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This Privacy Policy (the “Privacy Policy”) serves to inform individuals outside of our organization with whom we interacting, including customers, visitors to our Sites and other users of our Services (“you” or “your”) of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use the website (the “Site”), services, software, content, and all other products and services (all of the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by Sagetap, Inc., a Delaware corporation (together with its subsidiaries and Affiliates, “Sagetap”, “we,” “our” or “us”). Sagetap believes that the privacy of its users is paramount and strives to use Personal Date only in ways outlined in this Privacy Policy. The Privacy Policy is incorporated by reference into our Terms of Use, currently available at https://sagetap.io/terms-of-use (the “Terms of Use”). Any terms used herein and not defined will have the meanings given to them in the Terms of Use. By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Use and that you are over 18 years of age. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY. Defined terms used in this Privacy Policy are explained in Section (S) below.
A. Purpose
This Notice explains how we may Process your Personal Data. For the purposes of this Notice, Sagetap is the Controller. Contact details are provided in Section (R) below.
This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice. We will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.
B. Collection of Personal Data
We may collect or obtain Personal Data about you: (i) Directly from you (e.g., where you contact us); (ii) in the course of our relationship with you (e.g., if you make a purchase); (iii) when you make your Personal Data public (e.g., if you make a public post about us on social media); (iv) when you visit our Sites; when you register to use any of our Sites, or Services; or (v) when you interact with any third-party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
We may collect Personal Data about you from the following sources:
C. Creation of Personal Data
We may create Personal Data about you (e.g., records of your interactions with us). We may also create Personal Data about you, such as records of your interactions with us, our Clients, or our Sages.
The Services provide tools allowing you to upload electronic copies of technology pitches. Information that you provide through the use of these tools will be available to Sages. Sagetap has no obligation to keep private any information that you disclose to other users using these functions. You should exercise caution when deciding to disclose Personal Data through the use of these tools or functions. We strongly recommend that you do not post any information through the Services that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
D. Categories of Personal Data we may Process
We may Process: (i) Your personal details (e.g., your name, biographical information); (ii) demographic data; (iii) your contact details (e.g., your address); (iv) records of your consents; (v) payment details; (vi) information about our Sites (e.g., the type of device you are using); (vii) details of your employer (where relevant); (viii) information about your interactions with our content or advertising; and (ix) any views or opinions you provide to us.
We may Process the following categories of Personal Data about you:
E. Legal basis for Processing Personal Data
We may Process your Personal Data where: (i) you have given your prior, express consent; (ii) the Processing is necessary for a contract between you and us; (iii) the Processing is required by applicable law; (iv) the Processing is necessary to protect the vital interests of any individual; or (v) where we have a valid legitimate interest in the Processing.
In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:
F. Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, including ensuring that one of the legal bases set out above is available to us with respect to the Processing of those Sensitive Personal Data.
G. Purposes for which we may Process your Personal Data
We may Process your Personal Data for the following purposes: (i) providing Services to you; (ii) compliance checks; (iii) operating our Sites; (iv) communicating with you; (v) managing our IT systems; (vi) financial management; (vii) conducting surveys; (viii) marketing materials; (ix) ensuring the security of our premises and systems; (x) conducting investigations where necessary; (xi) compliance with applicable law; and (xii) improving our Sites, and Services.
We may Process your Personal Data for the following purposes, subject to applicable law:
H. Disclosure of Personal Data to third parties
We may disclose your Personal Data to: (i) legal and regulatory authorities; (ii) our external advisors; (iii) our Processors; (iv) any party as necessary in connection with legal proceedings;(v) any party as necessary for investigating, detecting or preventing criminal offences; (vi) any purchaser of our business; and (vii) any third party providers of advertising, plugins or content used on our Sites.
We may disclose your Personal Data to other entities within Sagetap, for legitimate business purposes (including operating our Sites, and providing Services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
Additionally, if you are a Sage:
Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics
I. International transfer of Personal Data
We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.
Because of the international nature of our business, we may need to transfer your Personal Data within Sagetap, and to third parties as noted in Section (H) above, in connection with the purposes set out in this Notice. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.
If you are located outside of the United States, you should be aware that the Personal Data you provide to us is being transmitted to us and Processed in the United States, and will be protected subject to this privacy policy and United States laws, which may not be as protective as the laws in your country. Please note that when you transfer any Personal Data directly to a Sagetap entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.
J. Data security
We implement appropriate technical and organizational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
K. Data accuracy
We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that:
From time to time we may ask you to confirm the accuracy of your Personal Data.
L. Data minimization
We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
M. Data retention
We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
1. We will retain copies of your Personal Data in a form that permits identification only for as long as:
2. the duration of:
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
N. Your legal rights
Under applicable law, you may have a number of rights, including: (i) the right not to provide your Personal Data to us; (ii) the right of access to your Personal Data; (iii) the right to request rectification of inaccuracies; (iv) the right to request the erasure, or restriction of Processing, of your Personal Data; (v) the right to object to the Processing of your Personal Data; (vi) the right to have your Personal Data transferred to another Controller; (vii) the right to withdraw consent; and (viii) the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
This does not affect your statutory rights.
Additionally, California Civil Code Section 1798.83 (“CCPA”) requires certain businesses that share customer Personal Data with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Personal Data to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.
Furthermore, subject to certain exemptions, California residents have the following rights with respect to Personal Data we may have collected about them:
You have the right to request that we disclose:
You have the right to request that we delete any Personal Data about you that we have collected. Upon receiving a verified request to delete Personal Data, we will do so unless otherwise required or authorized by law.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.
Please note that:
We will acknowledge the receipt of your request within 10 days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right not to be discriminated against for the exercise of your California privacy rights described above. Unless permitted by the CCPA, we will not:
O. Cookies and similar technologies
We may Process your Personal Data by placing or reading Cookies and similar technologies. For more information, please see our Cookie Policy.
When you visit a Site we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.
P. Terms of Use
All use of our Sites, or our Services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.
Q. Direct marketing
We may Process your Personal Data to contact you with information regarding Services that may be of interest to you. You may unsubscribe for free at any time.
We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Services that may be of interest to you. If we provide Services to you, we may send information to you regarding our Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any Services you have requested.
R. Contact details
You may contact us at via post, telephone, fax, email or via our online Contact Us form.
If you have any comments, questions or concerns about any of the information in this Notice, would like request copies of our prior Privacy Policies, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:
Sagetap, Inc. 1820 Vallejo Street (#202), San Francisco CA 94123
Phone: (650) 996-4480 Fax: (650) 996-4480 Email: legal@sagetap.io
S. Definitions