Privacy Policy

Last Updated: March 28, 2016

9STEER PRIVACY POLICY

9steer (hereinafter referred to as "9steer", "we", "us" or "our") operates a platform and community marketplace that helps people form offline experiences and relationships directly with one another, where they can create, list, discover and book unique advisory service through our website ("Platform"). 9steer refers to Steering Ltd.

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your 9steer account. You can request to have your 9steer account deactivated by emailing contact@9steer.co

DEFINITIONS

Where the definition of a term does not appear in this Privacy Policy (such as "Listing", "Advisory services", "Content," etc.), it shall be given its definition as outlined in our Terms of Service (http://www.9steer.co/terms).

"Aggregated Information" means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

"Data Controller" means 9steer, the company responsible for the use and processing of Personal Information.

"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

WHAT TYPES OF INFORMATION DOES 9STEER GATHER ABOUT ITS USERS?

1. Information that you give us

We receive, store and process information that you make available to us when accessing or using our Platform and Services. Examples include when you:



fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID verification information;


access or use the Platform, such as to search for or post advices, make or accept join board invitations, pay monthly retainers, book calls or pay for any associated services that may be available (such as but not limited to bonuses), post comments or reviews, or communicate with other users;


link your account on a third party site (e.g. LinkedIn) to your 9steer account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; and


communicate with 9steer.



2. Log Data

We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with 9steer or logged in to your 9steer account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.

3. Cookies and other Tracking Technologies

9steer uses cookies and other similar technologies, such as mobile application identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a "Do Not Track" signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for 9steer services on third party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

5. Third-party social plugins

Our Platform may use social plugins which are provided and operated by third-party companies, such as Facebook's Like Button.

As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the third party.

Please refer to the third party's privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.

HOW 9STEER USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

We use, store and process Information about you for the following general purposes:



to enable you to access and use the Platform;


to operate, protect, improve and optimize the Platform, 9steer’s business, and our users' experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and for advertising and marketing;


to help create and maintain a trusted and safer environment on the Platform and Services, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;


to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;


where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information about 9steer or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the "Account" section) when you login to your 9steer account;


to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by 9steer or our business partners; and


to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.



HOW 9STEER USES AND PROCESSES USER COMMUNICATIONS

We may, either directly or through third party companies and individuals we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Startups to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, advisory services and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that 9steer, in its sole discretion, may, either directly or through third party companies and individuals we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR 9STEER ACCOUNT

You may review, update, correct or delete the Personal Information in your 9steer account. If you would like to correct your information or cancel your 9steer account entirely, you can do so by sending a request to contact@9steer.co . Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your name, even after your 9steer account is cancelled.

SECURING YOUR PERSONAL INFORMATION

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by 9steer such as Startups’ company URL and Advisors’ LinkedIn profiles. Airbnb does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

SPECIAL FEATURES AND PROGRAMS

Referral service and requesting references

The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your 9steer profile.

We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and 9steer does not collect or retain the contact information that is used to send them.

You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins 9steer in response to your referral.

If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.

Meetups

The Platform may allow registered account holders to organize, search for or participate in offline events ("Meetups") in selected cities.

If you organize a Meetup or indicate that you will attend one, this information, together with some of your public information (such as your profile picture and public profile page) and any messages that you post about that Meetup, will be visible to users who browse the event. However, 9steer will never disclose where you are staying to another meetup user.

CHANGES TO THIS PRIVACY POLICY

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the "Last Updated Date" at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It's important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your 9steer account by emailing contact@9steer.co

GOT FEEDBACK?

Your opinion matters to us! If you'd like to provide feedback to us about this Privacy Policy, please email us at contact@9steer.co

FOR USERS RESIDING IN THE EU AND JAPAN ONLY: YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION

If you reside in the EU or Japan, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom). We may also request proof of identification to verify your access request.

We endeavor to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your valid request that the relevant action has been taken.

You may also request the erasure of your personal data if you believe we are otherwise in breach of relevant data protection legislation. There is no charge for making such a request.

COOKIE POLICY

9steer uses "cookies" in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

9steer cookies and third party cookies

Airbnb may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Platform, namely "persistent cookies" and "session cookies".

Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

Other technologies

The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

Uses for 9steer cookies

9steer uses cookies for a number of purposes, such as the following:



to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.


to simplify your access to and use of the Platform and make it more seamless.


to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.


to show you content that is more relevant to you.



Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser's toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website (http://www.adobe.com/) and make changes at the Global Privacy Settings Panel (http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager02.html).

Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

It's important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and deactivate your 9steer account. You can request to have your account deactivated by emailing contact@9steer.co