Privacy Policy
NIR-VANA’s mission is to connect innovators and advisors to allow them to be more productive and successful. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy and Cookie Policy.
- Introduction
- Data We Collect
- How We Use Your Data
- How We Share Information
- Your Choices & Obligations
- Other Important Information
Introduction
We are a social network and an online platform for innovators and advisors. People use our Services to find and be found for business opportunities and to connect with others and information. Our Privacy Policy applies to any Member or Visitor to our Services.
Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”). NIR-VANA advisors (“Advisors”) give advice to companies, entrepreneurs, researchers and inventors on innovation, partnering, funding, intellectual property. NIR-VANA innovators (“Innovators”) are companies, entrepreneurs, experts, investors, researchers or inventors.
Services
This Privacy Policy, including our Cookie Policy applies to your use of our Services.
This Privacy Policy applies to platform.nir-vana.eu excluding services that state that they are offered under a different privacy policy.
Data Controllers and Contracting Parties
Blue Room Innovation S.L, will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services; you are entering into the User Agreement with Blue Room Innovation S.L.
As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.
Change
Changes to the Privacy Policy apply to your use of our Services after the “effective date.”
Blue Room Innovation S.L (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may disable your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
1. Data We Collect
1.1 Data You Provide To Us
You provide data to create an account with us.
To create an account you need to provide data including your name, email address and a password.
You create your NIR-VANA profile (a complete profile helps you get the most from our Services).
You have choices about the information on your profile, such as your title, gender, address and geolocation, birthday, about, skills and photo. Innovators may choose to complete their Innovator Profile with their affiliation. Advisors may choose to complete their Advisor Profile with their affiliation, skills and trainings. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping you to connect to other users and external services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
Innovators and Advisors can opt in to create an account on some external service providers such as OPENiSME. Additionally, advisors belonging to the Enterprise Europe Network can connect their accounts to the Enterprise Europe Network’s Merlin Service and to EasyPP. It’s your choice whether to provide existing credentials or create new credentials to access the aforementioned tools and services. The NIR-VANA privacy policy does not apply to any of these third party tools. NIR-VANA will store you access credentials encrypted with the aim to ease a seamless access to the third party tools and services you decide to link.
You give other data to us.
We collect personal data from you when you provide, post or upload it to our Services, such as when you invite your clients or partners or introduce calendar meeting information, e.g. times, places, attendees and contacts.
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
1.2 Data From Others
Others may post or write about you.
You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services.
Others collaborate with you with our Services.
We receive personal data (including contact information) about you when others invite you, collaborate with you or send you messages using our Services.
1.3 Service Use
We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our APIs), such as when you view or click on content (e.g., learning video), perform a search, install or update one of our mobile apps or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.4 Cookies
We collect data through cookies and similar technologies.
As further described in our Cookie Policy, we use cookies and similar technologies to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools.
1.5 Your Device and Location
We receive data from your devices and networks, including location data.
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
1.6 Messages
If you communicate through our Services, we learn about that.
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a NIR-VANA invitation request, we track whether you have acted on it and will send you reminders.
1.7 Other
We are improving our Services, which means we get new data and create new ways to use data.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.
2. How We Use Your Data
We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services so that they can be more relevant and useful to you and others.
2.1 Services
Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive.
We use your data to authorize access to our Services.
Our Services allow you to stay in touch and up to date with colleagues, partners, clients, advisors and other professional contacts. To do so, you will be searchable and findable through the NIR-VANA Directory, the NIR-VANA global Search and other specific sections to search and find users. When found, other users will be able to see your profile according to your profile visibility under the Security section in your Account Settings. Anyone will be able to send you a private message, of which you will receive a copy in your email, unless you decide to change it under the Security section in your Account Settings. Your email address is not displayed to any Member or Visitor in your user Profile.
It is your choice whether to invite someone to our Services, send a message, invite, request or allow another Member to collaborate with you on a public or private collaboration space. When you invite someone to collaborate with you, your invitation will include your name and photo and a link to your Profile. We will send invitation reminders to the person you invited.
Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We may use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity.
Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members and schedule and prepare meetings with them.
2.2 Communications
We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.
We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your NIR-VANA messages inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, daily summaries of activities, reminders of pending tasks, and promotional messages from us. You may change your communication and email summary preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, including for example invitations to spaces and events, public or private collaboration spaces, news and success cases, challenges messages between connections.
2.3 Marketing
We promote our Services to you and others.
We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.
2.4 Developing Services and Research
We develop our Services and conduct research.
We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
2.5 Customer Support
We use data to help you and fix problems.
We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).
2.6 Aggregated reports
We use data to generate
aggregated reports.
We may use your data to
produce and share aggregated reports to the organisations
you are affiliated to. You can update your affiliation in the innovator Profile or advisor Profile.
2.7 Security and Investigations
We use data for security, fraud
prevention and investigations.
We use your data (including
your communications) if we think it’s necessary for security purposes or to
investigate possible fraud or other violations of our User
Agreement or this Privacy Policy and/or attempts to
harm our Members or Visitors.
3. How We Share Information
3.1 Our Services
Any data that you include on
your profile and any content you post or social action (e.g. likes, follows,
comments) you take on our Services will be seen by others.
Profile
Your profile is fully visible
to all Members and customers of our Services, subject to your settings. Visitors do not have access to your profile,
subject to your settings.
Posts, Likes, Follows,
Comments, Messages
Our Services allow viewing and sharing information including through posts,
likes, follows and comments.
- When you share an article or a post (e.g., an
update, image, video or article) publicly it can be viewed by everyone.
Visitors will be able to find and see your publicly-shared content,
including your name (and photo if you have provided one). Only Members
will be able to like, comment or express interest. This includes News and
success cases, posts in your profile, comments received from others and
organization challenges.
- In a private space, posts, events, tasks, files,
links, call recordings any other type of information or material are only visible
to those Members that are invited and accept the invitation to the space. Private
spaces are listed in the NIR-VANA directory only to the space members.
- In a public space, posts, events, tasks, files,
links, call recordings any other type of information or material are only
visible to the space members. The space owner decides the join policy,
which can be of type “Only by invite”, “Everyone can enter” and “Invite
and request”. Public spaces are publicly listed in the NIR-VANA directory.
- Your membership in public spaces is public and
part of your profile.
- When you follow someone, you are visible to
others and that person as a follower.
- When you like or comment on another’s content,
others will be able to view these “social actions” and associate it with
you (e.g., your name, profile and photo if you provided it).
3.2 Communication Archival
Regulated Members may need to
store communications outside of our Service.
Some Members (or their employers) need, for legal or professional
compliance, to archive their communications and social media activity, and will
use services of others to provide these archival services. We enable archiving
of messages by those Members outside of our Services. For example, a financial
advisor needs to archive communications with her clients through our Services
in order to maintain her professional financial advisor license.
3.3 Legal Disclosures
We may need to share your data
when we believe it’s required by law or to help protect the rights and safety
of you, us or others.
It is possible that we will
need to disclose information about you when required by law, subpoena, or other
legal process or if we have a good faith belief that disclosure is reasonably
necessary to (1) investigate, prevent, or take action regarding suspected or
actual illegal activities or to assist government enforcement agencies; (2)
enforce our agreements with you, (3) investigate and defend ourselves against
any third-party claims or allegations, (4) protect the security or integrity of
our Service (such as by sharing with companies facing similar threats); or (5)
exercise or protect the rights and safety of LinkedIn, our Members, personnel,
or others. We attempt to notify Members about legal demands for their personal
data when appropriate in our judgment, unless prohibited by law or court order
or when the request is an emergency. We may dispute such demands when we
believe, in our discretion, that the requests are overbroad, vague or lack
proper authority, but we do not promise to challenge every demand.
3.4 Change in Control or Sale
We may share your data when
our business is sold to others, but it must continue to be used in accordance
with this Privacy Policy.
We can also share your personal data as part of a sale, merger or change in
control, or in preparation for any of these events. Any other entity which buys
us or part of our business will have the right to continue to use your data,
but only in the manner set out in this Privacy Policy unless you agree
otherwise.
4. Your Choices & Obligations
4.1 Data Retention
We keep most of your personal
data for as long as your account is enabled.
We retain your personal data
while your account is in existence or as needed to provide you Services. This
includes data you or others provided to us and data generated or inferred from
your use of our Services. Even if you only use our Services when looking for opportunities
every few years, we will retain your information and keep your profile open
until you decide to disable your account.
4.2 Rights to Access and Control Your Personal Data
You can access or delete your
personal data. You have many choices about how your data is collected, used and
shared.
We provide many choices about
the collection, use and sharing of your data, from deleting or correcting data
you include in your profile, innovator profile or advisor profile and controlling the visibility
of your profile to Members or Visitors, configure the e-mail
summaries and the type of notifications you want to receive in your email or in the web.
We offer you settings to
control and manage the personal data we have about you.
For personal data that we have about you:
- Delete Data: You
can ask us to erase or delete all or some of your personal data (e.g., if
it is no longer necessary to provide Services to you).
- Change or Correct Data: You can edit some of your personal data through
your account. You can also ask us to change, update or fix your data in
certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of
your personal data (e.g., if we have no legal right to keep using it) or
to limit our use of it (e.g., if your personal data is inaccurate or
unlawfully held).
- Right to Access and/or Take Your Data: You can ask us
for a copy of your personal data and can ask for a copy of personal data
you provided in machine readable form.
You may also contact us using
the contact information below, and we will consider your request in accordance
with applicable laws.
4.3 Account Closure
We keep some of your data even
after you disable your account.
If you choose to disable your NIR-VANA account, your personal data will generally stop being
visible to others on our Services. We retain your personal data even after you
have closed your account if reasonably necessary to comply with our legal
obligations (including law enforcement requests), meet regulatory requirements,
resolve disputes, maintain security, prevent fraud and abuse, enforce our User
Agreement, or fulfill your request to “unsubscribe” from further messages from
us. We will retain de-personalized information after your account has been disabled.
Information you have shared with others (e.g. in messages, posts in public
or private spaces) will remain visible after you closed your account or deleted
the information from your own profile messaging system, and we do not control
data that other Members copied out of our Services. Content associated with
closed accounts will show your name as the source, since this becomes a proof
of collaboration. Your profile will not be searchable or findable, but it may
continue to be displayed in the services of others (e.g., search engine
results) until they refresh their cache.
5. Other Important Information
5.1. Security
We monitor for and try to
prevent security breaches. Please use the security features available through
our Services.
We implement security
safeguards designed to protect your data, such as HTTPS. We regularly monitor
our systems for possible vulnerabilities and attacks. However, we cannot
warrant the security of any information that you send us. There is no guarantee
that data may not be accessed, disclosed, altered, or destroyed by breach of
any of our physical, technical, or managerial safeguards.
5.2. Data Processing and storage
We store and process your data
in the EU.
We process data inside the European
Union and rely on legally-provided mechanisms to lawfully transfer data across
borders. All data from the NIR-VANA platform is stored on UK high
performance cloud servers. The servers comply with all EU privacy policies and are ISO-27001
(Information technology — Security techniques — Information security management
systems — Requirements) certified. Countries where we process data may have
laws which are different, and potentially not as protective, as the laws of
your own country.
5.3 Lawful Bases for Processing
We have lawful bases to collect, use and share data about you. You have
choices about our use of your data.
At any time, you can withdraw
consent you have provided by going to settings.
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 (e.g. to deliver the NIR-VANA
Services you have requested)) and “legitimate interests”.
We may process your personal
data for the purposes of our legitimate interests or for the legitimate
interests of third parties (e.g., your employer or company), provided that such
processing shall not outweigh your rights and freedoms. For example, we may
process your personal data to:
·
Protect you, us, or others
from threats (such as security threats or fraud)
·
Comply with laws that apply to
us
·
Enable or administer our
business, such as for quality control, consolidated reporting, and customer
service
·
Manage corporate transactions,
such as mergers or acquisitions
·
Understand and improve our
business or customer relationships generally
·
Enable us, Members, and
Visitors to connect with each other, find economic opportunity, express
opinions, exchange information, and conduct business
Where we rely on your consent
to process personal data, you have the right to withdraw or decline your
consent at any time and where we rely on legitimate interests, you have the
right to object.
If you have any questions
about the lawful bases upon which we collect and use your personal data, please
contact our Data Protection Officer:
info@blueroominnovation.com (info@blueroominnovation.com)
5.4. Direct Marketing and Do Not Track Signals
Our statements regarding
direct marketing and “do not track” signals.
We currently do not share
personal data with third parties for their direct marketing purposes without
your permission.
5.5. Contact Information
You can contact us or use
other options to resolve any complaints.
If you have questions or complaints
regarding this Policy, please contact our Data Protection Officer:
info@blueroominnovation.com (info@blueroominnovation.com)
5. Other Data protection provisions
5.1.
Data protection provisions about the application and use of Linkedin
On this website,we have integrated the Linkedin
button as a component to enable login and registration of users.
The operating company of Linkedin is LinkedIn Corporation, ATTN: Copyright Agent, Legal
Department, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA. You can consult Linkedin’s Privacy Policy at (https://www.linkedin.com/legal/privacy-policy).
When you register to NIR-VANA using Linkedin,
this will direct you to the Linkedin site to request
permission to import some personal data from your Linkedin
profile into your NIR-VANA profile. NIR-VANA will import the following
information from Linkedin: your name and surname,
your title, your city and country and your profile photo. You can modify them
anytime in your user Profile.
Once registered using the Linkedin button, you will
be able to seamlessly log into NIR-VANA as long as you have the Linkedin session initiated in your browser. If your session
is not initiated, you will be directed to the Linkedin
site to log in.
Your Linkedin credentials will never be shared with
NIR-VANA.
Linkedin receives information about your visits and
interaction with NIR-VANA when you log-in or register with LinkedIn according
to their Privacy Policy.
5.2.
Data protection provisions about the application and use of Google Analytics
(with anonymization function)
On this website, the controller has
integrated the component of Google Analytics (with the anonymizer function).
Google Analytics is a web analytics service. Web analytics is the collection,
gathering, and analysis of data about the behavior of visitors to websites. A
web analysis service collects, inter alia, data about the website from which a
person has come (the so-called referrer), which sub-pages were visited, or how
often and for what duration a sub-page was viewed. Web analytics are mainly
used for the optimization of a website and in order to carry out a cost-benefit
analysis of Internet advertising.
The operator of the Google Analytics
component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351,
United States. Google has certified to the EU-U.S. Privacy Shield Framework and
thus guarantees to behave in accordance with the EU-GDPR (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
For the web analytics through Google
Analytics the controller uses the application "_gat. _anonymizeIp".
By means of this application the IP address of the Internet connection of the
data subject is abridged by Google and anonymised
when accessing our websites from a Member State of the European Union or
another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics
component is to analyze the traffic on our website. Google uses the collected
data and information, inter alia, to evaluate the use of our website and to
provide online reports, which show the activities on our websites, and to
provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the
information technology system of the data subject. The definition of cookies is
explained above. With the setting of the cookie, Google is enabled to analyze
the use of our website. With each call-up to one of the individual pages of
this Internet site, which is operated by the controller and into which a Google
Analytics component was integrated, the Internet browser on the information
technology system of the data subject will automatically submit data through
the Google Analytics component for the purpose of online advertising and the
settlement of commissions to Google. During the course of this technical
procedure, the enterprise Google gains knowledge of personal information, such
as the IP address of the data subject, which serves Google, inter alia, to
understand the origin of visitors and clicks, and subsequently create
commission settlements.
The cookie is used to store personal
information, such as the access time, the location from which the access was
made, and the frequency of visits of our website by the data subject. With each
visit to our Internet site, such personal data, including the IP address of the
Internet access used by the data subject, will be transmitted to Google in the
United States of America. These personal data are stored by Google in the
United States of America. Google may pass these personal data collected through
the technical procedure to third parties.
The data subject may, as stated above,
prevent the setting of cookies through our website at any time by means of a
corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also
prevent Google Analytics from setting a cookie on the information technology
system of the data subject. In addition, cookies already in use by Google
Analytics may be deleted at any time via a web browser or other software
programs.
In addition, the data subject has the
possibility of objecting to a collection of data that are generated by Google
Analytics, which is related to the use of this website, as well as the
processing of this data by Google and the chance to preclude any such. For this
purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through
a JavaScript, that any data and information about the visits of Internet pages
may not be transmitted to Google Analytics. The installation of the browser
add-ons is considered an objection by Google. If the information technology
system of the data subject is later deleted, formatted, or newly installed,
then the data subject must reinstall the browser add-ons to disable Google
Analytics. If the browser add-on was uninstalled by the data subject or any
other person who is attributable to their sphere of competence, or is disabled,
it is possible to execute the reinstallation or reactivation of the browser
add-ons.
Further information and the applicable
data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.