Privacy Policy

Effective Date: April 1st, 2018

You have arrived at www.convene.com (the “Website”), which is owned and operated by Sentry Centers Holdings LLC, a Delaware limited liability company d/b/a Convene (“Convene”). Throughout this Privacy Policy the words “we,” “us,” and “our” refer to Convene and its affiliates, and the words “you” and “your” refer to the user visiting the Website and your institution or organization. This Privacy Policy applies to information that we collect at any website, service or application that posts a link to this Privacy Policy (including any mobile and online versions) and our handling of such information. It also applies to your use of all features, widgets, plug-ins, applications, content, downloads and/or other services that: (i) we own and control and make available through the Website; and/or (ii) that post or link to this Privacy Policy (collectively, with the Website, the “Service”), regardless of how you access or use it, whether via computer, mobile device or otherwise. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Service (unless otherwise stated below). By accessing or using the Service in any manner, you signify your agreement to: (a) this Privacy Policy; (b) the Convene Terms of Use; and (c) any other legal notices, conditions or guidelines located within the Service. If you do not agree to this Privacy Policy or our Terms of Use, please exit now and do not use the Service.

Information the Service Collects

    1. Information You Provide to Us

We may ask you to provide us with information that identifies you personally, such as your first and last name, telephone number, e-mail address, password and mailing address (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Service, including through our Convene-Bot instant messaging assistant, job applications platform, logging into your Member account, content download forms, contact us forms, or when you otherwise interact with the Service.

If you are a Member, you may have the opportunity to create a unique username and password to facilitate access to certain information or features on the Service. Please be aware that it is your responsibility to keep this information secure in order to prevent others from gaining access to your Member information. You agree that you will not share your username or password with others.  If you believe that your username and password have been compromised, please contact us at please contact us at marketing@convene.com

(b) Information Collected or Stored As You Access and Use the Service

In addition to any Personal Information or other information that you choose to submit to us via the Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.

This Usage Information may include:

  • your IP address, UDID, UUID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to the Service;
  • the areas within the Service that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, such as the time and date your Device accesses the Service.

Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. Tracking Technologies include, without limitation, the following:

Cookies. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Service through the Internet. Our cookies do not, by themselves, contain Personal Information, including passwords, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Service and may associate that information with your Account if you have one. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Service. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in the Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Beacons. A beacon is an object that employs wireless technology to locate certain devices. Beacons work by transmitting signals containing unique identification numbers, which can be picked up on by certain applications on nearby Bluetooth-enabled devices, like smart phones. The applications may then be triggered to provide personalized content to the device or to collect information related to the location of the beacon. You can control the interaction between beacons and the applications on your devices that leverage beacon technology.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider strictly necessary to allow you to use and access the Service, including cookies required to prevent fraudulent activity and improve security.

PerformanceRelated. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Service.

FunctionalityRelated. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you visit the Service or keeping track of your specified preferences, including in terms of the presentation of content on the Service.

TargetingRelated. We may use Tracking Technologies to deliver content relevant to your interests on the Service and thirdparty sites based on how you interact with our Service. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Tracking Technologies Choices and Consent

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

Third Party Tracking and “Do Not Track”

There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Further, third parties may use Tracking Technologies in connection with the Service, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. You consent, however, to potentially encountering third-party Tracking Technologies in connection with use of the Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on the Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

(d) Interactions with Third-Party Sites

The Service may include functionality that allows certain kinds of interactions between the Service and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. If we offer and you choose to use this functionality to access or use the Service, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing and interacting with the Service. In addition, we may provide third-party sites’ interfaces or links on the Service to facilitate you sending a communication from the Service.  These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Convene may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on the Service.

How We Use the Information Collected

Generally. We may use your Personal Information or Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Service’s features; (3) to process any inquiry, such as any inquiry or request for use of our locations, and including verifying your information is active and valid; (4) to improve the Service or create new service offerings, to customize your experience on the Service, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Service and, in our discretion, changes to the Service and/or any of the Service’s policies; (6) for internal business purposes; (7) to evaluate your candidacy for a job posting that you have applied for through the Service; and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

How and When We Share Information with Third Parties

We may share non-Personal Information, such as aggregated Usage Information, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information with third parties for those third parties’ direct marketing purposes unless we have given you the choice to consent or withhold consent to such sharing at the time you provide your Personal Information, in which case we will honor your choice. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Convene may also disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on the Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

(b) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) To Protect the Rights of Convene and Others. To the fullest extent permitted by applicable law, we may also disclose your information, including Personal Information, if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Convene or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer. We may share your Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

Your California Privacy Rights

Under California law, California residents who have an established business relationship with us may choose to opt out of our disclosure of Personal Information about them to third parties for direct marketing purposes.  Unless noted at the time of collection, our policy is not to disclose Personal Information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, please contact us at:

Convene

Attention: Legal Affairs

101 Greenwich Street, 4th Floor

New York, NY 10007

marketing@convene.com

Third-Party Content and Links To Third-Party Sites

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you. In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Service onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave the Service and to review the privacy policies and terms of use of all third-party websites that you visit and exercise caution in connection with them.

Changing Your Information and Communications Preferences

You are responsible for maintaining the accuracy of the information you submit to us. The Service may allow you to review, correct or update Personal Information or other information you have provided through the Service’s registration forms or otherwise. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. If you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Convene’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into the Service account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of the Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the information you have provided to the Service or this Privacy Policy or practices described in it, you should contact us in the following ways:

Convene

Attention: Legal Affairs

101 Greenwich Street, 4th Floor

New York, NY 10007

marketing@convene.com

Non-U.S. Site Users

The Service is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and any users accessing the Service from the European Union or the United Kingdom should be aware that the European Commission has not conferred an adequacy statement on the United States. Your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.

By using the Service or providing us with any information, you consent to the collection, transfer, processing and storage of your information, including Personal Information, in the United States in accordance with the terms of this Privacy Policy.

European Union and United Kingdom Users Rights

If you are a user from the European Union or the United Kingdom, upon request, you have the right to:

    1. obtain a copy of the Personal Information we hold about you;
    2. access the Personal Information we hold about you;
    3. request information about the purposes of us processing your Personal Information and the categories of Personal Information concerned;
    4. obtain information on the recipients or categories of recipients (including international recipients) to whom your Personal Information has been or will be disclosed;
    5. request a transfer of your Personal Information from us to another data controller;
    6. in certain circumstances, request the “right to be forgotten” and the erasure of all the Personal Information we hold about you;
    7. the right to lodge a complaint to the supervisory authority in your jurisdiction in respect of your data protection rights; and
    8. the right to withdraw your consent at any time by contacting us as set forth below, however please be aware that such withdrawal of consent will not affect the lawfulness of Personal Information collected, processed and transferred prior to the date of your withdrawal of consent.

There is no charge for any of these requests. For any such request please contact us at:

Convene

Attention: Legal Affairs

101 Greenwich Street, 4th Floor

New York, NY 10007

marketing@convene.com

We will endeavor to respond to such requests in a timely manner, but in no event longer than one month.

Children’s Privacy

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of majority in your jurisdiction, including any information that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent.

If you are a child under 13 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service. In the event that we become aware that we have collected personal information from any child under the age of thirteen (13), we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at:

Convene

Attention: Legal Affairs
101 Greenwich Street, 4th Floor
|New York, NY 10007

marketing@convene.com

Data Security

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use the Service and provide us with your information at your own risk.

Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy anywhere on the Service and your use of the Service at any time indicates your consent to the privacy policy posted at the time of such use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Contact Us

If you have any questions about this Privacy Policy or how we collect or store Personal Information, please contact us at:

Convene

Attention: Legal Affairs
101 Greenwich Street, 4th Floor
New York, NY 10007

marketing@convene.com