First Round Technology, the company behind Prosus.ai, collects informationfrom multiple sources, including various websites hosted by or affiliated with First Round Technology (each a “Website” and collectively, the “Websites”) and various software products and services offered by First Round Technology (the “Software”). The Websites and the Software are referred to collectively in this Policy as the “Offerings”.
This Policy provides you with information concerning our practices and procedures as they relate specifically to information we collect via any Offering that incorporates this Policy. By using such Offering, you are accepting the practices described in this Policy. We may occasionally update this Policy to reflect changes in our practices. When we post modifications to this Policy, we will revise the “Last Revised” date at the bottom of this web page. The modified Policy will be effective immediately upon posting on the Website. Your continued use of the Offering after the posting of the modified Policy constitutes your agreement to abide and be bound by it. If we make any material changes we will notify you by email (sent to the e-mail address as provided by you) or by means of a notice onthis Website prior to the change becoming effective and we will update theeffective date accordingly. We encourage you to periodically review this page for the latest information on our privacy practices. If you object to any modification, your sole recourse is to stop using the Offering.
We’ll ask for your consent before using your information for a purpose thatisn’t covered in this Policy. You may, of course, decline to share certain Personal Information with First Round Technology, in which case First Round Technology may not be able to provide to you some of the features and functionality found on the Offerings.
First Round Technology collects information from multiple sources, including the various Offerings. Some of this information can be used to identify you or another identified or identifiable natural person or other data subject (“Personal Information”). Other information is aggregated, anonymized, or otherwise not immediately usable to identify you or another natural person or data subject (“Anonymous Information”). Personal Information and Anonymous Information are collectively referred to as “Customer Information” in this Policy.
We collect information about the apps, browsers, and devices you use to access our Websites and Offerings or open one of our HTML emails by using different types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include Internet Protocol address (also known as “IP address”) or other device address or ID, web browser or device type, the web pages or sites that you visit just before or just after visiting a Website, the pages you view on a Website, and the dates and times that you visit the Websites.
Cookies and web beacons
We use small text files called cookies to improve the overall Website experience. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Cookies generally do not permit us to personally identify you (except as provided below). We may also use clear GIFs (a.k.a. “Web beacons”) in HTML-based emails sent to our users to track which emails are opened by recipients. This information is collected directly by the third party, and First Round Technology does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s own data collection, use, and disclosure policies.
Types of Cookies
The Websites uses the following types of cookies:
Essential (or “Required”) cookies that are required for providing you with features or services that you have requested. Disabling these cookies may make certain features and services unavailable.
Functional cookies are used to record your choices and settings regarding our Websites, maintain your preferences over time, and recognize you when you return to our Websites. These cookies help us to personalize our content for you, chat with you on the website, and show videos to you.
Performance and analytics cookies
Performance/Analytical cookies allow us to understand how visitors use our Websites by collecting information about the number of visitors to the Website, what pages visitors view on our Website and how long visitors are viewing pages on the Website. Performance and Analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the content for those who engage with our advertising.
Retargeting and advertising cookies
Retargeting and Advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
You can decide whether or not to accept cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies. You can also delete all cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Website functionality might not work.
If you choose to use a Website to purchase goods or services, we collect and process fulfillment data, some of which may be Personal Information. These are required individual details for the establishment, content or alteration of a contract. Which details are required depend on the goods or services you are procuring. The essential details can be identified by the asterisk (*). This includes – depending on the good or service – your name and e-mail address, billing information, company name, tax ID, address and telephone number, user name and password.
The Software may, from time to time, collect usage statistics on your use of and interaction with the Software, in order to further improve your experience with and learning of the Software and First Round Technology’s other products and services. In particular, the collected information is used to improve the usability and effective operation of the Software. The collected usage statistics include statistics on the execution of operators, operators and settings in processes, the selection of actions and navigation between elements in the user interface of the First Round Technology Software.
First Round Technology uses the information we collect for the following purposes:
Maintain and improve our offerings
We use your information to ensure the Offerings are working as intended, such as tracking outages or troubleshooting issues that you report to us. For example, we continuously monitor our products to look for problems. And if we find something wrong with a specific feature, reviewing activity information collected before the problem started allows us to fix things more quickly.
And we use your information to make improvements to the Offerings – for example, to understand and analyze the usage trends of the Software to improve it and build better products. Or it may help us discover that it’s taking users too long to complete a certain task or that they have trouble finishing steps at all. We can then redesign that feature and improve the product for everyone.
Develop new offerings
We use the information we collect in the Offerings to help us create new features and functionality.
Provide personalized services
We use the information we collect to customize the Software for you, including recommending specific next steps for you to take while using the product.
We use data for analytics and measurement to understand how our Offerings are used. For example, we analyze data about your visits to our sites to do things like optimize website design, monitor and analyze the operation and effectiveness of the Website, and monitor aggregate site usage metrics such as total number of visitors and pages viewed. We use a variety of tools to do this, including Google Analytics. Google Analytics relies on first-party cookies, which means the cookies are set by First Round Technology. You can opt-out from Google Analytics by clicking https://tools.google.com/dlpage/gaoptout.
Communicate with you
We use information we collect, like your email address, to interact with you directly. For example, we may email you to let you know about upcoming changes or improvements to the Software; or regarding things you post on the Offerings. And if you contact First Round Technology, we’ll keep a record of your request to help solve any issues you might be facing.
When you’re signed into your Prosus account, you can always review and update information by visiting your First Round Technology account profile.
Removing your information
To delete all of your information, send an email to firstname.lastname@example.org. Once we confirm your identity, we will immediately start the process of removing your data from the product and our systems. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and timeframes in connection with such removal.
There are other ways to control the information First Round Technology collects, including configuring your browser to indicate when First Round Technology has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember, as described above, the First Round Technology Offerings rely on cookies to function properly.
The Offerings contain links to websites and services provided by third parties. Any Personal Information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on the Offerings. We encourage you to learn about third parties’ privacy and security policies before providing them with Personal Information.
First Round Technology Offerings are not intended for minors. For that reason, First Round Technology does not knowingly collect or maintain Personal Information from persons under 16 years old, and no part of the First Round Technology Offerings are directed to persons under 16. IF YOU ARE UNDER 16 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE FIRST ROUND TECHNOLOGY OFFERINGS AT ANY TIME OR IN ANY MANNER.
Some of our Offerings let you share information with other people, and you have control over how you share. Any information that you voluntarily choose to include in an area of the Offerings accessible to other First Round Technology members, such as a public profile page or in a posting, will be available to other First Round Technology members who access that content.
Also, if you communicate directly with another First Round Technology members, any information that you voluntarily choose to include in such a communication with other First Round Technology members will be available to such other members. Once you make your information available in any of these ways, it could be collected and used by the recipients without restriction. We urge First Round Technology users to exercise common sense, prudence and good judgment about what information to make available to others through the First Round Technology Offerings.
We do disclose your Personal Information in connection with developing and maintaining the First Round Technology Offerings. We share your Personal Information in the following cases:
With your consent
We’ll share Personal Information outside of First Round Technology when we have your consent. For example, if you give us permission to share your information with a partner of First Round Technology.
For external processing
For legal reasons
We will share Personal Information outside of First Round Technology if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
We maintain reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
If you have found a vulnerability or would like to report a security incident, you may send an email to email@example.com. If First Round Technology learns of a security breach, we will notify you in accordance with applicable law.
Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We may transfer your Personal Information from the European Union to the United States in accordance with standard contractual clauses we entered into.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please email firstname.lastname@example.org to exercise these rights.
We process your information for the purposes described in this policy, based on the following legal grounds:
With your consent
We ask for your agreement to process your information for specific purposes like sending emails, and you have the right to withdraw your consent at any time.
When we're pursuing legitimate interests
We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
When providing a service
We process your data to provide a service you’ve asked for under a contract. For example, we process your information in connection with your licenses to the First Round Technology Offerings.
When we're complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.
Data protection officer
Locations and international transfers
We share your personal information and service data within First Round Technology. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where First Round Technology operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.
Data processing addendum
To enable you to be compliant with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Processing Addendum (DPA) that is based on Standard Contractual Clauses. You can request a DPA from First Round Technology by contacting the data protection officer email@example.com. Once we get your request, we'll forward the DPA to you for your signature.
California (USA) residents
California law permits individuals who provide First Round Technology with Personal Information and who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. First Round Technology does not, at this time, disclose Personal Information to third parties for their direct marketing purposes. If First Round Technology changes this policy, we will update this provision and provide instructions on how you may make a request for details concerning such information.
These policies may be amended from time to time. Your continued use of any First Round Technology Offering that incorporates this Policy will signify your acceptance of such amendment.
This privacy notice was last updated on the 9th August 2019