CHIEF.IO - Privacy Policy Last Updated: October 16, 2018
This privacy policy (“Privacy Policy”) describes the collection, use, and disclosure of personal information by chief.io (“Company”, “we”, “us”, or “our”) from users that access our website located at http://chief.io and our Services. This Privacy Policy does not apply to any Third Party websites, services or applications, even if they are accessible through our Services.

By using our Services, you consent to the collection, use, and disclosure of Personal Information (as defined below) in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into Terms of Service chief.io/terms (the “Terms”) and subject to the provisions of the Terms. All other terms not defined herein will have the meanings set forth in the Terms.

1. Revisions to this Privacy Policy. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective.

2. Scope. This Privacy Policy applies to Personal Information that is Processed (as defined below) by us in the course of our business, including on our Services. All individuals whose responsibilities include the Processing of Personal Information on behalf of us are expected to protect that data by adherence to this Privacy Policy.

3. Transparency/Notice: Types of Personal Information We Collect and How We Use It. The types of Personal Information we may collect (directly from you or from Third Party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. We collect Personal Information regarding its current, prospective, and former Members, customers, visitors, and guests (collectively “Individuals”).

4. Types of Personal Information We Collects

• Account Creation. When you create an Account or use the Services, we may collect the following types of information, including but not limited to: your name, phone number, and email.

• Account Registration. During Account registration, you will need to use your login credentials using a Social Networking Service (“SNS”) Account (LinkedIn), we may be able to access and collect your name, email address and other information (such as gender and date of birth) that your privacy settings and/or the privacy policy on the applicable SNS Account may permit us to access. We will obtain from your existing SNS Account certain information such as your user name, profile photo, and other personal information we may obtain (but to the extent that your SNS Account privacy settings permit us to access such information).

• Identity Verification. We may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity, source of funds, and address, and/or to manage risk as required under applicable law. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information.

• Communications with Us. Whenever you contact us or respond to our communications (e.g., email, telephone, written), we receive your contact information and any other personal information you choose to provide us.

• Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, details about your browser or device, geo-location information, Internet service provider, pages that you visit before and after using the Services, and other information about how you use the Services.

• Information from Other Sources. We may obtain information about you from third-party sources as required or permitted by applicable law, such as public databases, credit bureaus and ID verification partners.

• Identity. We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.

• Interactive Features. Our Services contain interactive functionality that allows you to engage with other users on the Services. If you use any interactive functionality on our Services that request or permit you to provide us with Personal Information (including, for example, any Services that allow you to engage with any other User to request information about enterprise software), we collect the Personal Information that you provide to us in the course of using these interactive features. If you choose to submit content to any public area of the Service, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

5. How We Use Your Information

• To Provide the Services or Information Requested including to:
o Generally manage your Account;
o Provide a personalized experience and implement the preferences you request;
o Process transactions and send you notices about your transactions;
o Provide customer support.

• Administrative Purposes including to:
o Resolve disputes, collect fees and troubleshoot problems;
o Ensure quality control and staff training;
o Verify your identity by comparing your Personal Information against third-party databases;
o Send administrative or account-related information to you;
o Enhance security, monitor and verify service access, combat spam or other malware or security risks;
o Measure interest in the Services;
o Improve the Services;
o Develop new products and Services;
o Enforce our agreements with third-parties
o Prevent potentially prohibited or illegal activities;
o Enforce our Terms.

• Marketing our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or services. We may provide you with these materials by email or through the functionality of the Services, as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide services to you and our sponsors;
o For other purposes disclosed at the time when Individuals provide Personal Information; and
o Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.

• Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and services.

• Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within us and with Third Parties for our or their purposes in an anonymized or aggregated form designed to prevent anyone from identifying you.

• Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

6. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Services, applications, messaging, and tools, and to recognize you across all relevant devices.
• Cookies. Cookies are small text files placed in visitors’ devices to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, some features of the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site or the App that collects information about users’ engagement with the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Web Analytics Service Providers

We may use analytics service providers to collect information regarding visitor behavior and visitor demographics. We use information to help determine how to improve our Services, gauge user experience and response to changes in our Services, to develop content, and for internal research purposes. Google Analytics. We may use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:
• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Services, applications, and tools. This includes technologies that allow you access to our Services, applications, and tools; that are required to identify irregular services behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, Services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Services, applications, or tools. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content;
• Advertising or Targeting Related. We may use first-party or Third Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services, or on Third Party websites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. Please note however that certain functionality of the Services may not be available or function properly if you opt out of certain Technology uses.

7. Third Party Websites Our Service may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

8. Onward Transfer - We May Disclose Your Information • Information We Share. We may share your information as described in this Privacy Policy (e.g., with our Third Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. • Payment Processing. When you make a payment, the third-party payment processor (e.g., Stripe Connect) receives your full payment information and we receive only a funding confirmation. chief.io has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. • We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. We have executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. • Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with us. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them. • Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) disclose your Personal Information in good faith where it is otherwise necessary or advisable. • Security Reasons. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

9. International Data Transfers. You agree that all Personal Information collected via or by us may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States, the European Union, Australia, Singapore, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you explicitly consent to the storage of your Personal Information in these locations. 10. Opt-Out (Right to Object to Processing) • General. You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to our Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us as described below. • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). • Do-not-call and do-not-mail. We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

11. “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

12. Cookies and Interest-Based Advertising. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. See http://www.networkadvertising.org/mobile-choice. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our Third Party advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, http://youradchoices.ca/choices/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here. To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. Even if you opt out, we may still collect and use information regarding your activities in connection with your use of the Services (through the Site or App or otherwise) and/or information from the advertisements on Third Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

13. Rights of Access. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your portable personal information, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction of inaccurate, untrue or incomplete personal information; and (vi) request erasure of personal information held about you by Teatime Games, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at the email address set forth below.

14. Data Retention. We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

15. Security of Your Information. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by making a notice available to you through the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.

16. International Users. By using the Services, we will transfer data to the United States and other global jurisdictions. By choosing to use the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of California, United States and the adjudication of any disputes arising in connection with the Services will be in accordance with the Terms. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Privacy Policy.

17. Updates to this Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

18. California Privacy Rights. California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, we do not share Personal Information with Third Parties for their own marketing purposes.

19. Definitions. The following capitalized terms will have the meanings herein as set forth below. • “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, us or to which we disclose Personal Information for use on its behalf. • “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”). • “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. • “Third Party” is any company, natural or legal person, public authority, agency, or body other than you, us or our Agents.

20. Contact Us. If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to us at legal@chief.io.