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Privacy Policy

Last Updated: August 25, 2022

Welcome to the Formation Ventures website located at www.formation.ventures (the “Site”). This privacy Policy (“Privacy Policy”) applies to personal data we collect, including through this Site, and any other Formation Ventures registration or other website, mobile applications, online portals, electronic forms, surveys, and any other channel or mobile feature that we operate (collectively, “our Sites”) as well as any of our other products or services that link to this Privacy Policy that Formation Ventures may provide now or in the future (collectively, the “Services”). In these instances, Formation Ventures is the controller responsible for your personal data. This Privacy Policy is incorporated by reference into the Formation Ventures Terms of Use.

REVISIONS TO THIS PRIVACY POLICY

Any personal data collected by the Site or Services is covered by the Privacy Policy in effect at the time such personal data is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Site or Services or by sending you other notifications, and we’ll update the “Last Updated” date above to indicate when those changes will become effective.

WHAT DATA WE COLLECT ABOUT YOU

Account Information. We receive and store any information you knowingly provide to us. Through some requests you make (including but not limited to applying for or nominating someone for our Fellowship program, requesting curricular materials, or joining our mailing list), we may collect personal data such as your name, email address, school, school address, title, and other information about your interests and preferences. Any other information combined with your personal data will be treated together as personal data.

All personal data entered by you is voluntary and at your own discretion, though certain information is required in order to make some requests as noted above. If you provide such personal data, you consent to the use of that personal data in accordance with the policies and practices described in this Privacy Policy. Formation Ventures may send you notifications, information, materials, or other offers through email, text, or other type of notification. Also, we may receive confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Site and Services.

Information Collected Through Your School.

We will add information to your personal data that the school may provide to us in connection with our Site and Services. Formation Ventures understands that it is important that our partner schools comply with the Family Education Rights and Privacy Act (“FERPA”) and related regulations. Certain information collected through your school that may be provided to Formation Ventures that is directly related to a student and maintained by your school, may be considered an education record (“education record”) under FERPA.

INFORMATION COLLECTED AUTOMATICALLY

Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Site.



The technologies and information we automatically collect include:

“Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services. We may use Cookies to tell us how and when you interact with our Services, to monitor aggregate usage and web traffic routing on our Services, and to customize and improve our Site. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. However, if you don’t accept Cookies, you may not be able to access all portions or features of the Site. Some third-party service providers that we engage may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included in the Services and Site for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of the Services, to monitor how many visitors view the Services.

Information Related to Use of the Services. Our servers may automatically record certain information about how a person uses the Services or Site (“Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, browser type, operating system, the web page that a user was visiting before accessing our Site or the Services, the pages or features of the Services to which a user browsed and the time spent on those pages or features, search terms, the links on the Formation Ventures Site or Services that a user clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our user’s needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how the Services are used.

Information Sent by Your Device. We collect certain information that the device from which you are using the Services and Site (such as, mobile phone, iPad, computer, etc.) sends when you use the Services and Site, like a device identifier, user settings and the operating system of your device, as well as information about your use of the Services and Site.

Location Information. When you use our Site, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize the Services for you.

HOW WE USE YOUR PERSONAL DATA

We use personal data in the following ways:

  • Information You Give To Us. We will use personal data:
    • to provide you with the information and services that you request from us;
    • to provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) where you have consented to this, or where we can otherwise lawfully do so.
    • to notify you about changes to the Services;
    • to ensure that content from Formation Ventures is presented in the most effective manner for you and for your computer.
  • Information Automatically Collected. We will use this personal data:
    • to administer Formation Ventures and for internal operations, including troubleshooting, site traffic, data analysis, testing, research, statistical and survey purposes;
    • to improve Formation Ventures to ensure that content is presented in the most effective manner;
    • as part of our efforts to keep Formation Ventures safe and secure;
    • to make suggestions and recommendations to you and other users of Formation Ventures about goods or services that may interest you or them.

Our primary goals in collecting personal data is to provide and improve our Services, to administer your use of the Services, and to enable you to enjoy and easily navigate the Services.

We will use your personal data to:

  • administer the Services, communicate with you and provide customer support in relation to the Services.
  • resolve disputes, collect fees (if any) and troubleshoot problems.
  • customize your experience and otherwise measure and improve the Services.
  • send you relevant emails and communications (including keeping you informed about our products, offerings and any promotional offers) that might be of interest to you (If we use your personal data to market to you, you will be able to opt-out of such uses).
  • enforce our agreements, terms, conditions, and policies, and send you notices and alerts.

Additionally, we may offer you products and services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.

Legal bases under the GDPR, UK GDPR, POPIA or LGPD. If you are in the European Economic Area (EEA), the United Kingdom (UK), South Africa or Brazil, we will collect and use your personal data only if we have one or more legal bases for doing so under the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), the South Africa Protection of Personal Information Act (“POPIA”) or the Brazil General Personal Data Protection Law (“LGPD”). The legal basis depends on your interaction with us. This means we collect and use your personal data only where: you have given your consent for one or more specific purposes; it is necessary to perform a contract we are about to enter into or have entered into with you; it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; it is necessary to protect the vital interests of you or another natural person; or it is necessary to comply with a legal obligation. We will indicate the legal basis or bases on which we are relying for each purpose. Where we are relying on consent as the legal basis, we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it.

PERSONAL DATA THAT WE SHARE WITH THIRD PARTIES

First and foremost, you should know that Formation Ventures does not sell or rent your personal data to any third-party for any purpose – including for advertising or marketing purposes. Furthermore, we do not share your personal data with any third-parties except in the limited circumstances described in this Privacy Policy and as set forth below:

Information Shared with Authorized Viewers. We may share your information, including your personal data, with individuals that you have explicitly authorized us to share your information with (“Authorized Viewers”).

Information Shared with Our Service Providers. We may engage third-party services providers to work with us to administer and provide the Services (e.g. companies that provide us services such as hosting and maintenance of our Site, data storage and management, etc.). These third-party services providers have access to your personal data only to the extent needed to perform services on our behalf.

Information Shared with Third Parties. From time to time in the course of our business or operations, we may collaborate with other educational partners to collect, analyze and process data relating to our student users. Such collaboration enables us to grow and improve our Services.Generally, any such data is collected in an aggregated and anonymized format, which means that personal data will not be included in any such collected data. Your use of the Site and Services constitutes your consent to the collection and sharing of aggregated, anonymized data with such third parties in the manner described in this paragraph. In the event that any data is shared with third parties in a manner that contains personal data, we will take reasonable efforts to ensure that our users have consented to the collection and sharing of such personal data.

Analytics Services. Our website may use third party website tools from time to time, for example Google Analytics and online survey tools. For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/. We use these analytics services, including mobile analytics software, to help us understand and improve how the Services are being used. These services may collect, store and use information in order to help us understand things like how often you use the Services, the events that occur within the application, usage, performance data, and from where the application was downloaded.

Aggregated Information and Non-identifying Information. We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other non-personally identifiable information, including with users, partners or the press in order to, for example, demonstrate how the Services are used, spot industry trends, or to provide marketing materials for Formation Ventures. Any aggregated information and non-personalized information shared this way will not contain any personal data.

Legal Requirements.  We may disclose personal data if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal data where, in good faith, we think it is necessary to protect the rights, property, or safety of Formation Ventures, our employees, our community, or others, or to prevent violations of our Terms of Use or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to law enforcement and government requests. Where appropriate, we may notify users about the legal requests, unless (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Formation Ventures, or its users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

Change of Control. In the event that all or a portion of Formation Ventures or its assets are acquired by or merged with a third-party, personal data that we have collected from users would be one of the assets transferred to or acquired by that third-party. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal data as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal data by such a successor company, you may request its deletion from the company.

SPECIAL CATEGORIES OF DATA



Formation Ventures does not intentionally collect any “special categories of data” under GDPR, UK GDPR, POPIA, or LGPD, without your explicit consent for one or more specified purposes or as otherwise permitted or required by applicable law. Special categories of data include personal data (a) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or (b) concerning health or data concerning a natural person’s sex life or sexual orientation.

FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”)



If you are employed by a school or district subject to FERPA, you agree to appoint Formation Ventures as a “school official” as that term is defined in FERPA and as interpreted by the Family Policy Compliance Office, and determine that Formation Ventures has a “legitimate educational interest” for the purpose of delivering the Services in accordance with these Terms. Formation Ventures agrees that it shall be bound by all relevant provisions of FERPA, including operating under the direct control of the school or district with respect to handling of “personally identifiable information” from “education records,” as those terms are defined in FERPA. Formation Ventures further agrees that personally identifiable information from students will not be disclosed to third parties except as required to provide Services to you contemplated in this Agreement. Any third party users will be bound to manage personally identifiable information in compliance with the Privacy Policy, security policies and all applicable laws, and to use the personally identifiable information for the sole and limited purpose of providing the Services to the user.

Formation Ventures may use education records that have been de-identified for product development, research or other purposes permitted by applicable law (“De-identified Data”), including:

  • To demonstrate the effectiveness of the Services, including in our marketing materials; and
  • To develop and improve our educational products.

Formation Ventures will not attempt to re-identify the De-identified Data nor will we transfer the De-identified Data to a third-party unless that party agrees not to attempt re-identification.

YOUR CHOICES

We offer you choices regarding the collection, use and sharing of your personal data and we’ll respect the choices you make. Please note that if you decide not to provide us with the personal data that we request, you may not be able to access all of the features of the Services.

Opt-Out. We may periodically send you free newsletters, SMS messages and e-mails that directly promote the Formation Ventures Site and Services. When you receive such communications from us, you will have the opportunity to “opt-out” (by following the unsubscribe instructions provided in the email you receive). There are certain communications regarding use of the Services that you will not be able to opt out of– e.g., communications regarding updates to our Terms of Use or this Privacy Policy.

Opt-In. If you are located in the European Economic Area or the United Kingdom, essential cookies may be used in order to provide the Services. However, you will be provided with the ability to choose whether you consent to the use of and subsequent processing of data collected through non-essential cookies (e.g., functional cookies, analytics cookies, targeting cookies and/or social media cookies) at the time when you first visit the Formation Ventures site. If located in the European Economic Area, you may also more generally opt in to the use of cookies, by clicking [Insert link to Cookie Banner].

HOW WE PROTECT, STORE AND TRANSFER YOUR DATA

Formation Ventures uses commercially reasonable information security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. Formation Ventures segregates certain personally identifiable and other information about your use of Formation Ventures’s Services into separate databases, some of which can be accessed only by a limited number of employees.

We restrict access to personal data to authorized Formation Ventures administrators, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Formation Ventures is operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including personal data, will be transferred to the United States. We may also allow service providers located around the world to access personal data as provided in this notice. If your personal data is subject to GDPR, UK GDPR, POPIA, or LGPD we will ensure your legal rights and protections travel with any such “transfer” of your personal data as required by applicable law. We do this by signing “standard contractual clauses” approved by the European Commission that give personal data the same protection it has in the European Union, and/or otherwise requiring that our service providers protect personal data in accordance with applicable law. We will also comply with similar applicable laws regarding the storage and transfer of personal data in other jurisdictions where your personal data may be collected or provided.

Storage Period. We will store your personal data until it is no longer needed to fulfill the purpose(s) for which it was collected or as otherwise required or permitted by law. After such time, we will either delete or anonymize your personal data or we may dispose of any data at our discretion without notice, subject to applicable law. Please contact us at admin@formation.ventures if you would like more details regarding our retention periods for different categories of personal data.

LINKS TO OTHER SITES

The Formation Ventures Site and Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. Formation Ventures is not responsible for the content, privacy or security practices and policies of any Third-party Service.

OUR POLICY TOWARD CHILDREN

The Formation Ventures Site and Services are not intended for use by children under the age of 13 and do not knowingly collect personal data from children under 13 years of age. If you believe that your child or student may have provided us with personal data without parental consent, you may contact us at admin@formation.ventures. If we learn that we have collected personal data of a child under 13 we will take steps to delete such information from our files as soon as possible.

Other Rights. To the extent provided by applicable laws (including the GDPR, UK GDPR, POPIA, and LGPD), you also may have the right to deactivate, block, anonymize, or delete personal data as appropriate; request and receive a copy of the personal data you have provided us and to transmit this data to a third party; and lodge a complaint with the applicable data protection authority. To exercise any of these rights that you are not able to do directly, please contact us at admin@formation.ventures.

RESPONDING TO DO NOT TRACK SIGNALS

Our Site and Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.

QUESTIONS?

Please contact us at admin@formation.ventures if you have any questions about our Privacy Policy.