Entrepreneurs’ Organization Privacy Notice

Effective: July 8, 2019

This Privacy Notice (“Notice”) covers all of the relevant information applicable to Entrepreneurs’ Organization’s use Our members’, event attendees’, and site visitors’ personal data when using Our products or services, or otherwise interacting with Us, regardless of the channels or means used to interact with Us. This includes:

  • What information We collect about you
  • The purposes for which and how We use your personal data
  • Sharing of your personal data with third parties
  • How long we store your date
  • How to access, control, correct, or delete your personal information
  • How We transfer information We collect internationally
  • Your rights related to Our use of your personal data
  • Other important information related to your personal data

EO needs to process the personal data of its members and other individuals with whom We interact in order to pursue Our charitable purposes and provide members the full benefit of their memberships. We are transparent about what We do with your personal data. We are making this privacy notice easily accessible and available to you at all times at https://www.eonetwork.org/contact-us/privacy-policy to help you to understand the implications of Our use of your data, and the rights you are entitled to in relation to your data.

These are some terms We regularly use in this Privacy Notice:

  • When We refer to Our “Platform”, We generally mean any of the channels or means, digital or in person, you may have used to interact with Us. The main ones are:
    • Our Website, www.eonetwork.org;
    • EO member only accessible Web sites and any related mobile applications, including both any EO or EO event mobile application you may have installed on your mobile device;
    • In person, at any EO organized event.
  • We offer a wide range of products and services as Well and We may enable your interaction with EO members, strategic alliance partners, and other third parties. We refer to all of these products and networking capabilities, together with Our other services, applications and Websites as "Services" in this policy.

Your use of Our Platforms and/or Services are contingent upon your acknowledgment of understanding and acceptance of the terms of this Notice. If you do not agree with this notice, you may not access, use, or interact with any of Our Platforms or Services.

1. WHO IS THE CONTROLLER OF YOUR DATA

ENTREPRENEURS’ ORGANIZATION, a District of Columbia non-profit corporation with a principal place of business located at 500 Montgomery Street, Suite 700, Alexandria, VA 22314, USA (“EO” “We”, “Us”, “Our”) is the controller of your personal data. This means that EO is responsible for processing and protecting your personal data.

You can contact EO with any inquiries about Our use of your personal data or this Notice by writing to EO’s Data Protection Officer at the postal address listed above or to the following email address: [email protected]

2. WHY WE PROCESS YOUR PERSONAL DATA

Depending on the purpose for which We process your data from time to time, as explained above, We generally need to process one or more of the following general categories of personal data:

  • your identity data (for example, your name, surname, language and country from which you interact with EO, contact data, etc.);
  • economic and transactions information (for example, your payment or card data, information on any transactions, payment of dues, refunds, reimbursable expenses, etc.);
  • connection, geolocation and/or browsing data (if you interact with EO from your mobile phone, for example);
  • commercial information (for example, if you have subscribed to any of EO’s newsletter(s) or other communications),
  • information about your tastes, preferences, browsing habits;
  • information about your business dealings, including any companies you may own or operate

When We ask you to provide your personal data to give you access to any functionality or service of any of Our Platforms, We will mark certain fields as compulsory, since this is information that We need to be able to provide the Service or give you access to the functionality in question. Please be aware that if you decide not to make such data available to EO, you may be unable to complete your member registration and unable to enjoy the Services EO provides.

Depending on how you interact with Our Platforms, i.e., if you are an EO member, if you are a website visitor, or if you are an EO event attendee as a member or guest, and generally, depending on the services, products or functionalities that you wish to enjoy, We will process your personal data for the following purposes:

PURPOSE

INFORMATION

EO MEMBERS

1. To manage your membership with EO, including providing access to any of Our digital Platforms

We need to process your data to identify you as a user of the relevant Platform and grant you access to various Services available to you as an EO member. We collect information about you when you input it into Our Platforms or while you use Our Services or otherwise provide it directly to us. You have the option of adding a display name, profile photo, job title, your company information and other details to your profile information to be displayed in Our Services. We keep track of your preferences when you select settings within the Services.

The Services also include Our Websites and mobile applications owned and operated or licensed by EO. We collect other content that you submit to these Websites, which include social media or social networking Websites operated by Us. For example, you provide content to Us when you provide feedback or when you participate in any EO interactive features, surveys, contests, promotions, activities or events.

We collect information about you when you interact with Our Platforms, including browsing Our Websites or social media pages, and taking certain actions within those Platforms.

We collect information about you when you use Our Services, including visit Our site and/or interacting with any of Our Platforms, the features you use; the links you click on; the type, size and filenames of attachments you upload, and how you interact with others on the Platforms.

We collect other content that you submit to these Services, which include social media or social networking Websites operated by Us. For example, you provide content to Us when you provide feedback or when you participate in any EO interactive features, surveys, contests, promotions, activities or events.

We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use Our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information We collect depends on the type and settings of the device you use to access the Services.

2. To manage the personal data provided to Us by third parties related to your access to Our Platforms or use of Our Services

We receive information about you when you or your chapter administrator integrate or link a third-party service with Our Services. For example:

  • If you create an account or log into the Services using your Google credentials, We receive your name and email address as permitted by your Google profile settings in order to authenticate you.
  • You or your chapter administrator may also integrate Our Services with other services you use, such as to allow you to access, store, share and edit certain content from a third-party through Our Services.
  • You may authorize Our Services to access, display and store files from a third-party document-sharing service within the Services interface.
  • You may authorize Our Services to connect with a third-party calendaring service so that your meetings and connections are available to you through the Services.
  • You may authorize Our Services to sync a contact list or address book so that you can easily connect with those contacts within the Services or invite them to collaborate with you on Our Services.

The information We receive when you link or integrate Our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to Us or shared with Our Services.

3. To provide any Services, including organizing events, in pursuit of EO’s charitable purpose.

We need to process the personal data you provide to Us to provide Our Services. Those can include:

  • When you register for events in order for EO organize and manage and such events as a benefit of your EO membership. Such processing may involve the sharing of your personal data with third party service providers involved in the organization and management of events.
  • The EO products you use, where We collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content We collect and store include: your name, your email address, your company name and any feedback you provide to Us. Content also includes the files and links you upload to EO Services.
  • To contact you for updates or informative notices related to the Services or events, including quality surveys and to be able to establish the degree of member satisfaction with the provided service;
  • EO collects feedback you provide directly to Us through Our digital products and We collect clickstream data about how you interact with and use features in EO Services.

4. Processing of payments and related activities.

We collect certain payment and billing information when you register for certain paid Services including event registration, membership and membership renewal.

This purpose includes processing your data, mainly:

  • To designate a billing representative, including name and contact information, upon registration.
  • Provide payment information, such as payment card details, which We collect via secure payment processing services.
  • To manage payments, regardless of the payment procedure used.
  • Activate the necessary arrangements in order to control and prevent potential fraud against you and against Us during any payments.
  • For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Platform.
  • To process refunds, or payments of reimbursable expenses or otherwise

5. To meet requests or applications that you make through EO’s support channels.

We only process the personal data strictly necessary to manage or resolve your request or application. This includes Our member support Platforms, where you may choose to submit information regarding a question or issue you are experiencing with an EO Service. Whether you designate yourself as a member, open a support ticket, speak to one of Our EO staff members directly or otherwise engage with Our support team, you will be asked to provide contact information, a summary of the question you have or issue you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

6. For marketing purposes.

This purpose includes the processing of your data, mainly, for:

If and when you subscribe to any of Our newsletters or other communications, We will process your personal data to manage your subscription, including to send customized information on Our products or services through various means (such as e-mail or SMS). We may also make available to you this information through push notifications in case you have activated them in your mobile device.

  • Accordingly, please take into account that this data processing implies analysis of your user or member profile to establish your preferences and therefore which products and services are most fit to your style when sending you information. For example, based on your profile, company, use of Our Platforms, and browsing history (i.e., depending on the articles that you clicked), We will make you suggestions on Services, events or other content that We believe may interest you.
  • Remember that you may unsubscribe from any of Our newsletters or other communications at any time without cost by following the instructions that We provide you within each communication. If you do not want to receive push notifications, you can deactivate this option in your mobile device.
  • To perform promotional actions.
  • To disseminate in the Platform or through Our channels in social networks photographs or pictures taken during your use of Our Services, that you shared.

7. Analysis of usability and quality to improve Our services

If you access any Our Platforms, We will use your browsing data for analytic and statistical purposes, i.e., to understand the manner in which users interact with Our Platform(s) and thus be capable of introducing improvements in the Platform(s).

In addition, We occasionally perform quality surveys and actions to know the degree of satisfaction of Our members and detect those areas in which We may improve.

ALL SITE VISITORS, PLATFORM USERS, AND EO EVENT GUESTS

1. Visit Our Website or interact with any of Our other Platforms

We collect information about you when you interact with Our Platforms, including browsing Our Websites or social media pages, and taking certain actions within those Platforms.

We collect information about you when you use Our Services, including visit Our site and/or interacting with any of Our Platforms, the features you use; the links you click on; the type, size and filenames of attachments you upload, and how you interact with others on the Platforms.

We collect other content that you submit to these Services, which include social media or social networking Websites operated by Us. For example, you provide content to Us when you provide feedback or when you participate in any EO interactive features, surveys, contests, promotions, activities or events.

We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use Our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information We collect depends on the type and settings of the device you use to access the Services.

2. Express interest in EO, or apply for EO membership

We process your personal data when you express interest in EO or apply for EO Membership. This data can include your name, surname, location, business name and type, business size, and other personal data.

3. Register for an event as an EO guest

We need to process the personal data you provide to Us to organize and manage any EO events you might attend as an EO guest.

  • When you register for events in order for EO organize and manage and such events as a benefit of your EO membership. Such processing may involve the sharing of your personal data with third party service providers involved in the organization and management of events.

4. For marketing purposes

This purpose includes the processing of your data, mainly, for:

  • If and when you subscribe to any of Our newsletters or other communications, We will process your personal data to manage your subscription, including to send customized information on Our products or services through various means (such as e-mail or SMS). We may also make available to you this information through push notifications in case you have activated them in your mobile device.
  • Remember that you may unsubscribe from any of Our newsletters or other communications at any time without cost by following the instructions that We provide you within each communication. If you do not want to receive push notifications, you can deactivate this option in your mobile device.
  • To perform promotional actions.
  • To disseminate in the Platform or through Our channels in the social networks photographs or pictures taken during your use of Our Services, that you shared publicly, or that you otherwise provided to EO.

5. Processing information received from third parties

If you access Our Platform, We inform you that We will use your browsing data for analytic and statistical purposes, i.e., to understand the manner in which users interact with Our Platform and thus be capable of introducing improvements in the Platform.

We may receive information about you from third-party services, and from EO’s strategic alliance partners.

3. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

The legal basis for EO’s processing of your personal data depends on the purpose for which that data is being processed.

  • For members:

    • Our legal basis for processing member personal data, is in pursuit of Our legitimate interest in furthering Our charitable purpose and providing you your membership benefits. You may object to any instance of Our processing of your personal data based on Our legitimate interest at any time.
    • In certain circumstances, we might process your data based on the legal basis of requirements related to the fulfillment of Our contractual obligations.
  • For visitors, non-member Platform users, non-member EO communications subscribers, and/or non-member EO event guests:
    • Our legal basis for the processing of your personal data is the consent you are required to provide to EO prior to any use of any of Our Services or Platforms. You have the right to withdraw this consent at any time.

4. HOW LONG WILL WE KEEP YOUR DATA

Entrepreneurs’ Organization has established data retention categories associated with EO’s legitimate use of your personal data. In no event will EO retain any of your personal data for any longer than is necessary to perform the purpose for which EO is processing that data or otherwise legally obliged to retain it. When EO asks you to share your personal data with EO, you may request information related to the associated retention period to allow for your informed decision making. You will always be provided with the option to opt-out of any personal data collection activity. Personal data retention periods will also be maintained on eonetwork.org under the Privacy Tab.

5. SHARING WITH THIRD PARTIES

EO does not sell your personal data.

To achieve the purposes mentioned in this Notice, We must give access to your personal data to EO affiliate entities and to third parties that provide EO with support in the services that we offer, including, without limitation:

  • EO chapters
  • EO related entities
  • Event venues
  • Technological service providers, including Web hosts and communication service providers;
  • Social media service providers
  • Partners and service providers EO hires for marketing and advertising services (e.g., e-mail newsletter services);
  • Merchandising and other related service providers;
  • Logistic, transport and delivery partners and service providers;
  • Providers of customer support related services;
  • Financial institutions;
  • Anti-fraud detection and prevention entities.

For efficiency and effectiveness of providing the Services, some of these providers are located in territories outside the European Economic Area, including territories that do not offer a level of data protection comparable to that of the European Union, for example, in the United States of America. In such cases, We inform you that We will transfer your data with adequate safeguards in place to keep your data safe. Such safeguards include the use of executed Standard Contractual Clauses approved by the EU Commission, the content of which you may review at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

6. YOUR RIGHTS

We will use reasonable efforts to keep personal data confidential and to ensure that you may exercise your rights related to your personal data. You may exercise your rights free of charge by writing EO an e-mail at ([email protected]) that informs EO of the reason for your request and the right(s) you are seeking to exercise. If EO considers it necessary to verify your identity you to process your request while also protecting your personal data, We may request you to provide a copy of a document evidencing your identity.

  • General rights of all data subjects: notwithstanding the purpose or legal basis We use to process your data, you have the following rights:
    • To request access to your personal data that We hold. We remind you that where you are an EO member, you can review this information by visiting your online account.
    • To request that We rectify the personal data that We hold. For EO members, you may be able to access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to Us through any procedure, you guarantee that they are true and accurate and you undertake to notify to Us any change or modification of your data. You will be liable for any loss or damage caused to the EO or Our Platforms or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide Us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.
    • To request that We erase your personal data to the extent that they are no longer necessary for the purpose for which We need to keep processing them, as We have explained above, or when We are no longer legally permitted to process them.
    • To request that We cancel or limit the processing of your personal data. In certain cases this will entail your right to request We temporally suspend the processing of the data or that We keep them longer than legally necessary.
  • Rights of data subjects whose data is processed on the legal basis of their consent:
    • if you have given EO your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.
  • Rights of data subjects whose data is processed on legal basis of consent or fulfillment of a contractual obligation
    • When We are legally permitted to process your data due to your consent or to for the purposes of a contract, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to Us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on Our part.
  • Rights of data subjects whose data is processed on the legal basis of EO’s pursuit of its legitimate interests: where the processing of your data is based on EO’s legitimate interest, you will also have the right to object to any instance of the processing of your data.
  • Right to complain to relevant authority: We also want to ensure we notify you that you have the right to file a complaint or a claim before the responsible data protection regulatory authority related to any EO violation related to EO’s processing your personal data.

7. CHANGES TO PRIVACY POLICIES AND NOTICE UPDATES

We may amend the information contained in this Notice from time to time, when appropriate. If we update the Notice, We will use reasonable efforts to notify you of those changes through EO’s Platforms. For example, by means of a banner, a pop-up or a push notification when visiting EO’s Platforms. In certain cases EO might even send a notice directly to your e-mail address if the changes in question have a material impact on your privacy rights. That way, you will be able to review the changes and object to them or unsubscribe from any of the impacted Services. Regardless, EO suggests you occasionally review this Notice should We make minor changes to it or undertake any interactive improvement to Our Platforms or Site.

8. COOKIE POLICY

EO utilizes cookies to “remember” your online preferences on Our owned Website, eonetwork.org, including the number of results you wish displayed from a query. We also use cookies and similar devices to facilitate your browsing in Our Platforms, understand how you interact with Us, and, in certain cases, to be able to show you advertisements or provide other customized content to you in accordance with your browsing habits.

For your reference www.eonetwork.org uses both Google Analytics and Live Chat Inc. cookies to function properly.