This Privacy Policy describes how Global Innovation Catalyst, LLC (“GIC”, “we”, “us”, and/or “our”) handles personal information that we collect from and about you when you visit our website, [www.globalinnovationcatalyst.com ] (the “Site”); apply for admission to, and participate in our programs; engage with us through our newsletters, emails, and branded social media accounts; or otherwise interact with us. Collectively, we describe our products and services - including our Site, programs, and online publications and communications - as our “Services.” This Privacy Policy also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.
For the purposes of this Privacy Policy, “Personal Information” means information about identified and identifiable individuals, such as their name and email address, and includes “personal data” as defined by the European Union’s General Data Protection Regulation (“GDPR”) and “personal information” as defined by the California Consumer Privacy Act (“CCPA”).
By using any of GIC’s Services, you confirm that you have agreed to the GIC Terms of Service, to the extent permitted by law, and have read and understood this Privacy Policy.
Information you give us directly
Some information we collect directly from you. The type of Personal Information we collect in these situations varies depending on the type of response or service requested but may include your first and last name, contact details, date of birth, education history, financial information, employment affiliation, photos, interests, demographic information, social network information, and any other information you choose to provide. For instance, we collect information that you voluntarily provide in the following ways:
- When you fill in forms on our Site, request additional information, or respond to an advertisement. When you fill in forms on our Site including when you request additional information about programs, we may require that you provide us with certain information such as your first and last name, email address, program interest, social network information (such as a LinkedIn profile), current organization, position or title, and, if applicable, the name and affiliation of the person who referred you to us.
- When you set up a Site account and populate your profile. If you create an account on our Site, we will collect the username and password you create in order to log in. We may also ask you to populate your site with a profile picture, age range, location, and interests.
- When you sign up to receive newsletters or other email communications from us, subscribe to our blog, or complete a survey When you engage in one of these activities, we may collect your name, email address, and any additional information you choose to provide to us as part of that request (such as information about your satisfaction with our programs in response to a survey).
- When you apply for enrollment, apply for financial aid, register for programs, or use our career resources. When you apply for admission to a GIC program we collect an array of information about you including contact information, demographic information, and information about your past educational and work experiences. Basic information we collect includes your first and last name, email address, phone number, physical address, country of citizenship, organizational affiliation, position or title, social network information (such as a LinkedIn profile); and preferred start date. We may, from time to time, offer certain financial aid options. If you apply for such aid, we may ask you for certain information relating to your finances.
- When you purchase educational or other products and services from us. If you choose to purchase programs or other products or services from us, we require that you provide us, or our third-party payment processor, with your name, payment card information, and billing address.
- When you register for an event or webinar. If you register for an event or webinar we host or sponsor, we may collect your name, contact details, location, photos, demographic information, program you are enrolled in, an any specific information relevant to the event for which you are registering.
- When you register for a contest, competition, or sweepstakes. In these circumstances, we may collect your name, contact details, location, photos, demographic information, program track, a short bio, and any other information you choose to provide.
- When you email us to ask a question or request customer service or when you communicate with us via a third-party social media platform. When you contact us by email; through our branded social media accounts; through any integrated chat providers we may provide; or by telephone, SMS, or physical mail, we may collect your name, username, email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide.
- When you invite others to learn more about GIC. Our Services allow you to invite others to use GIC. In these cases, we store the invitee’s email address only so long as is necessary to send the invite. We also let the invitee know who invited them to use GIC and let them request that their information be deleted from our systems.
- When you apply to become an Instructor, mentor, speaker, or volunteer with us. If you apply to become an Instructor, mentor, speaker, or volunteer with us, we will collect any information you choose to share in your application, which may include your name, email address, phone number, physical address, employment history, and education history.
Information we collect automatically when you use our Services
We also collect certain information automatically as you navigate our Services or interact with our communications. To collect this information, we, or our third-party service providers may use cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We, and our third-party service providers use cookies in order to do things such as recognize you when you return to our website, save your preferences (including your preferences regarding cookie handling), understand which sections of the website you find most interesting, ensure our Site is working properly, and prevent fraud. We use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or until they expire).
The information we collect automatically can include the following:
- Information about the devices you use to access our Services (including your internet protocol (IP) address, browser type, and operating system);
- The address of the web page visited before and after using our Services;
- Details about your interactions with our Services (such as the date, time, length of stay, and specific pages accessed during your visits);
- Search terms used to reach our Services;
- Usage information (such as the number and frequency of visitors to our Services); and
- Location information (such as GPS information or general location information inferred from your IP address).
If you do not want us to collect information through the use of cookies, you can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to the guidance offered by your chosen web browser if you would like help managing your cookie preferences. Please note that if you reject or block cookies, the Services may not work as intended.
Information we collect from other sources
We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from:
- Payment processors (in relation to transactions);
- Social media platforms (that you may connect to or interact with through our Services);
- GIC Fellows (which are third parties we work with in order to spread the word about our programs and identify prospective participants who may be interested in our Services);
- Service providers we work with (in order to verify, update, or append data to the information that we have otherwise collected about you);
- Other third parties that work with us (in relation to providing or making available our Services); and
- Other individuals (if they provide us with your email address in order to invite you to learn more about GIC).
We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.
We use the information described above to:
- Administer the application and registration process (including reviewing and processing applications, organizing applicants into cohorts based on when they apply, verifying the information you provide, determining if you meet the criteria necessary to become a program participant, registering you for programs, contacting you in relation to your enrollment status, and processing program payments);
- Provide our Services (including creating your account and identifying you when you sign in; managing your access to and use of our Services; fulfilling your requests, registrations, and purchases; and sending you technical notices, updates, security alerts, and support and administrative messages);
- Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);
- Communicate with you (including responding to your requests, inquiries, comments, and suggestions);
- Personalize content (including tailoring content we send or display to you in order to provide you with news and information we think will be of interest to you);
- Further our networking, marketing, and social strategies (including posting testimonials; notifying you about programs, services, offers, promotions, and events; and promoting our programs and services);
- Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);
- Support our general business operations (including maintaining our business and legal recordkeeping); and
- Carry out any other purpose described to you at the time the information was collected.
We may share information about you with certain third parties in the following circumstances:
- Companies under common control: We may share data between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with GIC.
- Vendors and service providers: We may share Personal Information with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf, such as processing payments, providing analytics services, or providing cloud-hosting or cloud-storage services.
- Education partners: We may share Personal Information with third-party institutions, including The Center for Sustainable Development and Global Competitiveness (SDGC) at Stanford University with which we work to make available certain education and career initiatives.
- Other third parties: We may share your Personal Information with other third parties that provide advertising, campaign measurement, online analytics and other services, in order to help us reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Services and other online services over time and across devices.
- Business transfers: We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re- organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
- Legal requirements: We may share Personal Information when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Personal Information when we believe it is necessary to protect GIC’s rights and property, to protect the safety of our users, and to defend against legal liability.
- Consent: We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information.
- Social media platforms: We may offer social sharing features and other integrated tools such as widgets, which allow you to share content on our Site with third-party social media platforms like Facebook or LinkedIn. Using these social sharing features is optional. You should always review, and if necessary, adjust your privacy settings on third-party social media platforms before linking or connecting them to our Site or Services.
We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services.
You have a variety of rights and choices related to our use of your Personal Information.
- Opting out of email marketing. You can opt out of receiving our promotional emails at any time by following the instructions included in those emails. Please be aware that it may take up to 10 days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non- promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).
- Restricting cookies/Do Not Track. GIC does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” signals, we will assess and provide an appropriate response to those signals.
- Limiting Information in Your Account. You can control the information we collect about you by limiting what information you provide through your account. Please note that if you choose not to provide certain information it may make it difficult or impossible for you to access some services (for example, to register for a program).
- Limiting Information Available Through Social Media Platforms: When you interact with us through a third-party social media platform, such as when you like, follow, or share our content on Facebook, Twitter, LinkedIn, or other platforms, we may receive information from that third-party social media platform including your profile information, picture, user ID associated with your social media account, and any other information you permit the social media platform to share with third parties. If you want to limit or stop receipt of information from third-party social media platforms, you can change your privacy settings on those other websites. You also may choose not to use social features we make available.
- Access, Update, or Delete Your Information. If you would like to access, update, or delete Personal Information you have provided you may do so through your account settings or by emailing us at privacy@globalinnovationcatalyst.com. To learn how to close your account, please contact us at privacy@globalinnovationcatalyst.com. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.
- California Privacy Rights: If you are a resident of California, California law requires us to disclose the following information with respect to our collection, use, and disclosure of your Personal Information.
- Notice of Collection. Although the information we collect is described in greater detail in the “Information We Collect” section above, the categories of Personal Information that we have collected – as described by the CCPA – including in the past 12 months are:
- Identifiers, such as name, contact information, and IP address. We collect this information directly from you, from third-party sources, or indirectly through your actions on our Site or from your devices.
- Other individual customer records, such as phone number, billing address, signature, education, employment, bank account and payment card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code § 1798.80(e)), and overlaps with other categories listed here. We collect this information directly from you, from third-party sources, or indirectly through your actions on our Site or from your devices.
- Commercial information, such as invoicing information and engagement with our Service. We collect this information directly from you.
- Demographic information, such as age and gender. We collect this information directly from you.
- Internet activity, such as referring and exiting pages and your interactions with our Service. We collect this information directly from your device.
- Financial Information, such as payment information or financial account numbers. We collect this information directly from you.
- Employment information, such as company name and job title. We collect this information directly from you or from third-party sources.
- Sensory information, such as photos or voice recordings. We collect this information directly from you or from third-party sources.
- Inferences, such as information about your interests and preferences. We collect this information directly from you or indirectly from your activity on our Site or from your device.
- Business or Commercial Purpose for Collecting and Using Personal Information. We collect each category of Personal Information listed above for the business or commercial purposes described in the “How We Use Your Information” section above.
- Categories of Sources of Personal Information. We collect each category of Personal Information listed above directly from you, through automatic data collection means, or through the third-party sources described in the “Information We Collect” section above.
- Categories of Personal Information Disclosed. In the preceding 12 months, we may have disclosed the categories of Personal Information listed above in the circumstances described in the “How We Share Your Information” section above.
- Categories of Third Parties With Whom We Share Personal Information. We may share each category of Personal Information listed above with the third parties described in the “How We Share Your Information” section above.
- Right to Know. California residents may request disclosure of the specific pieces and/or categories of Personal Information that we have collected about them, the categories of sources for that Personal Information, the business or commercial purposes for collecting the information, the categories of Personal Information that we have disclosed, and the categories of third parties with which the information was shared. To request this information please contact us at privacy@globalinnovationcatalyst.com
- Right to Opt-Out. GIC does not sell Personal Information to third parties for monetary value. However, the term “sale” is defined broadly in the CCPA. To the extent that “sale” under the CCPA is interpreted to include any of the data uses described in the “How We Use Your Information” section above, California residents are entitled to opt-out of the “sale” of data at any time.
- Deletion. You may request that we delete the Personal Information we have collected about you (subject to certain exceptions). Please be aware that we may keep certain information as required or permitted by applicable law. To exercise this right, please contact us at privacy@globalinnovationcatalyst.com .
- Authorized Agent. You may designate an authorized agent to make a request on your behalf. To do so, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. To verify the request, we may contact you directly.
- Right to Non-Discrimination. Limiting use of, or deleting, your Personal Information may affect features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.
- Shine the Light. California Civil Code § 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below
Our Services are intended for adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please contact us at privacy@globalinnovationcatalyst.com .
We may provide links to third-party websites, services, and applications that are not operated or controlled by GIC. This Privacy Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.
Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States where we are based or in any country where we have operations or where we engage vendors or service providers. These countries may not have the same data protection laws as the country in which you originally provided the data. By using our Services or submitting your Personal Information to us, you agree to such transfers.
Data Retention
We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Policy, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
GIC uses generally accepted administrative, physical, and technical safeguards we believe are appropriate to protect the confidentiality, integrity, and availability of your Personal Information. Although we make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet and storing information electronically. GIC cannot and does not guarantee absolute security.
We may change this Privacy Policy from time to time to reflect changes in our practices or in the law. If we make changes to this policy, we will post the updated Privacy Policy on our website and indicate when it was last revised. You are advised to review this policy periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy, to the extent permitted by law.
If you have any questions about our Privacy Policy or how we protect your Personal Information please contact us at privacy@globalinnovationcatalyst.com .
Last updated: May 29, 2020
