Last Updated: July 18, 2023
Data Covered by This Policy
Gauntlet may collect and receive information in various ways. We will collect information when you visit our Site, when you sign up to receive information on our services, when you receive communications from us, or when you communicate with us.
For purposes of this Policy, “Personal Information” means information that directly or indirectly identifies an individual, such as a name, email address, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual, and also includes information referred to as “personally identifiable information” or “personal data” under applicable data privacy laws, rules, or regulations.
This Policy does not cover the practices of companies we do not own or control or people we do not manage. Our Site may contain links to other websites, applications, platforms or services operated by third parties. For instance, we use Medium.com to host our blogs. We provide links to the LinkedIn and Twitter platforms. Those third parties’ policies and practices are covered by their privacy policies. We recommend that you review those third parties’ policies to understand how they may use your personal information.
What Information We Collect
We collect the following types of personal information:
Information That You Provide to Us
When you contact us, complete an online form, or subscribe to an alert or mailing list, we will collect certain contact or demographic information. This includes your name, email address, and protocol of interest.
Certain services that we offer may require a payment for access. We collect payment information for these purchases, which includes payment card number, expiration date, and billing information).
We may collect data about your transactional and activity information, such as requests, searches or orders.
In some instances, you may choose to provide us Information about others, such as the name and email address of a contact with whom you want to share information from our Site. Do not give us information about others unless you are authorized or have their permission to do so and have brought this Policy to their attention. We will use their information for the purposes described in this Policy.
Information We Collect from Other Sources
We may collect information from other sources, such as organizers of events in which Gauntlet participates, third-party data suppliers, business partners and social media platforms. The information we collect includes name, email address, and phone number. Social media platforms, including Medium, Twitter, and LinkedIn provide information such as username, user ID, demographic information, and other information, subject to your settings on those platforms and the privacy practices of those platforms.
Information We Collect Automatically
We collect certain information automatically when you visit our Site or subscribe to our alerts and/or mailings. This information includes the number and frequency of visitors, technical information about browsers and devices used to access the Site, and information about crashes or other technical issues.
In addition, we and third parties automatically collect certain information through cookies and similar tools. This includes information about your activities over time across the Site as well as across third-party sites, apps or other media. Some cookies (and similar tools) assign or collect unique cookie IDs or other identifiers associated with your browser or device. They may collect information while you are using our Site while they are running in the background of your device. The information automatically collected includes the following:
- Information about your computer, device, browser and operating system (e.g., type, model, and/or version).
- Internet protocol (IP) address, which is used to derive your general geographic area (e.g., city and country).
- Device identifiers.
- Information about your interactions with the Site, including browsing activities and clickstream data that reflect the materials on our Site that you have accessed, clicked on, or viewed.
- Information about how you accessed our Site, including details about websites or apps visited immediately before or after accessing our Site.
- Demographic and interests information (e.g., region, topics of interest).
- Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.
How We Use the Information We Collect
We collect and process personal information for the following purposes:
- To process your requests and to provide you with materials for which you signed up.
- To provide you customer assistance and technical support.
- To learn about how visitors use our Site and to analyze how you and others interact with and respond to our Site and communications from us.
- To communicate with you, including to send you materials you have requested or which we believe are of interest to you, information messages about our Site and services, responding to your questions and requests, and marketing and promotional communications.
- For our advertising and marketing purposes.
- To protect our rights and the rights of others.
From time to time we may also need to process personal information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other individuals, or if it is necessary for a task carried out in the public interest.
Legal Bases for Processing Information
We will not process your personal information if we do not have a legal basis for doing so. Legal bases include consent, contractual necessity, and our legitimate interests or the legitimate interests of others, as further described below:
- To honor our contractual obligations to you when we use your information to provide you with materials that you have requested. For example, when you purchase materials from us, it will be necessary to process your payment details and contact details to confirm and provide you those materials. Failure to provide the information could prevent or delay the fulfillment of the contractual obligations.
- To comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.
- To meet our legitimate interests when we use your information to provide you with the materials presented on our Site, to communicate with you and for advertising and marketing purposes, including interest-based advertising, in the context of a corporate transaction or with our business partners, social media platforms and advertisers. Our legitimate interests include improving the Site, our services, understanding how you interact with our Site and publications, deriving knowledge to develop new products and services, and customizing the Site by making it more relevant and interesting to you and others. When we process personal information to meet our legitimate interests, we put in place safeguards to help ensure that your privacy is given due regard.
- We will obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to sharing your information with third parties for their own marketing activities). If we ask for your consent to process your personal information, you can withdraw your consent at any time by contacting us using the details at the end of this Policy.
How We Share Information
We may share personal information in the following ways:
- With service providers that perform services or handle transactions on our behalf. These include, payment processors, security and fraud prevention consultants, hosting and other technology and communications providers, and analytics providers.
- With business partners.
- With advertising networks and websites, so that we can market and advertise on third party platforms and websites.
- With third party social media networks. Note that when you interact with social media widgets on the Site or share information from our Site using the social media share buttons, those social medial platforms may collect information. We do not control this sharing and are not responsible for the privacy practices of the social media platforms with which you engage.
- Other parties when required by law or as necessary to protect our rights, and in the context of corporate transactions.
- With your consent or otherwise at your direction.
How Long We Keep Your Personal Information
We will retain data, including personal information, as required by law. We may retain and use your information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements. Any removal or destruction of personal information will be compliant with relevant data protection legislation as well as other statutory rights, limitation periods and obligations. We may further retain information in an anonymous or aggregated form.
How We Secure Personal Information
We maintain appropriate technical and organizational safeguards to protect the security, confidentiality, and integrity of the information we collect from you. These safeguards are designed to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction of the information we collect from you and our platform. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. We cannot provide a 100% guarantee on the security of any information that we process.
Your Rights and Choices, Including Opt-Outs
Opt Out Preference Signals
You may opt out from the collection of non-essential device data on your web browser by managing your cookies at the browser or device level. You can turn on Global Privacy Control in your web browser or browser extension. We will honor opt out preference signals for each browser where you implement such signals. In addition, if you wish to opt-out of interest-based advertising and are located in the European Union or United Kingdom, click here. Please note, however, that by blocking or deleting cookies and similar technologies used on our Site, you may not be able to take full advantage of our Site or services.
Direct Marketing and Certain Third-Party Data Sharing
When we process your personal information for direct marketing purposes or share it with third parties for their direct marketing purposes, you can exercise your right to object to this processing at any time by emailing us at email@example.com. You may unsubscribe from our marketing or promotional emails by clicking the “Unsubscribe” link in our emails.
Data Privacy Rights Where You Live
Depending on where you live, you may have certain rights relating to the collection and use of your personal information based upon local data protection laws. These rights include the right to:
- Access the personal information that we hold about you;
- Know how we process your personal information;
- Correct any inaccuracies in the personal information that we hold;
- Delete your personal information (Note that this right is subject to certain exceptions. For example, we may need to retain your personal information to complete a transaction or other action you have requested. We may have a legal or regulatory obligation or other valid reason to continue to process it. If your deletion request is subject to one of these exceptions, we may deny your deletion request.);
- Restrict the processing of your personal information;
- Transfer your personal information;
- Obtain a copy of the personal information that you provided;
- Object to the processing of your personal information;
- Decline decision-making based solely on automated processing that has a legal impact; and
- Withdraw your consent at any time, should we process your personal information based upon consent (Note: if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of your personal information, if such use or disclosure is necessary to enable you to use some or all of our services);
- File a complaint about our practices with respect to your personal information with the supervisory authority of your country or EU Member State. A list of supervisory authorities in the EU is available here: https://edpb.europa.eu/about-edpb/board/members_en. The U.K. supervisory authority may be contacted at https://ico.org.uk/make-a-complaint.
Exercising Your Rights
To exercise your rights, you may contact us at firstname.lastname@example.org. We may need to verify your identity and place of residence before completing your rights request. We will only use personal information provided in a request to verify you and complete your request. We do our best to ensure that we respond to valid requests within one month unless otherwise required by law.
International Transfers of Personal Information
We operate globally and have offices, partners, and subprocessors around the world to deliver our services. When you use our Site and services, your collected information may be sent to and processed in countries outside your country of residence, including the U.S. For individuals residing in the European Economic Area (“EEA”) or United Kingdom (“UK”), and for personal information subject to European data protection laws, this includes transfers outside of the EEA or UK. Some of these countries may not have data protection laws that provide an equivalent level of data protection as the laws in your country of residence.
If we transfer personal information protected under this Policy to a jurisdiction for which the European Commission or UK’s Information Commission Officer has not issued an adequacy decision, we will ensure that appropriate safeguards have been implemented for the transfer of personal information in accordance with EU or UK Data Protection Law; or rely on the approved Standard Contractual Clauses.
Children’s Personal Data
We do not knowingly collect any personal information directly from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Sites or service or send us any personal information. If we discover we have received any personal information from a child under 16 in violation of this Policy, we will delete that information as soon as possible. If you believe we have any information from or about anyone under 16, please email email@example.com.
In an effort to improve our Site and services, we may change this Policy to reflect changes to our information practices from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. We encourage you to periodically review this Policy for the latest information on our privacy practices.