Global Privacy Policy

July 30th, 2018

Thank you for your interest in Pioneer, a LLC, and its affiliated companies (“Pioneer”, “we,” or “us”) and in the websites, products and services provided by us (collectively, the “Services”).

This Privacy Policy (this “Privacy Policy”) applies to the processing of Personal Data by Pioneer in the context of the Services and in connection with its member, partner and service provider relationships.

This Privacy Policy describes:

  • the personal data we may collect;
  • how we use your personal data;
  • how we share your personal data;
  • the rights and choices you have regarding your personal data;
  • the limitations of this Privacy Policy regarding third party sites or services;
  • how we protect children’s privacy;
  • the steps we take to protect your personal data;
  • how we transfer information;
  • how we may change this Privacy Policy; and
  • how you may contact us.

By using the Services, you consent to the privacy practices described in this Privacy Policy. This Privacy Policy is incorporated into and is subject to the Terms of Service for the Services you use.

For the purpose of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual.

I. Personal Data we may collect

In connection with the Services, we obtain Personal Data relating to you from various sources described below.

Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from a service if that information is necessary to provide you with the service or if we are legally required to collect it.

– Information provided by you as a Member. When you use the Services, you may provide us with information about you, including your name, email address, mailing address, phone number, educational and work history, businesses you founded or participated in, hobbies, and any other information you may volunteer as part of the Pioneer questionnaire. You may provide us with your Personal Data in various ways when using the Services. For example, you may provide us with your Personal Data when you use the Pioneer forums or submit forms on the Services or when you send us requests or questions using the Services or other means of communication.

– Information provided by other Members about you. Other Members may vote with regards to your business plan or abilities as a founder, comment on your business plan and ideas in a Pioneer forum, or follow you on social media and choose to disclose such preferences to Pioneer.

– Cookies and automatically collected information. When you use certain Services, we may send one or more cookies. We may use both session cookies and persistent cookies. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of the Services to their fullest potential. We may use third party cookies as well. For instance, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics cookies. Pioneer does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use the Services. We may also automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.”

– Third party web beacons and third party buttons. We may enable you to connect your Pioneer account to, or otherwise interface with, third party services, including third party social networks and communications services (such as Facebook, LinkedIn or Twitter). In addition, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third party web beacons and buttons is collected directly by these third parties, not by Pioneer. Please consult that third party’s own data collection, use, and disclosure policies for more information.

II. How we may use your Personal Data

We may use the Personal Data we collect from or about you to in the following ways:

– operate, maintain, enhance and provide features of the Services, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to Members

– understand and analyze Members’ input to the Pioneer leaderboard, forums and questionnaires

– to improve the Services, to evaluate and improve the quality of our products and services, and to develop new products, services, features, and functionality (including de-identified of Personal Data)

– contact you for administrative, informational, and marketing purposes. This may include providing customer service or sending communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Where required under applicable law, we obtain appropriate consent to send you marketing communications.

– comply with applicable legal requirements and industry standards and our policies

– enforce our Terms of Service

– manage our partner and service provider relationships

In addition, we may use information we automatically collect when you use certain Services to: (i) analyze your preferences in order to personalize or customize the Services; (ii) analyze the effectiveness of the Services; and (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed.

We may process your Personal Data for the above purposes when:

– you consented to the use of your Personal Data

– we need your Personal Data to provide you with products and services requested by you, or to respond to your inquiries

– the processing is necessary for compliance with a legal obligation

– we, or a third party, have a legitimate interest in using your Personal Data, such as to ensure and improve the safety, security, and performance of our products and services, to de-identify Personal Data and carry out data analyses

III. How we share your Personal Data

We will not disclose your Personal Data to third parties except as described in this Privacy Policy or as we disclose to you at the time the information is collected.

– With our affiliates. We may share your Personal Data with any members of our Pioneer group, including the parent company, affiliates, subsidiaries and branch offices, where applicable.

– Displaying information on the Services. Any information that you voluntarily choose to upload to a publicly accessible site or venue using the Services, or that you elect to make public, will be available to anyone who has access to that content, including other Members.

– Service providers. We work with third party service providers that provide application development, communications, hosting, maintenance, and other services for us. These third parties may have access to or process your Personal Data as part of providing those services to us. We require these service providers by contract to only process Personal Data in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements.

– As required by law and similar disclosures. We may preserve and disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or request, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

– Third party advertising partners. We may work with third party advertising partners to show ads that we think may interest you. These third party partners collect information from you via cookies and similar technologies. Where required under applicable law, we will request your consent to such collection and use of your information. You may be able to opt out of receiving personalized advertisements from our advertising partners who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations. Links to those sites are here:

– Merger, sale, or other asset transfers. Your Personal Data may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets.

– Other disclosures to third parties. We may make certain aggregated, de-identified, or non-identifying information about users of the Services available to third parties for various purposes, such (i) compliance with various reporting obligations, (ii) for business or marketing purposes with our business partners, (iii) product analysis, or (iv) to assist such parties in understanding our Members’ interests, habits, and usage patterns for certain programs, contents or services, and/or functionality of the Services.

– With your consent or as otherwise authorized. We may also otherwise disclose your Personal Data to third parties with your consent, or as otherwise authorized under applicable law.

IV. Use of Services by minors

The Services are not directed to children under the age of 16, and we request that they not provide Personal Data through the Services.

V. Retention and data security

Where you choose to create a Services profile or post a user contribution e.g., by upvoting another Pioneer Member, we generally do not delete or disable any information contained in such page, profile or contribution until and unless you ask us to. To request this, please contact us via email at legal@pioneer.app.

In all other cases, your Personal Data will be stored by Services for as long as necessary in order to fulfill the purposes set out in this Privacy Policy and to comply with minimum retention periods under applicable law.

We maintain appropriate administrative, technical, and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. We restrict access to Personal Data about you to those employees who need to know that information to provide Services to you. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards, subject to requirements under applicable law to ensure or warrant information security.

VI. Your rights and choices

Subject to applicable law, you have the right to:

– Request access to and receive information about the Personal Data we maintain about you, update or correct inaccuracies in your Personal Data, to restrict or to object to the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability where possible and applicable. In addition and depending on your jurisdiction, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

– Withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Those rights may be limited in some circumstances by local law requirements.

If you would like to get in touch with regards to exercising your rights and choices, please consult the “How to contact us” section below.

If you receive commercial messages via email or text message from us, you may unsubscribe at any time by following the instructions contained within the email or text message. You may also opt out from receiving commercial email or text messages from us by sending your request to us by email at legal@pioneer.app.

VII. Third party services

The Services may contain features or links to websites and services provided by third parties. Any information you provide on third party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, even if accessed through the Services. We are not responsible for these websites’ content, use, or privacy practices.

VIII. International data transfers

Services are operated and managed on servers located within the United States. If you choose to use Services from the European Union or other regions of the world with laws governing data collection and use that differ from United States law, you acknowledge that Pioneer will transfer your Personal Data to the United States for the purpose of performing the Services in accordance with our Terms of Service and for any other purpose for which you provide explicit, informed consent.

IX. Changes and updates to this Privacy Policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

X. How to contact us

Please contact us with any questions or comments about this Privacy Policy by email at legal@pioneer.app.