Privacy Policy

Last Updated: August 27, 2019

This Privacy Policy is for Geigsen services, our technology product Adaptive, and the websites associated with them as defined below.

Geigsen, LLC (“Geigsen”, “we”, or “us”) is a New York, USA, limited liability company. Geigsen adopted this Privacy Policy to make it easy for you to understand what sorts of information Geigsen collects and how we use that information. Please read our Privacy Policy carefully prior to using our Services (as defined below), and/or submitting information through the Site or the Platform. If you do not consent to or understand all of the provisions of our Privacy Policy, you are not authorized to use the Site or the Platform, and you should stop using the Site and the Platform.

Our Platform (as defined below) is intended for use by organizations and, in order to work properly, requires Geigsen to collect and process certain data about the organization and its employees. If you are purchasing Services on behalf of an organization, you warrant and represent that: (a) you have all necessary right and authority to agree to this Privacy Policy on your organization’s behalf, and (b) you have all consent and authority required by law to disclose and use the personal information of your employees and contractors participating in the Services (as defined below). 

IF YOU ARE AN EMPLOYEE OR CONTRACTOR OF AN ORGANIZATION THAT USES GEIGSEN’S SERVICES, PLEASE BE ADVISED THAT GEIGSEN DOES NOT HAVE CONTROL OVER HOW YOUR EMPLOYER CHOOSES TO USE PERSONAL INFORMATION YOU HAVE DISCLOSED TO THEM, AND THIS PRIVACY POLICY ONLY COVERS WHAT GEIGSEN DOES WITH YOUR INFORMATION IF DISCLOSED TO US BY YOU OR YOUR EMPLOYER. If you have questions about your rights with respect to personal information held by your employer, you should contact your employer directly.

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Scope

This Privacy Policy discloses information that we collect and use in the course of our business by automated means and when you access the website at the domain geigsen.com and adaptive.team (the “Site”), our associated application, AdaptiveTM (the “Platform”), and any service offerings made available through the Site and the Platform (collectively, the “Services”). By providing information through the Site, the Platform, or the Services, you acknowledge that such information is governed by this Privacy Policy.

For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (“GDPR”) or any subsequent amendment or replacement or supplementary legislation (together “Data Protection Law”), the data controller is Geigsen, LLC, whose primary business address is at: 

31-57 31st Street, #412 

Long Island City, NY 11106 

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Types of Data & Legal Basis for Processing

Our Services provide you with tools to manage and align organization-level strategy with individual goals. To provide those Services, we collect and use the following information about you through our Platform and our Site:

• Personal Data, which we define as any data that can be used to identify you on its own. Personal Data we collect includes your first name, last name, email address, workspace (e.g., Slack) username, and any other personally identifiable information you might include in communications with us.

• Organization Data, which we define as information provided by an organizational client, including how our Platform is used by your organization. Organization Data we collect includes your company’s name and the names of certain employees or contractors using our Services, the organization’s overarching strategies and goals, as well as metrics and usage data unique to your organization. 

• Feedback Data, which we define as qualitative information about an employee’s or contractor’s steps toward achieving their employer’s strategies and goals.

• Anonymous Data, which we define as information that does not personally identify you on its own but could be combined with other information to identify you.  

We use Personal Data, Organization Data, Feedback Data, and Anonymous Data in conformance with this Privacy Policy in order to provide you with access to our Site, Platform, and Services in a reliable and secure manner. We also collect and use Personal Data, Organization Data, Feedback Data, and Anonymous Data:

• For our legitimate business needs.

• To fulfil our contractual obligations to you.

• To comply with our legal obligations.

To the extent we process your Personal Data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.

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Information We Collect

We collect Personal Data, Organization Data, Feedback Data, and Anonymous Data in the following ways:

• When you voluntarily give us information. For example, you may provide us information by filling in forms on our Site or on the Platform, or by corresponding with us by email or otherwise. This includes Personal Data you provide when you register to use our Services, sign up for our newsletter, take part in a survey or promotion, or report a problem with our Services. We may ask for Personal Data such as your name, email address, phone number, company name, job title, organizational offerings, and work-related actions and tasks when you use our Site or Platform. 

• When provided by your employer. For example, your employer or contractor may provide us Personal Data and Organization Data such as your name, enterprise-software username, Slack workspace credentials, and other information about you so that our Platform works properly for the organization.

• When you use our Services. We automatically collect Organization Data, Feedback Data, and Anonymous Data about how you interact with our Services and Sites, including:

• Device information, such as your hardware and operating system.

• Log information, or information that our servers automatically generate when you use our Services. Log information includes information like your search queries, your IP address, browser type, hardware settings, and browser language.

• Location information, which may be derived by our service providers from your IP address, Wi-Fi access point, and/or cell tower.

• Your workspace username, which our Platform may cache to improve Platform performance.

• From our service providers. Our hosting providers will give us access to certain Anonymous Data about how you interact with our Site and Platform. For instance, Squarespace, our web host, gives us analytics about how many visits there are to our Site each day, where those visits originate, and general location information based on your IP address.

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Cookies

We use cookies, beacons, or similar technologies on our Site to measure inbound traffic and understand how our Site is used and what’s driving traffic to our Site.

 

How We Use Your Information:

Personal Data

When you provide Personal Data to us, we use it to provide you with access to the requested Services, content, or information. We may also use your Personal Data to:

• Carry out our obligations arising from any contracts entered into between you, your employer, and us.

• Provide technical administration and customer support.

• Respond to your inquiries.

• Send important notices, such as communications about purchases and changes to our terms, conditions, and policies.

• Deliver products and services you purchase or request.

• Provide you with the information, products and services that you request from us.

• Provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.

• Notify you about changes to our Site, Platform, or Services.

• Ensure that the Platform is presented in the most effective manner for you.

• Inform you about scheduled Site and Platform downtimes and new features.

• Allow you to participate in interactive features of our Site and Platform when you choose to do so.

• Keep our Services safe and secure.

• Enforce legal agreements that we’ve executed with you.

• Protect against or identify fraudulent transactions.
   

Organization & Feedback Data

We use Organization Data and Feedback Data to provide Services to you and your employer. We do not aggregate this data; however, we may use Organization Data specific to your organization to measure trends and behavior in connection with our Platform and improve the Services provided to you.
 

Anonymous Data

We collect, analyze and use Anonymous Data to help us provide you with a better user experience. For example, we keep track of how often or how many times an organization provides feedback on our Platform. When we use Anonymous Data, we do so in a way that keeps your Personal Data anonymous. By way of example, we use Anonymous Data to:

• Analyze our audience size and usage patterns.

• Develop, deliver, and improve our Services.
   

Information From Other Sources

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
 

Disclosure of Your Information

Geigsen is not in the business of sharing or selling Personal Data. We consider this information to be a vital part of our relationship with you. However, in addition to specific consent provided by you, there are certain circumstances in which we may share Personal Data, Organization Data, and Feedback Data with third parties without further notice to you, as set forth below:

• Business Transfers. As we develop our business, we may buy, sell or reorganize businesses or assets. In the event of such sale, merger, reorganization, dissolution or similar event, data we collect may be part of the transferred assets.

• Affiliated Companies. We may also share data with our subsidiaries, affiliates and other related companies for purposes consistent with this Privacy Policy and providing you with the Services.

• Agents, Consultants and Service Providers. Geigsen, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we only allow them to process that information for the purposes the information was collected.

• To Provide You Services. Our Platform, by its nature, shares Personal Data, Organization Data, and Feedback Data between employers and their employees or contractors. This is core to the Platform, and we cannot provide the Services without disclosing this data.

• Legal Requirements. Geigsen may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) enforce, protect or defend the rights or property of Geigsen our customers, or others; (iii) act in urgent circumstances to protect the personal safety of users of this Site or the public; or (iv) protect against legal liability; (v) to enforce or apply our legal  agreements; (vi) for fraud prevention; or (vii) credit risk reduction.

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Special Notification for California Residents – Your Privacy Rights

Under California law going into effect as of January 1, 2020, California residents have the right:

• to know what Personal Data is being collected about them.

• to know whether their Personal Data is sold or disclosed and to whom.

• to say no to the sale of Personal Data.

• to access their Personal Data.

• to equal service and price, even if they exercise their privacy rights.

You can make a request in relation to any of the above rights by contacting us as set out at the end of this Privacy Policy. 

Individuals who are residents of California and have provided their Personal Data to us may request information regarding our disclosures, if any, of their Personal Data to third parties for direct marketing purposes. Such requests must be submitted at the contact details at the end of this Privacy Policy. Such requests must include the reference “Request for California Privacy Information” in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.
 

Special Notification for European Union Residents – Your Rights

You have the right under Data Protection Law, free of charge, to request:

• Access to your Personal Data.

• Rectification or deletion of your Personal Data.

• A restriction on the processing of your Personal Data.

• Object to the processing of your Personal Data.

• A transfer of your Personal Data (data portability).

You can make a request in relation to any of the above rights by contacting us as set out at the end of this Privacy Policy. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of Data Protection Law. 

You have the right to withdraw your consent to us processing your Personal Data, at any time, by ceasing to use the Platform and making a written request to have your Personal Data deleted.

We may send notifications from time to time in order to update you about any Services, events, and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
 

Storage of Personal Data

We store Personal Data we collect on encrypted servers hosted by Amazon Web Services at their Virginia, US, Data Center and on cloud-based servers using Microsoft OneDrive. Any data we store on servers is encrypted at rest and delivered over encrypted communication systems. 

The data that we collect is transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It is also processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. Such staff or subcontractors maybe engaged in, among other things, the fulfilment of Services or the provision of associated support services. By submitting your Personal Data, you agree to this transfer, storing or processing outside of the EEA. 

Our Site is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site from outside the EEA. This means that where you chose to post your data on our Site, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose. Our infrastructure configuration scripts are available for audit upon written request.
 

Protection of Your Information

All information you provide to us is stored on our secure servers hosted by Amazon Web Services and on cloud-based servers using Microsoft OneDrive. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site or Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your Personal Data, we cannot guarantee the security of your data transmitted via our Platform or Site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
 

Links to Other Websites

Our Site or Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

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Data Retention

We retain Personal Data, Organization Data, and Feedback Data for as long as necessary for the relevant activity for which it was provided or collected, but in no event longer than 18 months after we receive it. This will be for as long as we provide access to the Platform to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the Platform for the purposes set out below.

After you have closed your account or ceased using the Platform we usually delete Personal Data, however we may retain Personal Data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, and enforce our legal agreements. We may keep Anonymous Data in aggregated form indefinitely.

Please note: After you have closed your account or deleted information from your account, any information you have shared with others on the Platform will remain visible. We do not control data that other users may have copied from the Site or Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

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Age of Users

This Site and the Services are not intended for and shall not be used by anyone under the age of 18. We do not knowingly collect information about persons under 18 years old. If you are the parent or guardian of someone under 18, and you believe that we have collected or processed data regarding your child, please contact us at the details below.

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Customer Support

If you have questions, comments or concerns about this Policy or Geigsen’s compliance with the Data Protection Law, please contact Geigsen at:

Geigsen, LLC

1239 Broadway, Suite 1003

New York City,

NY 10001

E-mail: contactus@geigsen.com