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Unreasonable Privacy Statement
This statement was last updated April 16, 2018.
Unreasonable offers a variety of products and services, including websites (such as unreasonablegroup.com), digital communications platforms (such as Flow), media publications (such as unreasonable.is), event planning and production, and other services. This Privacy Statement is designed to help you understand how we collect, use, and share your information and what choices you have with respect to the information when interacting with any of these products and services, collectively referred to hereafter as "Services".
Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Statement. This Privacy Statement may change from time to time (see Changes to this Privacy Statement). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
When we refer to "Unreasonable", "we", or "us", we mean the business entity Unreasonable Alchemy, LLC.
When you engage with one or more of our Services, we may collect "Personal Information" from you, meaning information that identifies you as an individual or from which you may be identified. Depending on the Service with which you are engaging, we may collect:
We collect contact information such as your name, company affiliation, mailing addresses, email addresses, online service (e.g. Twitter) usernames and/or identifiers, and telephone numbers.
We may record and/or keep notes about our communications with you and vice versa.
If you engage with one of our in-person event Services, we may collect Personal Information such as government identification numbers, your gender, your date of birth, frequent flyer account details, known traveler number, travel documents, and flight, hotel, and other travel-related dates, arrangements and locations.
If you provide it, we collect Personal Information such as food allergies, emergency health conditions, and sleep preferences to provide a safer, more pleasant in-person experience. Please read more about our policy for this type of information under "Voluntary Collection of Sensitive Personal Information".
We collect information about how you interact with our Services, information you provide directly to us, and information that you publicize such as work and educational history, biographical information, information about your skills, interests, and needs, information about your role and actions in conducting your business, feedback and suggestions, communications with others through our Services, fundraising information, and investment accreditations and preferences.
We also collect information about and from other people that interact with our Services. This information may include your Personal Information. For example, we may collect a group photograph including you that is provided by another person in the group, or we may retain a record of a communication sent from somebody else to you through our Service.
We may collect data that includes your Personal Information from third parties such as LinkedIn (if you register for our Services with LinkedIn), partner organizations, news publications, and/or public databases.
Photographs and video footage are captured at most of our in-person events. This media may include your likeness. Additionally we may obtain photos or videos from other sources (such as LinkedIn) when you choose to engage with our Services.
We collect Personal Information needed to comply with our contractual or legal obligations, such as date of birth information for attendees of events with alcohol present, and government identifiers and payment information for contractors and vendors.
We collect technical Personal Information about your use of our Services such as your IP address, information about your device or browser setup, records of interactions with our emails, and records of your interactions with each Service.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about any third-party content, you should contact the responsible provider directly.
If you voluntarily share "Sensitive Personal Information" (i.e., Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation, or judicial data) with us, that information may be used to provide a better experience and meet your particular needs. For example, if you voluntarily convey a health-related need to us, we may store and use that information in order to provide a hotel room with appropriate amenities, or to provide you with meals that are compatible with medical dietary restrictions. We do not collect or store Sensitive Personal Information unless it is voluntarily provided by you. By providing such Sensitive Personal Information, you expressly consent to our collection, processing and storage of that information in accordance with the terms of this Privacy Statement.
We will use your Personal Information only in the ways that are described in this Privacy Statement below:
Since our business focuses on connecting people, we use your Personal Information regularly to provide our Services. For example, Personal Information is used to select, advertise, and assist ventures participating in our event Services, and Personal Information is shared among our community via our online community Service, Flow. Personal Information collected concerning your usage of our Services will be used to analyze and improve those Services. If we have a contractual relationship with you or your company, we will use Personal Information in accordance with this statement and our contract.
We use your contact information to send you emails and other communications such as invitations to our own Services and services provided by third parties, announcements, newsletters, and transactional notifications. We will respect your request to limit or prohibit our communication with you.
If you will be attending one of our in-person event Services, we use your Personal Information to plan, book, and manage your travel, lodging, and dining, and maintain a safe, happy, and healthy environment at the event.
We may use your personal information to facilitate opportunities across our global community. Our online directory Service, Flow, may allow others in our community to discover and communicate with you. You can choose to limit the disclosure of your contact information wherever you provide it in Flow.
When you make a request to us, or another individual through our Services, or otherwise indicate a purpose for sharing Personal Information, your Personal Information may be used in efforts to fulfill that request or purpose.
We are dedicated to providing the best, most impactful Services possible. In order to do this, we use Personal Information such as Service usage information to analyze and improve our Service offerings, and to report back to our Service Co-Creators.
Your feedback, suggestions, and usage information are used to design and market new Services.
We use analysis of Personal Information to keep our Services secure and to prevent misuse.
With your consent, we may publish limited Personal Information such as your name, photographs, and/or video footage for marketing or editorial purposes.
Personal Information will be used to comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process when necessary.
We will share your Personal Information with third parties only in the manners as set forth herein and as described in this Privacy Statement below:
We share Personal Information with members of our global community including participants of our in-person event Services, as well as with users of our online community Service, Flow. For example, when you attend a program, other individuals at the program will be provided with some of your Personal Information. And when you create an account on Flow, others on Flow will be able to see the Personal Information you provide depending on the privacy settings you have chosen.
Occasionally, when we deem it beneficial for both parties, we may share Personal Information to make introductions between you and another member of our community directly.
We may also, depending on your level of interaction with our Services, share limited Personal Information (such as your name, title, and photograph) on public-facing Service-related websites or marketing materials.
When you interact with or send communications to others through our Services, you choose to share certain Personal Information to those with which you are sharing. For example, if you send a request to connect to an individual through our online community Service, Flow, that individual will receive your contact information and any other Personal Information you provide in your message.
Other people using our Services may post content or send communications to others that contain Personal Information about you. For example, someone may share a photograph including you, or pass on information that you provided to them. If you have concerns about how others are sharing your Personal Information, you may contact either the person who has shared the information, or Unreasonable (see "How to Contact Us" below) to discuss remediation.
If you engage with one of our Services, we will use and share your Personal Information in ways necessary to provide that Service. For example, if you submit content to our editorial site unreasonable.is, that content and the Personal Information you provide may be shared with the public audience of the site.
In many cases, we work with other entities such as corporations and government agencies ("Co-Creators") to produce and maintain our Services. We may share Personal Information with Co-Creators for a number of purposes such as assessing the impact of the Service, and providing assistance to our global community.
We may share Personal Information with our corporate affiliates, parents and/or subsidiaries.
We rely on a number of trusted third-party service providers or individuals, acting on our behalf, to operate certain aspects of our Services and support our business. For example, when necessary we provide Personal Information to travel, lodging, and dining providers in order to facilitate in-person event logistics management. Additionally, we rely on third-party services such as cloud hosting, email delivery, and analytics services to operate our digital platforms.
We choose third-parties carefully. We evaluate our service providers' privacy, security, and confidentiality policies and practices to ensure they meet or exceed the standards in our own Privacy Statement.
We may share anonymized or aggregated data with trusted third parties at our discretion so long as you cannot reasonably be identified as an individual.
In the event that Unreasonable goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement and any changes thereto.
We may use your Personal Information to uphold our ethical, contractual, and legal rights or obligations, to enforce our Terms of Service and other policies, and to protect the rights, property, or personal safety of Unreasonable, its employees, its users, its clients, and the public. For example, we will provide law enforcement with the Personal Information of an individual using our Services in a manner that is threatening to others.
Under certain circumstances your Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We may be obligated, in accordance with applicable law, to share your information upon your request. We may provide additional notice and ask for your consent if we wish to share your information in a materially different way than discussed in this Privacy Statement.
If you would like to access, correct, update, delete, or limit the sharing of your Personal Information, we will work with you to the best of our ability to fulfill your request.
In most cases you may access, correct or update most of it through our online Service, Flow. You may also modify and delete certain Personal Information, or update your consent status. Please note that you may not be able to delete certain content that has been shared with others through our Services and that you may not be able to delete information that has been shared with third-parties, though we can work with you to prohibit your information from being shared with third-parties in the future. We will respond to your request to access within 30 days.
Additional, we have created mechanisms to provide you with the following control over your information:
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website.
If you do not wish to have your email address or contact information used by Unreasonable to promote our own or third parties' products or services, you can opt-out through our online Service, Flow or by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
If you are unsure of how or where to access, correct, update, delete, or limit sharing of your Personal Information, please ask us by sending a request to firstname.lastname@example.org.
Furthermore, upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at email@example.com.
We take the security of your Personal Information seriously. We use a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our websites are encrypted using Transport Layer Security (TLS) technology.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding access to your email account and other authentication information that you use to access our Services. Please do not forward or share access-related emails from any of our Services. Also note that we cannot secure Personal Information that you release on your own or that you request us to release.
The transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the internet. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in any of the Services.
Where required by law, we will notify you of any such loss, access, misuse, or alteration of Personal Information that may affect you, so that you can take the appropriate actions to protect your rights.
Our Services are not targeted toward children under the age of 16. We do not knowingly collect personal information from children under the age of 16. In certain circumstances, a parent or guardian may provide information related to his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to Unreasonable about his or her child is kept secure and that the information submitted is accurate.
California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us by email or mail at:
c/o Industrious Boulder
1919 14th Street, Suite 700
Boulder, Colorado 80302
We recognize that the European Union (EU) has established strict protections regarding the handling of Personal Information of residents of the European Economic Area (EEA) ("EEA Personal Information"). To provide adequate protection for EEA Personal Information we participate in and have certified our compliance with the EU-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of EEA Personal Information. We are committed to subjecting all EEA Personal Information, in reliance on the Privacy Shield Frameworks, to the Framework's applicable Principles, including but not limited to principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit U.S. Department of Commerce's Privacy Shield List.
This Privacy Statement describes the categories of EEA Personal Information that we may receive in the U.S. as well as the purpose for which we use that EEA Personal Information. Unreasonable will only process EEA Personal Information in ways that are consistent with the purpose we collected it for, or for purposes the individual authorizes. Before we use your EEA Personal Information for a purpose that is materially different that the purpose we collected if for or that you later authorized, we will provide you with the opportunity to opt out. We maintain reasonable procedures to help ensure that EEA Personal Information is reliable for its intended use, accurate, complete, and current.
Under the Privacy Shield Frameworks, we are responsible for the processing of EEA Personal Information we receive and subsequently transfer to a third party acting as an agent or service provider on our behalf. Under certain circumstances, we may remain liable for the acts of such third-party agents or service providers for their handling of EEA Personal Information that we transfer to them. We comply with the Privacy Shield Principles for all such onward transfers of EEA Personal Information, including the onward transfer liability provisions. We may transfer EEA Personal Information to our third-party agents or service providers who perform functions on our behalf as described herein. We evaluate our service providers' privacy, security, and confidentiality policies and practices to ensure they meet or exceed the standards in our own Privacy Statement and where required by Privacy Shield, we enter into written agreement with those third party-party agents and service providers requiring them to provide the same level of protection Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing.
In some cases, we may transfer EEA Personal Information to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your EEA Personal Information to third-party data controllers for the purposes described herein. We will only provide your EEA Personal Information to third-party data controllers where you have not opted-out of such disclosures, or in the case of Sensitive Personal Information, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for EEA Personal Information the Privacy Shield requires. We also limit their use of your EEA Personal Information so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your EEA Personal Information to one of our affiliated entities, we will take steps to ensure that your EEA Personal Information is protected with the same level of protection the Privacy Shield requires.
With respect to EEA Personal Information, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In addition to the access and control rights designated herein, EEA individuals have the right to access the EEA Personal Information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA Personal Information, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
In compliance with the EU-US Shield Principles, we are committed to resolving complaints about your privacy and our collection or use of your EEA Personal Information. EEA residents with inquiries or complaints regarding this Privacy Statement should first contact our Privacy Team at:
c/o Industrious Boulder
1919 14th Street, Suite 700
Boulder, Colorado 80302
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA Personal Information with forty-five (45) days of receiving your inquiry or complaint. We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.
Finally, as a last resort and where EEA individuals have (1) raised your complaint directly with us and provided us with the opportunity to resolve the issue, (2) made use of the independent resolution mechanism, JAMS, referenced above, and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you, such EEA individuals with residual privacy complaints may invoke a binding arbitration option before the Privacy Shield Panel. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
We may change this Privacy Statement occasionally. When it does change, we will post any changes on this page and encourage you to review our Privacy Statement to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, and obtain your consent to the new changes.
If you disagree with changes to this Privacy Statement, please discontinue your use of our Services, and contact us at firstname.lastname@example.org if you wish to request the removal of your Personal Information.
If you have questions about this Privacy Statement, please email our Privacy Team at email@example.com, or send a letter to:
c/o Industrious Boulder
1919 14th Street, Suite 700
Boulder, Colorado 80302