Privacy Policy

Revised: January 1, 2021


Federato Technologies, Inc., a Delaware corporation, is committed to protecting your privacy. This Privacy Policy describes how we collect, use and share data, and what choices you have with respect to your data. We have updated this version of our Privacy Policy to reflect changes in data protection law.

This Privacy Policy applies to all websites that we own and operate, our applications and/or APIs, and online services (our “Site“), as well as the Risk Ops platform (“Platform“), and other services, offerings, and other interactions (e.g., customer service inquiries, or your participation in user conferences, community events, etc.) you may have with us that are subject to this Privacy Policy (together with our Site, collectively referred to as our “Services“). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our Site (“Third Party Services“), or any other third party products, services or businesses.

Information We Collect and Receive

We collect and receive information that relates to identified or identifiable individuals (“personal information“) as follows:

  • Identity Data: Information such as your name; address; email address; telephone number; gender; date of birth, age and/or age range; photo/avatar; account login details (e.g., username and password); and information such as unique IDs and online identifiers.
  • Contact Data: Identity Data that includes personal and business contact information, such as postal address, email address, telephone number, or other identifiers used for communication.
  • Content: Unstructured or free-form content that you post on our Site or Platform that may include personal data (e.g., text, images, photographs, messages, comments, feedback and correspondence), such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our Site, receive customer support or otherwise correspond with us.
  • Financial Data: Information such as bank account details, payment card information, and information from credit reference agencies, including similar data defined in Cal. Civ. Code § 1798.80(e).
  • Commercial Data: Information from transactions and purchases you make through the Site, registrations  through our Site, and billing details.
  • Device/Network Data: Information regarding your interaction with a website, application, or advertisement (e.g., IP Address, MAC Address, SSIDs, etc.), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, cookie data, web beacons, and information about how you use our Site and interact with us.
  • Inference Data: Data such as your preferences for receiving marketing communications and details about how you engage with them, as well as information relating to your demographics and interests.
  • Audio/Visual Data: Recordings such as audio files and records (e.g., voice mails, call recordings, and the like).
  • Protected Class Data: Characteristics of protected classifications under California or federal law (e.g., race, national origin, religion, gender, and sexual orientation).
  • Special Category Data: Personal data subject to GDPR and similar laws revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

How We Collect Personal Information

Information you give us

You may give us personal information when register for the Platform or otherwise submit information to use through the Services or other communications with us. For example:

  • We may collect Identity Data, Professional/Biographical Data, and Content when you create a profile on our Site (“Profile Data”).
  • We may collect Commercial Data, Identity Data, and Financial Data when you enter into a commercial transaction or register for an event (“Transaction Data”).
  • We may collect Identity Data, Professional/Biographical Data, Content, Government ID, Protected Class Data, or Special Category Data when you submit an application to one of our programs (“Application Data”).

Event Recordings

As part of our Services, we host, coordinate, and operate community  public or private events (“Events“) where you may engage with founders, teams, sponsors, investors, and other Federato community members. We may create audio or visual recordings of these events, take photographs, conduct interviews or surveys, or conduct similar activities at these Events (“Event Recordings“), and we will collect and process, Audio/Visual Data incorporated into these Event Recordings. You may object to the processing of your personal information in connection with Event Recordings during the Event by speaking with organizers of the Event, or afterwards, by contacting us using the information below. Please note, the processing of personal information in connection with Event Recordings may be subject to additional terms and conditions to which you are a party (e.g. a release or consent) that will supersede the nature of processing or individual rights described in this Privacy Policy to the extent in conflict.

Information from Social Networking Sites

Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS“). If you connect to a SNS through our Site you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Privacy Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information automatically collected

We may automatically collect personal information such as Device/Network Data when you access and use our Site. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section below for more details.

Changes to your personal information

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by emailing us at contact@federato.ai

How We Use Your Information

To provide the Services you request

If you use our Site, sign up for, or request to participate in a particular Service, we will process your personal information you give us or that we receive from relevant parties as necessary or appropriate for us to provide that Service. For example, we may process your personal information as follows:

  • We process Device/Network Data to operate, maintain, administer and improve our Site;
  • We process Profile Data, Transaction Data, and Application Data to create, manage, and communicate with you regarding an account you may have on our Services, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
  • We process Profile Data, Transaction Data, and Application Data, Inference Data and other personal information to better understand your needs and interests, and personalize your experience with the Services; and
  • We process personal information related to support and maintenance for our Services that you may request.

In connection with marketing communications

If you request information from us, register on our Site, or participate in our surveys, promotions or events, where allowed by law, we or our third party partners, mentors, may use your personal information, such as Identity Data and Contact Data, as well as Inference Data or Profile Data, to send you updates, newsletters, surveys, offers, and other promotional materials, including communications that may be targeted to you based on your personal information, as permitted by law. You will have the ability to opt out of such communications.

Cookies and Similar Technologies

What are cookies and similar technologies?

We may collect personal information using “cookies“.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites or online services.

For online advertising

We use may use Device/Network Data and Inference Data we collect from cookies and similar technologies in order to market certain products and services to you, such as Events you may be interested in. For example, if you attend an Event, we may use your personal data in connection with online advertising campaigns on Google, Facebook, Instagram and LinkedIn. We, or our third party advertising partners, may combine this information in order to create profiles that are used to make more relevant profiles. You can control how these third parties use your data, and the ads you see on these platforms, using the tools described in the Your Rights and Choices section below.

With your consent

We may use or share your personal information with your consent, such as when you: consent to participate in additional surveys on gender and race/ethnicity (where legally permissible), let us post your testimonials or endorsements on our Sites, instruct us to take a specific action with respect to your personal information, or opt into third party marketing communications.

Please note, in certain cases (such as in connection with our Diversity & Inclusion efforts), we may collect and share with parties you authorize, information about race, ethnic origin, religious beliefs, physical/mental health, sexual orientation, or other personal information that is classified as a “special category” of personal data under applicable law. You may revoke your consent to this processing at any time. Additional information regarding these programs, how your personal information will be shared, and the parties that may receive it, are available within program descriptions we provided at the time you agreed to participate in the program.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To create aggregated or de-identified information

We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.

Miscellaneous processing

If we process personal information in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.

Note that we may, without your consent, also process your personal information on certain public interest grounds. For example, we may process personal information as necessary to fulfill our legal obligations, to protect the vital interests of any individual, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose personal information in extraordinary circumstances.

Data sale

Generally, we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to third parties in exchange for monetary or other valuable consideration. Note, however, we may make any disclosure or otherwise process personal information in connection with our provision of the Services to you or at your request, and we make any of the disclosures described in the Data Sharing section below.

How We Share Your Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We generally disclose personal information to third parties for the following purposes:

  • Partners, Mentors and User Groups. We may disclose your personal information to our partners, mentors, and other groups with whom we have contracted to sponsor and deliver industry-focused Programs, and to other users of our Services, for the purpose of providing our products and services, including sharing with other members of the groups for which you are registered.
  • Affiliates. We may disclose your personal information to our parent company, subsidiaries, joint ventures, or other corporate affiliates for purposes consistent with this Privacy Policy.  
  • Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
  • Compliance with Laws and Law Enforcement; Protection and Safety. We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, which may include your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
  • Service Providers & Business Purposes. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, email delivery and database management services). We may also disclose your data in connection with certain other business and operational purposes, such as data security monitoring, service analytics, internal research, quality control, etc. We generally share your personal data as you request, or in accordance with certain business purposes. When we disclose information for business purposes (e.g., where we disclose information as part of our own internal operations, such as security operations, internal research, etc.), we may disclose the following categories of information: Identity Data, Contact Data, Content, Financial Data, Professional/Biographical Data, Commercial Data, Device/Network Data, Inference Data, Audio/Visual Data,  Protected Class Data.

Your Rights and Choices

  • Access, update, correct or delete your information. All account holders may review, update, correct or delete the personal information by emailing us at contact@federato.ai.
  • Email communications. You may opt out of newsletters and marketing-related emails from us by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at contact@federato.ai.
  • Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at contact@federato.ai.
  • Choosing not to share your personal information.
  • Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
  • Uninstalling our applications. You can stop all collection of information by the application(s) by uninstalling the application(s).
  • Cookies and similar technologies. You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies or similar technologies, you may not be able to use certain features or services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
  • Do Not Track Signals. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
  • Google Analytics. You must opt out of other third party technologies directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Other Sites and Services

Our Site may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User Generated Content

We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will post an updated version of the Privacy Policy on our Site.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal information in which case we may use this information indefinitely without further notice to you.

Children’s Privacy

Our Products and Services are not directed to children under the age of 13, and we do not intentionally gather personal information from visitors who are under the age of 13, without their parental or guardian’s consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the contact information provided below. We will delete such information from our files as soon as reasonably practicable.

Information for California Residents

Your California privacy rights

If you are a California resident, you have the following rights:

  • Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months:
  • The categories of personal information that we have collected about you;
  • The categories of sources from which personal information is collected;
  • The business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share your personal information;
  • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and
  • Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipients.
  • Access. To request a copy of the personal information that we have collected about you during the past 12 months.
  • Deletion. To request that we delete personal information about you that we have collected from you.
  • Non-Discrimination. You have the right not to be discriminated against with respect to the quality or level of services we provide as a consequence of your exercise of your rights under CCPA.
  • Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.

Exercising your California privacy rights

To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us please contact us at contact@federato.ai

We will request that you provide information necessary to verify your identity. That information may vary based on the context and scope of your request. For example, we may require you to verify access to an email address, or provide other forms of identification appropriate to the request. We may require agents submitting a request on your behalf to provide proof of agency in order to respond to a request.

Personal information that we collect, use and share

The chart below summarizes the categories of personal information that we have collected, used and shared in the 12 months preceding the last update of this Privacy Policy. See Information We Collect and Receive for a description of the categories and sources of the personal information we collect and How We Use Your Information for a description of the business and commercial purposes for which we collect, use and share this information.

For Users in the EEA:
International Data Transfers

Federato Technologies, Inc. is headquartered in the United States. Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our partners, affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information
  • Delete.  Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.  

You can submit these requests by email to contact@federato.ai or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

  • Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
  • Binding Corporate Rules that have been approved by the European Commission and deemed to ensure that a given processor or controller provides adequate protection of data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, including the then-current transfer basis used to authorize transfers to specific third parties.

Contact Us

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at contact@federato.ai, or write to us at:

Federato Technologies, Inc.
320 High Street
Palo Alto, CA   94301