At Kickstart Capital, LLC (“Kickstart”), we are committed to protecting personal information. In this Privacy & Cookie Notice (“Notice”), Kickstart and its affiliated entities (“Kickstart,” “we,” or “us”) set out how we, as data controller, may collect, create, share and use personal information relating to identifiable individuals (“Personal Data”) and provide you with information regarding your Personal Data rights and choices as it relates to your use of the www.kickstartfund.com website.
By using the Kickstartfund.com website you represent that you agree to the policies described herein. If you do not agree with these terms, you must not use the website.
1. Scope of this Notice
This Notice describes Kickstart’s privacy practices for Personal Data collected by Kickstart websites (“Sites”) as well as other activities, such as if you visit our offices, attend a Kickstart event or otherwise interact with Kickstart and provide Personal Data, such as corresponding by email, unless such activities are covered by our other notices outlined below. Please read this Notice in full. By using our Sites or participating in other activities with Kickstart described below, you consent to the collection, creation, sharing and use of information as described in this Notice, where consent is required by relevant law.
Kickstart also operates public forums on Kickstart websites. The purpose of these forums is to discuss our products and services and encourage collaboration between our portfolio companies as well as others. Please note that any Personal Data you choose to post in Kickstart Collective or other forums may be read or used by other visitors (for example, to send to you unsolicited messages). Kickstart forum users should not upload sensitive or confidential content on this public forum.
For indirect customers (through a Kickstart partner), while Kickstart’s collection and processing of your Personal Data is explained below in this Notice, any direct Personal Data sharing by you with a Kickstart partner will be governed by that Kickstart partner’s policies/your agreement with them.
As a convenience to visitors to our Sites, we may also provide links to other websites that are not governed by this Notice. These linked websites are not under the control of Kickstart and we are not responsible for the content on such websites or the protection/privacy of any information which you provide while visiting such websites.
2. Personal Data we may collect
The Personal Data Kickstart may collect about you will depend on your interaction/relationship with us.
It may include:
- if you browse our Sites, information systems data relating to your interaction with our Sites, such as location (e.g., IP address), cookie related information (see section 6 below), usage (e.g., mouse clicks, page visits, feature usage, view time, downloads) and other information, such as language preference.
- if you complete a webform on our Sites (e.g., to attend a Kickstart event or submit a pitch), attend a Kickstart event (online or in-person) or office, or otherwise send this data to Kickstart (e.g., by email, telephone, exchange of business cards), identifying/contact information such as your name, job title, work email, organization/employer name, work telephone, and location information such as work address;
- if you attend a Kickstart event (in-person or online) or our offices, your attendance details (e.g., entry time);
- if you avail of Kickstart services, such as attend a training class or submit a technical support case, your activity with Kickstart to interact with and take part in these services;
- your image and/or voice, such as for phone/video call recordings (for training, quality assurance and administration purposes), if you attend a Kickstart event (event recording) or office (e.g., CCTV), post an image/recording to a Kickstart Site (e.g., add a profile photo to Kickstart Community) or you otherwise send a recording/image to Kickstart;
- information from otherwise engaging/interacting with you, such as your feedback to us through our Sites and responses to any promotional or survey communications; and/or
- information considered sensitive under local law, namely health information, if you visit our offices or attend an in-person Kickstart event and, if due to local COVID-19 related requirements, you are required to provide information regarding your health, vaccination status and recent travel history; and/or if in the course of visiting our offices or attending a Kickstart event, if you choose to disclose to us disability-related health information for the purpose of us making an accommodation/adjustment. Kickstart will only ever process sensitive information in connection with the purpose for which it was collected, for example to comply with local health & safety laws.
We may also collect Personal Data about you from third parties, such as from colleagues of yours at your organization (e.g., when registering multiple participants at an organization/company for Kickstart training, or where your details are provided by a colleague as a contact for your organization’s account), public sources (e.g., your organization’s website, LinkedIn), vendors (e.g., web analytics tools, data enrichment providers) and Kickstart partners (e.g., where your contact details are provided to enable delivery of Kickstart software, for customer success purposes and/or in relation to maintenance/support, including renewal and/or cancellation of same). We also maintain social media pages and may collect Personal Data from you when you interact with these or communicate with us through our social media pages.
3. Use of Personal Data
Depending on your relationship with Kickstart, we may use your Personal Data for different purposes. Where required by applicable law in relation to the particular use, we will obtain your consent to collect and use your Personal Data. Otherwise, we will rely on another legal basis, such as in connection with a contract or for our legitimate interests, as set out below.
- Perform a contract: We may process your Personal Data in connection with a contract with you or your organization, such as to process relevant payments, deliver (customer) or receive (vendor) products/services, manage our relationship with you as a Kickstart partner under our Kickstart partner agreement with you, and manage our relationship with you or your organization generally throughout the contract lifecycle, including managing renewals.
- Operate our Sites: We may use your Personal Data to provide our Sites, content and offerings (e.g., downloads, registrations for accounts or profiles, such as a Kickstart Account), including necessary functionality, content customization (e.g., based on what we think will interest you), and functionality to enhance ease of use (e.g., make the Sites easier for you to use by not making you enter information more than once, etc.). Unless such processing is in connection with a contract or our legitimate interests, it will be on the basis of your consent.
- Manage contact requests: We may use your Personal Data to reply to contact initiated by you, such as through a webform, chatbot, survey responses or Kickstart support. We process your Personal Data for these purpose for our legitimate interest in replying to/fulfilling your request, collecting survey responses and to carry out our contractual obligations under the applicable terms (e.g., providing Kickstart support).
- Other communications: We may use your Personal Data to otherwise communicate with you to manage our relationship with you/your organization, such as to manage our offerings, for customer success purposes, to contact you regarding updates to our offerings you may be interested in, and to run surveys and contests. Such processing will be to fulfil our contractual obligations, where necessary for our legitimate interests or, where legally required, with your consent.
- Call recording: We may record phone or video calls (e.g., Zoom) for training, quality assurance and/or administration purposes. We process this Personal Data on the basis of our legitimate interests however, if required under applicable law, we will obtain your consent or give you the option to object to the call being recorded.
- Marketing: We may use your Personal Data to contact you for marketing purposes, such as to alert you to product upgrades, special offers, updated information/services from Kickstart, and to contact you (e.g., by phone or email) regarding your interest in our offerings and/or invite you to Kickstart events. Such contact will be on the basis of legitimate interest or, where legally required, on the basis of your consent. To opt-out of marketing contact, please unsubscribe here firstname.lastname@example.org.
- Events: We may process your Personal Data to operate Kickstart events, including training/education related activities, in-person and online, that you have selected to attend. Such processing will be on the basis of our legitimate interests or to perform a contract with you under the applicable terms of service.
- Manage premises: Where you attend our offices, we may process your Personal Data to administer our premises and fulfil our legal obligations regarding health and safety, and to manage the security of our premises to ensure there is no unauthorized access. Such processing will be on the basis of our legitimate interests and/or to carry out our legal obligations.
- Compliance and Security: We process your Personal Data to comply with our legal obligations and to ensure compliant use/security, such as to ensure the use of our Sites, content and offerings in compliance with our terms and/or to ensure their security, to cooperate with courts, regulators or other government authorities to the extent processing/disclosure of Personal Data is required under applicable law, where it is necessary to protect our legal rights or those of others, or for other compliance purposes such as auditing, investigations and responding to legal processes or lawful requests. Where we process health related data for Covid-19 related reasons or to accommodate a reasonable adjustment for a disability, we will only do so to carry out our legal obligations relating to health and safety, under applicable law.
- Professional advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
- Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
We may also combine Personal Data we hold about you. For example, we may combine your B2B contact with your usage data relating to our offerings and our Sites for the purposes above, such as to improve our Sites and our offerings, as well as to create more tailored experiences by providing content that may be of interest to you. We may also use your Personal Data to fulfil any other purposes disclosed to you at the time of collection or as otherwise required/permitted by applicable law.
4. Sharing Personal Data
Kickstart may share Personal Data for various purposes, such as:
- within the international group of Kickstart companies to operate our business and provide our Sites, products and services;
- with authorized Kickstart vendors, advisors and contractors providing services on our behalf (such as a technology or professional service providers) to operate our business, Sites, products and services;
- if you register for or attend a Kickstart event, Kickstart may share participant information (e.g., your name, organization, work email) with other participants, organizers or hosts of the same event in order to facilitate the event and the subsequent exchange of ideas. Kickstart may also share your contact details with event sponsors where you have consented, e.g., through registration, to these sponsors contacting you regarding their own offerings. Your contact details may also be used by other hosts of the same event, such as to send marketing material, according to their privacy notices provided to you;
- third-party networks/websites so that we can advertise on their platforms;
- if you use Kickstart products and services, we may share with your organization/colleagues certain data, such as your download and usage data of Kickstart products and/or your use of Kickstart support;
Kickstart will only share Personal Data to the extent needed to perform the relevant use and will take such steps as are necessary to safeguard Personal Data. For example, our vendors, advisors and contractors are required to keep such Personal Data confidential and not to use it other than for the purposes intended. Kickstart partners are obliged to comply with the privacy rules set out in their agreement with Kickstart. Kickstart does not sell or rent Personal Data to third parties.
Kickstart may also disclose Personal Data to comply with legal requirements, such as in relation to legal proceedings or investigations by governmental or law enforcement agencies, or to meet tax or other reporting requirements, including to (a) protect and defend the rights or property of Kickstart, including the defense and management of legal claims and investigations, (b) act in urgent circumstances to protect the personal safety of users our Sites, our Kickstart team members, or the public, (c) as part of a merger or change in corporate ownership or control, and/or (d) as otherwise permitted or required by applicable law.
5. Non-residents of the United States or Canada
Kickstart is a U.S. company and seeks to interact only with residents of the United States and Canada. If you are a resident of a country other than the United States and Canada you are not authorized to use, access, or view any Kickstart Site and we ask that you immediately terminate any browsing session of the Site.
6. Cookies and similar technologies
As is true of most websites, when you visit our Sites, cookies will be placed on your device (computer, mobile or tablet). A "cookie" is a small text file that is placed on your device by websites you visit. Some of the cookies we use are strictly necessary to operate our Sites. Others relate to the Site's performance, functionality and/or to advertising. Information relating to a cookie or similar technology may include identifiers such as IP address, and information like general location, browser type and language, and internet activity such as timestamps. Kickstart uses the following types of cookies and similar technologies on our Sites:
A. Strictly Necessary: These cookies enable the Sites to function correctly and deliver the services and products you have requested. These cookies do not gather information about you that could be used for marketing or remembering other websites you have visited on the internet.
B. Functional: These cookies do things like remember your preferred language, understand your preferences and associate users to forms submitted to enable pre-completion of subsequent forms as well as improve and customize your experience on our Sites.
C. Performance: We use third-party analytics tools to help us analyze how our Sites and other electronic mediums are used, such as allowing us to compile reports on website activity, providing us other services relating to website activity and internet usage and whether email communications are opened or left unread.
D. Advertising: These cookies may be set on our Sites by our advertising partners. They may be used to build a profile of your interests and/or show you relevant adverts on other sites. If you wish to not have your online information used for this purpose you can also visit resources such as https://optout.networkadvertising.org and/or https://www.youronlinechoices.eu (please note these and similar resources do not prevent you from being served ads as you will continue to receive generic ads).
7. Protection of Personal Data
Kickstart takes appropriate precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Such measures may include some of the following: (i) using security controls such as, passwords, firewalls and/or encryption, (ii) restricting Personal Data to those with a legitimate purpose in receiving/accessing it, (iii) deidentifying Personal Data, or assigning codes or pseudonyms when the personal identifiers are not required for the purpose at hand, (iv) using data retention controls to ensure that Personal Data is not kept for longer than is necessary, (v) providing training and internal policies to team members to embed privacy and security across our organization, and (vi) putting in place relevant procedures (such privacy and security vetting) and contracts relating to the use and protection of Personal Data with third parties.
8. How long we retain Personal Data
Kickstart will retain and process Personal Data for a period of time consistent with the purpose of collection (see section 3 above) and/or as long as necessary to fulfil our legal obligations. We determine the applicable retention period by taking into account the (i) amount, nature and sensitivity of the Personal Data, (i) relevant use, including whether we can achieve the use through other means (e.g., by instead using deidentified data); (iii) potential risk of harm from unauthorized use or disclosure of the Personal Data, and (iv) applicable legal requirements (e.g., statutes of limitation).
9. Children's Privacy
Kickstart does not knowingly or intentionally collect information from anyone under the age of 16, and we request that anyone under the age of 16 does not submit Personal Data to us. If you become aware that a child has provided us with Personal Data, please contact us at email@example.com. If we become aware that someone under the age of 16 has submitted Personal Data, we will delete this information from our records. If you are under the age of 16 you must exist this Site immediately.
10. Contact Information
For privacy inquiries or complaints, or to otherwise contact Kickstart’s, please email firstname.lastname@example.org.
Changes to this Notice
Kickstart reserves the right to modify or update this Notice from time to time to reflect changes in technology, our practices, law and other factors impacting the collection/use of Personal Data. You are encouraged to regularly check this Notice for any updates. We may also collect, use and disclose Personal Data for other purposes otherwise disclosed to you at the time of collection/processing in a supplementary notice.