Privacy Policy

Last modified: June 2, 2020

Introduction  

CivImpact Labs, LLC (“Company,” “our,” “we,” “us”) manages this website and all related services and functionalities, including, but not limited to, audio and video conferencing, text chats, support services, and software (collectively, the “Services”). Our goal is to help people connect and share more easily online, which necessarily means that you will share information on the Services. We also want you to understand how your personal information may be used and shared when you use the Services, in compliance with this Privacy Policy, so you can make informed decisions and choices about your information.

This Privacy Policy is part of our Terms of Use available here. Please read this Privacy Policy and our Terms of Use carefully to understand our policies and practices regarding your information and how we will treat it, as you agree to this Privacy Policy by using the Services. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT USE THE SERVICES.

Children Under the Age of 16 

The Services is not intended for children under 16 years of age and you may not enter personal information about anyone under the age of 16. We require everyone who uses the Services to be legally able to consent to using the Services and our data collection and processing activities that we describe in this Privacy Policy. If we learn we have received personal information from or about a child under 16, we will delete that information immediately. If you believe we might have any information from or about a child under 16, please contact us immediately at privacy@qxtro.com.

Information We Collect

Like most platforms, we collect several types of information from and about users of the Services, including:

  • Information by which you may be personally identified, such as name, phone number, address and e-mail address, when you enter it into the Services, such as by creating a profile or account or subscribing to our newsletter;
  • Information related to events, centers, or spaces that you are organizing, such as organization name, background content, and invited attendees;
  • Information that you voluntarily enter or provide to us when asking us for assistance or support, such as telephone number or information about your Services usage;
  • Information that you enter or provide when you use Services features and functionalities, such as through the chat rooms, video conferences, polls, surveys,
  • Information that allows us to charge you for services or items requested on the Services, such as credit card information and billing address when you host or sign up for an event, center, or space on the Services;
  • Information that you provide to the Services for a specific reason or purpose that is listed on the Services before you provide it; and  
  • Information about your internet connection, the equipment you use to access the Services, and Services usage details.

How We Collect Information From You

We collect this information in two ways:

  • First, directly from you when you provide it to us, such as entering your information into a questionnaire provided to you on the Services, signing up for an account, or participating in an event, center, or space on the Services.
  • Second, automatically as you navigate through the Services, such as usage details, IP addresses, web browser preferences, and information collected through cookies and other tracking technologies. Although we do not correlate tracking information to individuals, some information collected, such as IP addresses, will be unique.

In some countries, including countries in the EEA, the information referenced in this Privacy Policy may be considered personal information under applicable data protection laws. If you do not want us to collect this information, do not use the Services.

Participating in Services Activities and User Contributions

In general, the information about you that we collect and then share with other users is limited to the information you include in your profile and the information you include when creating or joining an event, center, or space (see “How We Use Your Information” and “Sharing and Disclosure of Your Information” below for complete information). However, as a service designed for social connections, there are ample opportunities for you to voluntarily share more information about yourself – and we advise you to use caution when sharing your information on the Services.

Through video and audio conferences, text chats, and surveys, you can provide information that will be published, displayed, or posted on public areas of the Services and transmitted to other users of the Services or other third parties (collectively, “User Contributions”). Your User Contributions are provided and posted at your own risk. While we hope hosts will only allow trusted individuals into events, centers, and spaces, we do not vet or verify any Services users, whether or not they have an account.

We reserve the right, at our sole discretion, to remove, either temporarily or permanently, any User Contribution for any reason whatsoever. However, our right to remove any User Contribution does not obligate us to police, review, or verify User Contributions in any way. We are not responsible or liable for any User Contributions or any user’s use of any User Contributions.

Do Not Track Settings

The Company does not track its customers over time or across third party websites to provide targeted advertising, and therefore does not respond to Do Not Track (DNT) signals. However, some third party websites track your browsing activities when you use their websites so that they can tailor their content to your preferences. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

How We Use Your Information  

We use information that we collect about you or that you provide to us, including any personal information:

  • To develop, provide, and improve the Services and its services to you.
  • To provide you with information, products, or services that you request from us.
  • To improve the accuracy and relevance of information or services that you request from us, such as using survey responses to show events or centers that might be interesting to you.
  • To provide you with notices about your account and/or purchases.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to the Services or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.

Sharing and Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business, including credit card processors for processing payments on the Services.  
  • To other users on the Services to the extent that you include it in your public profile or in a User Contribution, or otherwise choose to share it with them.
  • To other users to the extent that information about you is shared by someone else on the Services.
  • To a buyer or other successor if the Company or its assets are sold and user information is part of the Company assets transferred.
  • To fulfill the purpose for which you provide it, such as if you include personal information on your user profile so other users can search for you, we will post that information in the manner you entered it.
  • For any other purpose disclosed by us when you provide the information.
  • To third party contractors in order to analyze Services performance and user behavior and/or to improve the Services.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, other Services users, or others.

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, such as maintain your account or allow you to host or attend events, centers, or spaces, or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, such as if you cancel your account, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@qxtro.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a registration, product service experience, invitations from other users, or other transactions.
  • Voluntary Information Requirements. To participate in an event, center, or space on the Services, you must create a profile with your name and email address. No other information is required to use the Services, so you can refuse to respond to inquiries or provide certain User Contributions if you do not what us or other users to have or use your information. Also see the next section about correcting and deleting your information (“Accessing and Correcting Your Information”).

Accessing and Correcting Your Information 

You can review and change the personal information you have entered into your profile by logging into the Services and visiting your profile page. You may also send us an email at [EMAIL ADDRESS] to request access to, correct, or delete any personal information that you have provided to us, including in your profile or in a chat text. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Additionally, we will assist you in deleting your information from our Services upon your request, but we cannot control or access other users’ files outside of the Services or cached pages.  

Recordings of the Services and User Contributions

Hosts can choose to record video, audio, and/or text through the Services, and if you are in an event, center, or space with this functionality enabled then your User Contributions will be recorded. If you do not want to be recorded, do not use the Services or provide User Contributions, or contact the host to see if they will refrain from recording. Additionally, other users may set up third party mechanisms to record User Contributions and we cannot control or monitor these activities.

Transferring Your Information

The Company is a worldwide service. By using the Services, you authorize us to transfer and store your information outside your home country, including in the United States, for the purposes described in this Privacy Policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

If we have a contract with a third party to transfer personal information from the European Economic Area, we will take additional measures as required by law, including having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.

Data Security  

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access. For example, access by a user to some of their personal information is available through a password and unique customer ID selected by the user. Most information is encrypted through the Services with Secure Socket Layer technology (SSL) and is also encrypted when it is stored by us to prevent unauthorized parties from viewing such information. Also, we perform regular malware scanning of the Services and all servers and computers used by us to support the Services. All Company employees are required to adhere to our security and confidentiality procedures and undergo training related to maintaining the security of user personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Your California Privacy Rights  

California Civil Code Section § 1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@qxtro.com.  

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit [CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS].

EEA Users

You have options under the law in relation to the information and data that we have about you. To exercise any of the options discussed below, please contact us at privacy@qxtro.com. In particular, you may:

  • Access the information we have about you. We’ll will make an effort to share this information with you within a reasonable time.
  • Have your information corrected or deleted. 
  • Object to us processing your information. You can ask us to stop using your information, including when we use your information to send you marketing emails or push notifications. We only send you marketing material if you’ve agreed to it, but if you’d rather we don’t, you can easily unsubscribe at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or by emailing us at the email address above.
  • Withdraw your consent for us to collect and process your personal information at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • Have the information you provided to us sent to another organization, where we hold this information with your consent or for the performance of a contract with you, where it’s technically feasible.
  • Complain to a regulator. If you’re based in the EEA and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Legal Basis for Processing Personal Information

Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as your agreement to our Terms of Use and requests to use our Services functionalities); (ii) where the processing is in our legitimate interests and not overridden by your rights (such as, generally, our business interests in operating our Services services); or (iii) where we have your consent to do so (which we have when you voluntarily enter information into our Services, agree to our Terms of Use and Privacy Policy, and provide User Contributions). 

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

We do not use any automated decision-making systems at this time. 

Third Party Links

The Services may contain links that lead to other websites, either provided by the Company or other users. The Company is not responsible for the privacy practices, content, and/or activities of these linked websites. Nonetheless, we seek to protect the integrity of the Services and welcome any feedback about these external websites.

Changes to Our Privacy Policy

We will post any changes we make to our privacy policy on this page and you will be notified of any material changes on the Services home page and in an email to the most recent email address that you provided to us, if any.

Organization and Contact Information  

The Services are operated by and are the property of CivImpact Labs, LLC. For general information about the Services, this Privacy Policy, or anything else, you can contact us at:

Data Protection Officer
privacy@qxtro.com