GDPR Data Protection Officer:
The purpose of this policy is to explain how we ensure your privacy, what steps we take to prevent and mitigate the compromise of private information, what kinds of information we collect from you, what we do with that information, and how you may exercise certain of your rights under applicable data privacy laws related to that information. This policy identifies our data protection officer, and provides you with the information that you may need to contact our data protection officer.
The Company’s GDPR Data Protection Officer is Maximillian Peters (the “Protection Officer”). The Protection Officer may be contacted via email at firstname.lastname@example.org, or by writing to us at:
ATTN: GDPR Data Protection Officer
1775 Tysons Boulevard, Suite 1450
22102 McLean, VA
You may complain to the GDPR Protection Officer if you think there is a problem with the way we are handling your data. You may also contact the GDPR Protection Officer in order to exercise any of your rights, including your “right to be forgotten,” under the GDPR.
Any information that you enter into any text field on the Website will be collected by the Company for internal use except where noted otherwise in this notice. Because the Website is a platform service, any text, reviews, images, video, links, files of any type, or any other content, including subscriptions, events that are created and invitations to events, invitations to other persons to use the Website including invitations extended via the Third-Party Platforms as further defined below, other communications made via the Third-Party Platforms as further defined below whether or not mediated by an API, or any other information or artifice of communication of any kind whatsoever (collectively, and without limiting the generality of the foregoing, “Content”) that you post onto the Website will be collected for purposes of showing that Content to other users. Where the Website so states, Content may be limited only to those users that you designate through invitations or through other direct communications, including the chat functionality that we provide. Content that is transmitted via Third-Party Platforms is collected and processed as described below. Content that you send through our native chat functions or other inter-user communications tools, or that you input to the Website or transmit via the Website in any form may be collected. Content that you post to the Website may be visible to all or some other users, and to the Company, depending upon your privacy settings. We also collect, store, and process any information, whether or not constituting Content, that you submit to the Company in any form, including via email. We collect, store, and process any information that is sent to our GDPR Compliance Officer, as further defined below, for purposes of complying with the actual or stated intent of any requests received that are within the responsibilities of the GDPR Compliance Officer, and for internal purposes including tracking the frequency of different GDPR requests and ensuring the suitability of internal compliance protocols.
Please click on “Settings” in our application to review your privacy settings.
Information that you enter into the Website at the point of account creation will be stored by us and used to create a customer profile for you, except that we do not store passwords locally. If you lose your password, you may request a password reset. We cannot provide you with your current password because we do not know it.
If you delete your account, the company may retain your profile information for future use, including for counting the number of customer accounts that have been deactivated.
We also collect information about your uses of the Website. This includes information about the other users with whom you connect or share Content, including that Content itself. This may include information about you supplied by other users. For example, if another user posts Content to your profile and you view or engage with that Content, we will collect that information both as to the Content and to your viewing of, or other engagement with, the Content.
We also collect information about the Content that you view while using the Website. We collect information about how long you use the Website. We may collect certain non-personal information about your Website usage, such as an IP address or similar information. Please see below for more information about the kinds of non non-personal information that we collect about you.
If you make any purchases through the Website or purchase any of our products or services, we will collect your payment information for purposes of completing that transaction and maintaining a customer profile for you.
If we choose to display promotional content or advertisements, we may use information about the kinds of Content that you view, and your own Content, to determine the advertising experience that is most relevant to your interests.
The principal service of the Company is to provide a platform for your engagement with certain third parties, which may be your members, marketing contacts, employees, or any other such third parties, however styled (altogether, your “Affiliates”). For all such uses, the Website is a “platform” within the applicable data privacy and communications-related laws of the United States and the European Union.
The Website integrates with several third-party platforms. Any use of those platforms via the Website is subject to the terms and conditions of those platforms. You may find the complete list of our integrated partner platforms here: integrations
All persons other than the Company listed at the above URL are “Third-Party Platforms.”
To the extent that they receive any information from you on account of your use of the Website (including use of the Website or a Third-Party Platforms mediated by an API), all such Third-Party Platforms are third parties within the meaning of the GDPR.
The Company collects certain non-personal information about you. By “non-personal information,” we mean information about you that cannot be used, and is not stored, in a way that can identify you personally. This information may also be known as “pseudonymous” information.
The Website will collect information about your location based on your IP address. An IP address is a user-supplied identifier that allows the Company to know, in general terms, where its users are located. An IP address is not the same as a physical address, and is not the same as either your shipping address or your billing address, if applicable.
The Company uses your IP address for internal purposes such as knowing which countries provide certain percentages of its users. The Company does not distribute your IP address to any other person. The Company does not verify your IP address or connect it to your shipping or billing address for purposes of checkout if you purchase any products or services from us. Your IP address is not and cannot be used by the Company to identify you personally. The Company’s web host will also know your IP address for purposes of logging visits to the Website from your IP address and for preventing distributed denial-of-service attacks, which are disruptive attacks on websites caused by very large numbers of simultaneous visits to the Website.
The Company collects information about users such as the number of users visiting the Website at any given time, the times during which visitors visit the Website, the length of time that users use the Website, which pages they visit, which products they order, and what other actions they take while using the Website. This information is collected by the Website and is provided in an anonymized form to the Company’s data analytics provider, which is Google Analytics (the “Data Analytics Provider”). This information is used by the Company to track the engagement, general geographic origin, and headcount of its users. This information is combined together to provide general demographic information on the Website’s users. This information is not and cannot be used to identify you specifically.
The Data Analytics Provider is a third-party processor for purposes of the GDPR.
The Company provides opt-in functionality that allows you to look up and connect with other users via the Website. Your ability to look up other users, and to be looked up by other users, is subject to your manually opting in to visibility to other users. If you so opt, you represent and warrant that you consent to the public display of certain of your account information including your name and contact information, that you consent to the Company’s allowing any Website user to look up that information through a text field search tool, that you consent to the Company’s using auto-complete or other suggestive fill-in information to collect and transmit certain of your profile information including your name and contact information to other users, and that you expressly indemnify and hold harmless the Company for any use or misuse of such functionality. Look-up functionality and your consent to the public display of any of your profile information anywhere on the Website is at your own risk. All Website functionality is “as-is.” We do not make any representations or warranties to any person, including you, as to the accuracy or completeness of any information, whether or not construed as Content, that you transmit to us or that you post to the Website or transmit via the Website or a Third-Party Platform.
The Company’s Third-Party Platforms may include payment processing tools or merchant services providers (all such payment platforms, without limiting the generality of the foregoing, “Merchants”). The use of any Merchant is subject to the terms of service and privacy policies of that Merchant. The Company does not collect or store payment information except for the express and limited purpose of verifying submitted payment information to enable checkout. The Company does not store your credit card information or other information, including any of your native login credentials to a Merchant.
Any payment information that is transmitted to us through the Website is transmitted via a token system. Payment information is reduced to a pseudonymous token, transmitted to the Merchant, who confirms to us whether or not payment is successful. The Company collects and processes information related to the success or failure of payments for the purpose of effectuating fulfillment of any order or purchase, and where applicable, will also collect and process information related to your shipping or billing address for the express and limited purpose of verifying successful payment and effectuating fulfillment of any order or purchase (such information shall be deemed Content hereunder).
The Company cannot remind you of lost or forgotten payment information because the Company does not know it.
If we elect to provide promotional content or advertising, we may share information about the kinds of Content that you post and use, information related to your general geographic location as we infer it from your IP address, and other information that you supply to the Website to ensure that promotional content or advertisements are relevant to your interests.
We do not share your information with third-parties except to the express and limited extent that your use of a Third-Party Platform, via an API or otherwise, may necessitate the sharing of certain of your information (such as your IP address) via the Third-Party Platform’s API. If you use the Website to schedule conferences, meetings, video or audio calls, or any other communication, where such communication takes place via a Third-Party Platform, such information may be accessible to the Company. The Company does not record, store, or otherwise process audio or video calls, or similar meetings, except to the express and limited extent that the Company may process information of a general nature about such calls including the time and date of such calls, participants invited to such calls or meetings, the duration of such calls or meetings, and other information native to the call or meeting event having no relation to the content (whether or not constituting Content) of such calls or meetings.
We will also respond to a valid subpoena or other valid governmental requests for information. If we receive a valid subpoena or other valid governmental request for information about you, we may not disclose this request to you.
If we elect to provide for integration with other third-party apps or other services with the Website, we may share your Content or other information with those third-party apps or other services depending on their own terms and conditions. We will not share your information with any third-party apps or other services without first informing you.
If we have a good-faith belief that a user has posted Content or otherwise used the Website in a way that makes us believe that a user has engaged, or is about to engage, in criminal activity or other serious wrongdoing, we may share that information with the relevant authorities. If we do so, we may not inform you when we share that information.
Nothing in this notice should be construed as amending, modifying, replacing, or otherwise affecting the terms and conditions of any transactions between you and the Company, except that to the extent any such terms and conditions are inconsistent with the General Data Protection Regulations of the European Union and the equivalent rules of the United Kingdom and any other applicable jurisdiction (altogether, the “GDPR”) those terms and conditions are VOID.
Instructions For Exercising Your Right To Instruct Us To Forget Your Information
The GDPR provides a generalized “right to be forgotten,” meaning that you have the right to instruct us to delete any and all information that the Company, the Website, or any of the third parties collects about you. Please contact us by email at email@example.com, by phone at in order to instruct us to forget any or all of the information that the Company, the Website, or any of the third parties collects about you. You may delete your profile entirely in the application settings. This withdraws your consent from our policies. Per the GDPR, we may take up to 24 hours to process any withdrawn consent. You may download a copy of the personal data you have provided through the controller in the settings. Any further subject access requests must be directed via email to firstname.lastname@example.org.
We will follow instructions received from you pertaining to your rights under the GDPR or any other similar law. You are a “Data Controller” within the meaning of the GDPR. With respect to personal data, we follow instructions that we receive from you, including your instruction to provide you with a machine-readable copy of all information about you that we store or process, and including your instruction to us to “forget” such information, unless those instructions are (i) legally prohibited or (ii) require material changes to the Software. In addition, we will reasonably support any Data Controller in addressing requests from other Data Controllers or regulatory authorities regarding our processing of personal data. If we cannot comply with an instruction or if there is a user-billable cost to comply with the instruction, we will promptly notify you.
To process personal data, we and our sub-processors will only use personnel who are bound to observe data secrecy under the Data Protection Law. We will use the appropriate technical and organizational measures to meet this objective. The current version of our Data Breach Response Policy can be found here.
At signup, each user will be prompted to consent to the Data Controller’s policy, which might have been set up and customized by each client in the Admin Settings. We record the date/time when the consent was given, and for TOS/Privacy consent we restrict any access unless consent was given. The option to withdraw consent is entailed in the option to delete the user profile.
Breach of Data Security Protocol:
Slayte’s Data Breach Response Policy is contained here: Data Breach Response Policy. Our Data Breach Response Policy shall be deemed to fully integrate the Model Clauses of the GDPR related to data breaches and data breach responses.