of information, including Personal Information, to the United States or any other country in which _Able or its affiliates or service providers maintain facilities. We will ensure that appropriate safeguards are in place to protect your personal data and that transfer of your personal data is in compliance with applicable data protection laws.

Contact Us

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at [info@ablepartners.nyc].