1. Introduction

GB Intelligence Inc., (“GBI”) is dedicated to protecting your personal information. This Privacy Policy applies to your use of any GBI-owned websites, software, or associated services (collectively the “Platform”). Our Privacy Policy discloses our privacy practices and explains to you how we use, collect, store, transfer, and share your personal information. For users from the European Union (EU), our handling of data is also guided by the General Data Protection Regulation (GDPR). Please review this Privacy Policy periodically as we may revise it from time to time without notice. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform.

2. Information Collected

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or otherwise anonymized. For our users in the EU, we will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), and legitimate interests.

Personal Information Collected from Users

You will not be required to provide us with any personal information when you visit our Platform. However, portions of our Platform may require us to collect personal information about you. During your use of the Platform we may collect identifying information, name, address, email, job title, contact information, phone number, business information, and executive assistant information. Additionally, if you submit any content that contains personal information such information shall be collected by us. Any personal information you submit via the Platform shall be used and disclosed in accordance with this Privacy Policy.

Personal Information Automatically Collected

Whenever you use our Platform, we may collect non-identifying information from you, such as your location information, IP address, date/time-zone, interactions with the Platform, query information, location information, referring URL, browser information, application interaction, mobile provider information, operating system, data usage, data transferred, and internet service provider.

3. Sharing Information with Other Users

Where you submit information to us your information may be shared with other users of our Platform including but not limited to third party vendors, attendees of our events, and sponsors or advertisers. For our users in the EU, we ensure that these third parties respect your privacy and are contractually obliged to keep your personal data safe, and process it only in accordance with our instructions.

4. Anonymized Data

Please be aware that we may collect and aggregate personal information from our Platform and may anonymize that information for our own research or internal purposes.  Once such data has been anonymized, it cannot be traced back to you, the user. For our users in the EU, this process is compliant with GDPR regulations.

5. Sharing and Use of Your Information

This section explains how GBI may share or use your personal information. You consent to our use of your personal information for the following purposes. For our EU users, we respect your rights under the GDPR, and only share your personal data where we have a lawful basis for doing so:

• CONTRACT ADMINISTRATION - We may use your personal information to negotiate, execute, renew and/or manage a contract with you.
• ACCESS AND COMMUNICATIONS TO OUR PLATFORM AND SERVICES - We may use your personal information to: (1) interact with you through our Platform (e.g. software updates, Platform announcements, etc.); (2) send you email updates or updates regarding our business practices; and/or (3) manage and respond to your questions (e.g. technical, commercial or administrative).
• USE OF THE PLATFORM - We may use your personal information to (1) enable you to enjoy the use of, and easily navigate the Platform; and/or (2) better understand your needs and interests.
• SHARING WITH THIRD PARTIES - We may use your personal information to share with other users of the Platform as outlined above. We may also share your information with service providers with whom we contract with such as contractors, web hosts, data providers, marketers, and others so that we may provide you any services and allow you to access the Platform
• TRAINING AND IMPROVEMENTS - We may use your personal information to (1) train our employees or contractors to allow for a better Platform experience; and/or (2) improve the Platform.
• DIRECT MARKETING AND INQUIRIES - We may use your personal information to contact you for additional products and services that you may be interested in or to respond to an inquiry.
• LEGAL PROCESS - We may share your information: if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable provisions within this Privacy Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or GBI; to detect, prevent, or otherwise address security, technical issues, or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.

6. Retention of Personal Information

We will keep your personal information:

•    For any legally required duration or per our internal data retention policies.
•    Until we receive a request to eliminate, delete, or modify any of your personal information stored with us, subject to our internal retention policies.

For legal purposes and/or at the request of governmental authorities or regulatory agencies we may retain your personal information even after a request for deletion or removal by you.

For our EU users, in accordance with GDPR, we will hold your information for as long as necessary for the purpose it was collected, or as required under law.

7. Accessing and Editing Your Information

When using our Platform you may be able to access, edit, or delete some of your personal information by sending us a request.  You have the right to correct or update your personal information at any time. For our EU users, under GDPR, you have the right to access, correct, transfer or delete your personal data. If you wish to exercise these rights, please contact us at info@gbimpact.com

8. Removal of Information 

If you wish to have any of your personal information stored within the GBI Platform removed, please contact us at info@gbiimpact.com. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in removing any personal information requested and we reserve the right to reject any removal requests subject to our internal policies. For EU users, we will comply with requests for data removal in accordance with the GDPR.

9. Cookies

We currently use cookies to understand your use of our Platform, understand how you interact with our emails, and may share your cookie information with third contractors that assist us in providing you access to the Platform and that allow us to analyze the usage of our Platform.  If you do not wish to have cookies loaded on your browser, please adjust your browser settings.  Please be aware that disabling cookies may cause some issues with the functionality of our Platform.

10. Opting Out and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and email where you have consented, if you have any questions regarding such communications please contact us at info@gbiimpact.com.  We currently do not offer website functionality for you to opt out of any “do not track” signals or listings. For our EU users, you have the right to opt-out at any time, in accordance with the GDPR

11. Third Parties

GBI or its users may post links to third party websites on our Platform, which may include information that we have no control over.  When accessing a third party site through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us. GBI bears no responsibility for the information collected or used by any advertiser or third party website that you have visited through a link on our Platform. 

Throughout the course of our provision of our services to you, we may delegate our authority to collect, access, use, and disseminate your information.  We use third party individuals and organizations to assist us, including contractors, web hosts, marketers, and others to allow you to access the Platform.  Specifically, we disseminate your information to the following third parties:  LinkedIn and Google.  It is therefore necessary that you grant the third parties the same rights that you afford us under this Privacy Policy.  For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, marketing, or otherwise improving or preserving our Platform or its underlying files or systems.   You must review a third party’s privacy policy to understand how their information collection practices work as their practices may differ from this Privacy Policy. For EU users, we ensure that all third parties comply with GDPR and protect your data to the same standard that we do.

12. Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards. However, as our Platform is hosted electronically we can make no guarantees as to the security or privacy of your information.  For this reason, we recommend that you use anti-virus software, robust passwords, firewalls, and other precautions to protect yourself from security and privacy threats.

13. Your California Privacy Rights

GBI permits residents of the State of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579.  If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes.  Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. You may contact us at info@gbiimpact.com with any questions regarding your California Privacy Rights. California users are also entitled to the following specific consumer rights notice to contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

14.  Age Compliance

We intend to fully comply with United States’ laws respecting children’s privacy.  Therefore, we do not collect or process any information for any persons under the age of 18.  If you are under 18 you may not access the Platform. For our EU users, in line with GDPR regulations, if you are under the age of 16, you will need the consent of your parent or guardian to use the Platform.

15. Transfer of Your Information Internationally

If you are accessing the Platform from outside the United States, including the European Union, please be aware that your personal information may be transferred to, stored, and processed in the United States. We have taken appropriate safeguards to require that your personal information will remain protected and we use the Standard Contractual Clauses approved by the European Commission as the legal mechanism for these data transfers from the EU to United States.

16. Merger and Acquisition

In the event that GBI is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your personal information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

17. Amendments

We may amend this Privacy Policy at any time without notice.  When we amend this Privacy Policy, we will modify the date listed on this Agreement or we may contact you.  You must agree to the amendments as a condition of your continued use of our Platform.  

18. Contacting Us

If you have any additional questions, please contact us at info@gbiimpact.com 

If you are a resident of the European Union and have concerns about our data processing practices, you have the right to file a complaint with the appropriate supervisory authority in your country.