PartnerHere – Privacy Policy

Last modified: July 25, 2020

This privacy policy (“Policy”) informs you of our practices when handling your Information through the Services (both as defined below). In this Policy, “PartnerHERE”, “we”, “our” or “us” refers to PartnerHERE, Inc., a company registered in Delaware, United States with its registered address located at10755 Scripps Poway Parkway Suite 413 San Diego, CA 92131.  We are the data controller under the applicable privacy laws. This Policy describes how we collect and further process Information we collect from or about you in connection with your use of the PartnerHERE website at www.partnerhere.com (the “Website”) and connected entrepreneur and business matching, and training services (together with the Website, the “Services”).

When you use the Services, you accept and understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not use any of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights in relation to your Information as set out in this Policy.

1. INFORMATION WE COLLECT

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual and does not include data whereby personally identifiable information has been removed (such as anonymous data).

We will collect and use the following Information about you:

Information you provide to us

· Registration Information: for example, when you create an account on the Website, you will be asked to provide Information, including your full name, phone number.  If you create an account directly through the Website (i.e. not using Google or Facebook), you will also be asked to provide an email address and a password.  We will generate an individual account ID that will be linked with your account.

Profile Information: after you have created an account you are required to provide City (State, Country), ZipCode and ‘About Me’ to your default profile, and can also choose to add additional information to your profile, including relevant skills, training, experience and profile photo.
Location data: We do not collect your location through GPS or based on your IP address. We use only the City/Zipcode information provided in your profile to determine your relative location.
Other information you provide as you use the Services: when you use the Services you may choose to provide additional information, including any information you provide when sending messages to other users through the Services.
Communication and support: when you communicate with us via the Services or otherwise, you provide us with Information such as your name, email address, account details and the contents and nature of your correspondence with us, including technical support requests, complaints and feedback on your use of the Services.
Surveys: We may periodically conduct surveys requesting information that will be helpful for developing new features and improving the user experience.
We do not ask for information about third parties, but please make sure you have permission from your co-workers or friends before sharing Information referring to your co-workers or friends with us, or otherwise creating Information about them on the Services.

Information we automatically collect or is generated about you when use the Services

· Identifiers and usage.  When you use the Services we and third parties will automatically collect identifiers such as your IP address, information on your usage such as interactions with the Services and our team, and device information.

· Cookie information. We and third parties automatically collect information about your visit to and use of the Website via cookies (see our Cookie Policy for more information). The information collected may include Information, such as your IP address, advertising identifiers, non-personal information about your device including model, version and operating system, the web pages that you visit just before or just after you use our website, as well as information about your interactions with our website, such the time of your visit and where you have clicked.

Information received from third parties

Information we receive from third party platforms: when you register for the Services through a third party account (such as Facebook or Google), we receive your full name and email ID.
Information from platforms our Services relies on: We use Stripe as a payment portal, integrated with Lifter Learning Management System (LifterLMS) which provides us with information about memberships and courses purchased.
Other Third Parties:We do not run third party ads on the site or gain data other than analytics data from Google Analytics.  This data allows us to understand how the site is being used and what people find most useful.
We also collect, use and share aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Information but is not Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of our Services to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Information so that it can directly or indirectly identify you, we will treat the combined data as Information which will be used in accordance with this Policy.

Children

The Services are not intended for use by anyone under the age of 16 and we do not knowingly collect Information from children under the age of 16.  If you learn that a child has provided us with Information in violation of this Policy, please contact us as indicated below.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

· Provide you with the Services. We will use your Information to operate, maintain and provide you with the Services.  In particular we will perform our contractual obligation towards you to allow you to create an account, amend your profile, browse the Services, create listings and offers, correspond with other users, pay for a subscription to access certain content or fees for courses and contact you in case of any issue with your account.The Information we process when doing so includes your registration Information, profile Information, additionalInformation you provide to us when using the Services and identifiers and usage Information. [If you are a paying user of the Services, we will use yourpayment Information for payment processing purposes as well as sales tax collection and reporting as required by law.]

· Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to respond to and resolve your queries and complaints and facilitate support (e.g. retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration information, your identifiers, and any other information about you collected via our customer support channels.

· Improve and monitor the Services.It is in our legitimate interests to improve our Services for our customers, including improving the security of our Services. When doing so, we may collect Information we automatically collect or is generated about you when you use the Services, as well as non-personal information about your device such as device manufacturer, model and operating system.

· Conduct analytics.It is in our legitimate interests to analyse the use of, and any other interaction or interest in our Services. When doing so we will process Information we automatically collect or is generated about you when you use the Services to create anonymized and aggregated data regarding your Website usage.

· Conduct surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interests because they help us understand our userbase and improve the Services. If you participate, we process your registration information and any other information collected through the survey questions.

· Send you messages about promotions, events, and other news, products or services we think will be of interest to you. We may send you emails with product news and other promotional materials,  and tips and tricks to use our Services. When doing so, we process your registration information and information about your Services usage. Where it is required, we will only do so where we have your consent. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication.

· Provide you with advertising.  We may present you with ads and suggestions in our Services and elsewhere.  These may be ads relating to our own Services, or other services and brands you may be interested in.  If you have consented, these ads and suggestions will be tailored specifically to you.  Your consent can be withdrawn at any time.  In situations where your Information is not used to tailor these ads to you, we provide ads on the basis of our legitimate interests. To tailor ads and to allow our advertising partners to tailor ads, we process information we automatically collect or is generated about you when you use the Services.

· Prevent fraud, defend PartnerHERE against legal claims or disputes, enforce our terms and to comply with our legal obligations.It is in our legitimate interests to protect our interests by (1) monitoring the use of the Services to detect fraud or any other user behaviour which prejudices the integrity of our Services, (2) taking steps to remedy aforementioned fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Information with selected third parties, including:

Other users who will see your name, profile information, listings or offers, and any other information you choose to share with them through the Services such as direct messaging content. You can choose to make your offers and profile(s) private in their settings.
Vendors and service providers we rely on for the provision of the Services, for example:
üCloud service providers who we rely on for data storage, including Amazon Web Services who are based in the U.S.A.;

üCustomer support solution providers, who help us manage and respond to our customer questions and complaints. This includes Zendesk, Inc. who are based in the U.S.A.;

üAnalytics providers. We may work with a number of analytics service providers who help us understand our userbase. This includes Google LLC, who are based in the U.S.A. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout; and

üCommunication providers, who we use to communicate with our users, such as Twilio, a cloud communications platform, who are based in the U.S.A.

Advertising partners.  Subject to your settings, we may provide certain Information to advertisers who use them for their own purposes, such as serving you with ads in the Services, and to measure who sees and clicks on their ads. We may also share device identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities. [No such partners at this time]

Payment processors, such asStripe. These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies. More information on how Stripe uses your Information is available herehttps://stripe.com/en-in/privacy
Others: We share the user data with Google Analytics to track the user experience on the platform to enhance the user experience. We do not currently  share user data with any other social sites for advertising. Users can choose to share their / others' posts from our platform to other social media sites and we still share only the URL to the respective Offer or Want Ad on our platform.
Companies who belong to the same group as PartnerHERE. We share your Information with entities in the group we belong to, as needed to operate the Services.
Law enforcement agencies, public authorities or other judicial bodies and organisations.We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request;enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;detect, prevent or otherwise address security, fraud or technical issues; orprotect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
Change of corporate ownership.  If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
4. Security

Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process.

Our Services may contain links to other sites that are not operated by us.  If you click a third party link, you will be directed to that third party’s site.  We advise you to review the privacy policy of these sites.  We are not responsible for the content, privacy policies or practices of such third parties.  Additionally, we are not responsible for how third party integration services may collect, use or share the Information you send from the Services. Please review the privacy policy of such third party integration partners before connecting those services to the Services.

5. WHERE WE STORE YOUR INFORMATION

Your Information will be processed by our employees and service providers in the U.S.  We take steps to ensure all transfers are protected by adequate safeguards, including the standard contractual clauses approved by the European Commission.]

6. HOW LONG WE STORE YOUR INFORMATION

Your Information is kept for as long as necessary to achieve the purpose set in this Policy, or for as long as we are required by law or in order to comply with a regulatory obligation.

When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

7. YOUR RIGHTS

If you are based in Europe, in some circumstances you have certain rights in relation to your Information.You will find more information below on when which rights can apply. To exercise your rights, please contact usat Support@Partnerhere.com.   Please note that we may ask you to verify your identity before responding to such requests.

Access.You have the right to access the Information we hold about you, and to receive an explanation of how we use it and who we share it with.
Correction. You have the right to correct any Information we hold about you that is inaccurate or incomplete.
Erasure. You have the right to request for your Information to be erased or deleted.
Object to processing. You have the right to object to our processing of your Information where we are relying on a legitimate interest or if we are processing your Information for direct marketing purposes.
Restrict processing. You have a right in certain circumstances to stop us processing your Information other than for storage purposes.
Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Information that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Information to a third party.
Withdrawal of consent.  Where we are relying on consent to process your Information, you have the right to withdraw your consent at any time.
8. CONTACT & COMPLAINTS

We welcome questions, comments and requests regarding this Policy.

If you wish to make a complaint about how we process your Information, please contact us at support@partnerhere.comwe will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

You can also send a letter to us at PartnerHERE,10755 Scripps Poway Parkway Suite 413  San Diego, CA 92131.

9. CHANGES

If we make any material changes to this Policy, we will post the updated Policy here and notify our users through the Services and/or newsletters. Please check this page frequently to see any updates or changes to this Policy.