MODERN MUSE PRIVACY POLICY

LAST UPDATED: [July 2018]

 INTRODUCTION

Modern Muse’s (“we”, “our”) mission is to empower girls everywhere to make more informed career decisions (“Mission”).

Professional women who are registered on our website (“Website”) and want to inspire the next generation (“Muses”) post relevant content, and respond to questions from registered Website users (“Users”). Users can ‘follow’ Muses to see their public posts on their homepage, ask Muses public questions and respond to events posted by registered companies (“Companies”). Companies can post updates and information on events, such as experience opportunities. Website content is visible to unregistered viewers (“Visitors”), Companies and Users.  Those Services are provided to you through our website and/or mobile application and related Services (together, the “Services”).

Protecting your personal data and maintaining your trust is very important to us. This privacy policy (“Policy”) explains how we collect, use and protect your personal data when you use our Services and applies to any User, Muse or Visitor to the Services. This Policy should be read along with our Terms of Use, which can be found at www.modernmuse.org.

For the purpose of applicable data protection legislation, the data controller of your personal data is Modern Muse CIC (company number: 09738677) of 3 Brad Street, London, SE1 8TN.

PURPOSES OF PROCESSING

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2016/679 and any successor legislation. This includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

COLLECTING YOUR PERSONAL DATA

We collect and use your personal data in the following ways:

When you register as a User and/or teacher:

When you register as a User and/or teacher, we will collect and process the following personal data about you:

Information you give us.

This is information about you that you give us by filling in forms on our Services or by corresponding with us by phone, e-mail or otherwise, or when you report a problem with our Services, or otherwise, use the Services.

Registration information.

We collect information about you, including without limitation, your first name, age, gender, email address, birthdate, name of your school, college or university, and password.

Feedback.

Occasionally, and with your prior consent, we may contact you via email and invite you to provide feedback to improve and manage our capabilities.

You can change or remove your information at any time by updating your profile or by contacting us at [email protected] to delete your account.

When you register as a Muse:

Information you give us.

This is information about you that you give us by filling in forms on our Services or by corresponding with us by phone, e-mail or otherwise, or when you report a problem with our Services, or otherwise use the Services.

Registration information.

You are required to provide information about you and your education and career history to create your profile, such as for instance, your name, job title, location of your work, university, which subjects you studied, languages you speak and country of origin, photograph, which is published on the Services. You can decide how much information you want to add to your public profile. However, your profile may not be published if you do not provide the required or sufficient information, including without limitation as indicated on the registration form by the use of an asterisk (*). Modern Muse reserves the right, in its sole discretion, not to publish your profile and/or information on the Website, or remove your profile and/or information from the Website, if the information you submitted is or becomes, in Modern Muse’s opinion, untruthful, inaccurate and/or incomplete. You understand that by creating a Muse account, Users, Visitors and Companies may be able to identify you. We also collect information needed to set up your account (including without limitation your email address, gender, birthdate, and password).

Feedback.

Occasionally, and with your prior consent, we may contact you via email and invite you to provide feedback to improve and manage our capabilities.

Updates.

As a Muse, we may give you the opportunity to receive updates by email and Twitter. If you register to receive updates, we will send these to the email address you provide to us and/or the Twitter handle you link to in your profile. You can unsubscribe any time via a link in the email footer or by contacting us.

Any information that you provide when you register is covered by our Terms of Use and this Policy. You can change or remove your information at any time by updating your profile or by contacting us to delete your account.

When you use our Services:

Generally.

We automatically log information about you and your computer or mobile device when you access our Services. For example, when visiting our Website, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Website.

Location.

We may, from time to time, offer certain location or pinpoint based services. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorise us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may also collect and store certain information about the users who elect to use such location-based services, such as a device ID. This information will be used to provide you the location-based services. We may use third-party providers to help provide such location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third party providers may use the information only in accordance with this Policy.

COOKIES

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Website and when using our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognise your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers on our Website, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

We use the following types of cookies for the purposes set out below:

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Website and our Services. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Website or use our Services.

Do Not Track Signals. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

USING YOUR PERSONAL DATA

Your personal data will be used in the following ways:

Account operations. We will operate, maintain, and improve our Services, and manage your account, including communicating with you regarding your account and ensuring that you meet the minimum age criteria.

Asking a question. If you are a User and you ask a Muse a question, we will send you an email to let you know when they have replied. You can disable notification emails in your account settings if you do not want to receive these. Please note that Users’ questions will be posted on the Modern Muse Website, along with their first name, and available publicly on the Website.

Legal requirements. As we believe necessary or appropriate, we will use your personal data to (a) comply with applicable laws; (b) comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) enforce our Policy; and (d) protect our rights, privacy, safety or property, and/or that of you or others.

Posting updates. If you are a Muse, when you post an update it will automatically be public to all Visitors and Users. Only post information that you are happy to be made public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Website and/or Services.  Such personal data and other information will not be private or confidential once it is published on our Website and/or Services.

Promotions. With your consent, we will send you marketing emails about upcoming events and other news, including information about services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.”

Receiving a question. If you are a Muse and you receive a question from a User, we will send you a notification email. You can disable notification emails in your account settings if you do not want to receive these.

Searching for events close to you. If you search for experience opportunities and events near you, we will use the location of your device to identify and display those nearest to you. We will not share or retain your location data after the results are displayed.

LEGAL BASES FOR OUR USES OF YOUR PERSONAL DATA

We will only use your personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will update this Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your personal data?

In respect of each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

• Where we need to perform a contract we are about to enter into or have entered into with you, forinstanceour Terms of Use (“Contractual Necessity”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal data for is set out in the table below.
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

Generally we do not rely on your Consent as a legal basis for using your personal data other than in the context of direct marketing communications.

SHARING YOUR PERSONAL DATA

We may share your personal data as follows:

Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.

Our Third Party Service Providers. We may share your personal data with our third party service providers who process data on our behalf to facilitate our Services. These third parties have limited access to your personal data, only perform these tasks on our behalf and cannot disclose or use it for other purposes.

Employees of Modern Muse Corporate Partners.  If you are the employee of a Modern Muse Corporate Partner, we will share your personal data with your employer, in order to verify that you accurately work for that Corporate Partner.

Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.

Corporate Restructuring. We may share personal data in connection with a substantial business transaction, such as the sale of the Services, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We do not transfer your personal data to any parties located outside the European Economic Area. This is includes our staff, representatives and advisors.

SECURITY

We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information section below.

DATA RETENTION

We keep your personal data until your account is terminated or as needed to provide you access to our Services. If you deactivate your account, we will retain your personal data for 30 days and you can reactivate your account should you wish to during this time. After 30 days, your personal data will be deleted and you will no longer be able to reactivate your account.

We may retain your personal data even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, prevent fraud and abuse, or enforce this Policy and our Terms of Use.

OUR POLICY ON CHILDREN

Our Services are not directed to children under 11. To register as a User on the Services, you agree that you are the minimum age of 11 or older. If you are less than 13, your parent, teacher, or legal guardian must agree to this Policy (and our Terms of Use) for you. If you are a teacher or a school, you must have obtained the User’s parents’ or legal guardian’s consent to their child below the age of 13 (13 being excluded) signing up to the Services, including by agreeing to this Policy and our Terms of Use.

If a parent or guardian becomes aware that his or her child under 13 has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.

SENSITIVE PERSONAL DATA

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you are a teacher or User, please note that the name of your school may, in certain circumstances, reveal the pupil’s (or your) racial or ethnic origin, political opinions, religion or other beliefs, or health characteristics. For instance, if your school only admits pupils of a certain faith, the name of your school could constitute sensitive personal data on the pupils.

If you send or disclose any sensitive personal data to us when you submit user generated content to our Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Services.

YOUR RIGHTS

You have the following rights in relation to your personal data:

Opt-out.

You may contact us anytime to opt-out of direct marketing communications. Where you opt out of receiving these marketing messages, this will not apply to service emails in relation to your use of the Modern Muse services.

 Access.

You may access the information we hold about you at any time via your account or by contacting us directly.

Amend.

You can also contact us to update or correct any inaccuracies in your personal data.

Move.

Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget.

In certain situations, for example, when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

Object to processing of your personal data.

This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

Request the restriction of processing of your personal data.

This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.

Withdraw consent.

This right only exists where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the details in the Contact Information section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce.  For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

CHANGES TO THIS POLICY

We may modify this Policy from time to time. If we make material changes to it, we will provide notice through our Website, or by other means so that you may review the changes before you continue to use our Services. If you object to any changes, you must cease to use the Services. Continuing to use our Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes.

COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us (see ‘Contact Information’ section). We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

CONTACT INFORMATION WE HAVE

If you have questions, comments or complaints about this Policy and/or our practices in relation to your personal data, please contact us at [email protected].