Effective Date: December 17, 2019

Conductor LLC cares about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how Conductor collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), applications (“apps”), or other services that refer to or link to this Policy, as well as any offline products, programs, courses, and services (collectively our “Services”). Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.

 

1. INTRODUCTION

Personal Information.  “Personal Information” is data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us. Our Services.  The Services referenced in this Policy include the Services provided by Conductor.  References to “you.”  In this Policy, “you” means anyone who uses our websites, applications, or other Services. This policy  explains how we collect, use, and disclose your Personal Information in the context of your use of our Services.

2. INFORMATION WE COLLECT

The Personal Information that we collect and our use of that information depends on your relationship with us and the requirements of applicable law as described below. We collect information:

• that you provide to us directly.
• that your company provides to us;
• about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies. For more information about these technologies, please see our Cookie Policy
• If you opt in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts; and
• that we obtain from other sources.

INFORMATION COLLECTED FROM YOU Conductor requests different types of Personal Information from you and your company or others, depending on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:

• Contact Information, including your name, mailing address, phone number, email address, and other information that enables us to contact you

INFORMATION COLLECTED ABOUT YOU

• Third-Party Sources. We may obtain Personal Information, limited to name and business contact information, about you from your company. We also may receive Personal Information about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.
• Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to coming to the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about the use of certain online Services.
• Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about the use of each mobile version of the website may be associated with user accounts. In addition, Conductor enables you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools transmit Personal Information to Conductor to enable you to access your user accounts and to enable Conductor to track use of these tools. Some of these tools enable you to email reports and other information from the tool.

ANONYMOUS, AGGREGATED, AND OTHER INFORMATION We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own. In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.

3. USE OF PERSONAL INFORMATION

How we use your Personal Information depends on your relationship with us.  In general, we may use your Personal Information to:

• provide you with our products and Services, including online and offline events, and other materials you request;
• protect against fraud, abuse, or harm and otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means in Conductor’s online environments);
• respond to or fulfill customer service requests;
• analyze, better tailor, and improve our products and Services;
• contact you about our Services, promotions, tailor and provide you with relevant Conductor advertising, enhance your engagement with us, and otherwise communicate with you; and
• comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

Clients.  If you are a client, the Personal Information we may use includes:  

• Contact Information and Professional Information so that we may identify you and contact you, including to respond to inquiries or troubleshooting requests and to deliver notifications and other operational communications;

• Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity, and otherwise provide a Secure Environment (generally, to meet our legal obligations or to meet our legitimate interests);

• Payment Information, where appropriate, to process a financial transaction that you have requested, including your purchase of the Services (generally, to meet our contractual obligations to you); and

• Other Personal Information and company information to tailor our marketing to you and your organization and provide you with the Services, including, but not limited to (i) providing you with performance reports and analyzing trends; (ii) providing Services that you request through our booking and sign-in tools; and (iii) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services.

 

Third-party Application Data

Clients-only. Clients have the ability to provide access to data from a third-party through application integrations such as client-owned Google Analytics data.

• Analytics Integrations. For certain clients, Conductor provides the ability to integrate with third-party providers to augment and enhance reporting capabilities. The data collected from third-party integrations require your explicit consent through granting application access to third-party APIs. Conductor does not use or share any personal information from these third-party application integrations.
• Data Collected. Any client that provides consent to access their data hosted by third-party applications will be limited to analytics data such as (but not limited) to sessions, bounce rates and page views. Clients have the ability to limit what data is provided through configuration within the application. Data collected is stored within our production environment and secured using our standard security policies.
• Data Sharing. No data collected through third-party API access is shared.

Guests and Other End Users.  If you are a visitor or guest who visits our offices, the Personal Information we may use includes:

• • Your name and email address, whether provided by you or your host, to identify you and provide you with a digital or physical access badge;

 

• Contact Information, such as information you submit through our website, so that we may identify you and contact you, including to respond to inquiries that we receive from you;

• Contact Information and Verification Information to protect against fraud, abuse, or harm, verify your identity and the purpose of your visit, and otherwise provide a Secure Environment (generally, to meet our legal obligations or to meet our legitimate interests);

• Payment Information, where appropriate, to process a financial transaction that you have requested (generally, to meet our contractual obligations to you); and

• Other Personal Information to provide the Services, including, but not limited to (i) providing you with WiFi; (ii) processing the data or files that you input, upload, or store with the Services, such as to fulfill search queries that you submit or process documents that you upload to the Services. This Personal Information may vary depending on the length of your visit or the Services that you access.

  LEGAL BASES FOR PROCESSING EU PERSONAL INFORMATION The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others a Secure Environment, and analyzing, improving, and better tailoring our products and Services. We also generally rely on our legitimate interests in marketing our Services to you. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.

4. SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to our service providers and advertisers in order to provide our Services and to improve the end user experience. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.

• Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
• Other Parties When Required by Law and as Necessary to Provide and Protect Our Services.  There may be instances when we disclose your Personal Information to other parties:
  • to provide you with the Services that you or your company request;
  • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
  • to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
  • to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or
  • to protect our rights, property, and safety or that of any of Conductor’s business partners, customers, or employees; and
  • where otherwise required by law.

We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.

• Other Parties in Connection with a Corporate Transaction.  We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
• Other Third-Party Partners, With Your Consent.  We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.

4.1 THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES

We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:

• Third-parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.
• Advertising providers help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.

We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited).

4.2 SOCIAL MEDIA

We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and video with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results. While we will not edit comments, we may delete a comment from our page on a social media site if it, for example, does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language, or if it is a personal attack or hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.

5. RIGHTS IN YOUR INFORMATION: ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

We value your rights to your data. In accordance with applicable law, you may have the right to (i) request confirmation of whether we store, use, or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information or, as described above, object to those uses; (v) seek correction of inaccurate, untrue, or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by Conductor, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at the email or physical addresses set out in Section 12.2 below. We will process such requests in accordance with local laws. To protect your privacy, Conductor will take steps to verify your identity before granting access or making any changes to your Personal Information.

6. OPT-OUT

You have the right to opt-out of certain uses and disclosures of your Personal Information as set out in this Policy, and in specific circumstances, for example related to direct marketing.

6.1 GENERAL

Where you have consented to Conductor’s use of Personal Information, you may withdraw that consent, in accordance with applicable law. Prior to disclosing Personal Information to a third party other than its original purpose or a purpose authorized subsequently by the data subject, Conductor will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, Conductor will comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

• Opting-Out of Marketing Communications.  We provide a means to unsubscribe in our marketing-related email communications. Additionally, you can send an email to optout@conductor.com, please reference “Opt-Out” in your subject line and state in the body of the email that you wish to have your name removed from the distribution lists. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt out of those communications, e.g., communications regarding updates to our Terms of Use or this Policy.
• Collaboration. We do not sell your Personal Information to third parties for their direct marketing purposes. We may partner with other organizations to run events or programs. The Personal Information and other information that you provide to sign up or participate in that event or program will be available to that organization, and you may receive emails or other communications from it after the event. Please refer to that organization’s privacy policy for information on how to opt-out of its communications.
• Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.

7. SUPERVISORY AUTHORITY

For visitors to our Services in the EU, you may lodge a complaint with a supervisory authority if you believe our processing of your Personal Information infringes applicable law.

8. INTERNATIONAL TRANSFERS

Conductor is headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard data protection clauses, to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below in Section 12.2.

9. RETENTION

Conductor will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended. When determining how long this retention period will last, we take into account the length of time Personal Information is required to:

• Continue to develop, tailor, upgrade, and improve our Services;
• Maintain business records for analysis and/or audit purposes;
• Comply with record retention requirements under the law;
• Defend or bring any existing or potential legal claims; or
• Address any complaints regarding the Services.

10. INFORMATION SECURITY

The security of all Personal Information provided to Conductor is important to us. Conductor takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Conductor strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to Conductor, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials or badge with others, logging out when you leave your desk, and other security best practices.

11. AUTOMATED PROCESSING

In the future, we may use automated processes to help us determine your eligibility for new services or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, or request that we restrict the use of your Personal Information for the purposes of these automated decisions.

12. OTHER RIGHTS AND IMPORTANT INFORMATION

12.1 CHANGES TO THIS POLICY IN THE FUTURE

Any information that is collected via the Services is covered by the Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion. If we make any material changes to this Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, as required by applicable law, and we will update the “Effective Date” below to indicate when those changes will become effective. We encourage you to review this Policy periodically to remain informed of how we use and protect your information, and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by Conductor. 

12.2 QUESTIONS OR COMMENTS

If you have any questions or comments regarding our Policy, please contact us at: Conductor ℅ Privacy 2 Park Avenue #1501  New York, New York 10016

Email: privacy@conductor.com  Conductor will address your concerns and attempt to resolve any privacy issues in a timely manner. Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.

13. JURISDICTION-SPECIFIC INFORMATION

California Privacy Rights California residents are entitled to request and obtain certain information about the disclosure of certain categories of their Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals. California residents who are registered members or users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at privacy@conductor.com. In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.