Privacy Policy

1. Scope of This Policy
   
2. Agreement to Terms
3. Information We Collect
4. Cookies
5. Children’s Privacy
6. Our Use of Personal Information
7. Our Disclosure of Personal Information
8. Your Privacy Choices
9. Security
10. Additional Disclosures for Residents of Canada
11. Links to Other Websites
12. Effective Date and Changes to This Privacy Policy
13. How to Contact Us

Bleeker, PBC (“Bleeker,” “we,” “us,” “our”) respects your privacy and values your trust. The purpose of this Privacy Policy is to inform you of the treatment and handling of information that we may learn about you from using our websites, including our corporate site at bleeker.co and the Bleeker Connect site at collective.bleekerconnect.com (the “Sites”), our Bleeker Collective mobile application (the “App”), and/or by use of any of our services (collectively, with the Sites and the App, the “Service”). If you have any questions regarding this information or our privacy practices, please see the section entitled How to Contact Us at the end of this Privacy Policy.

If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Service without providing us any personally identifiable information.

We may collect the following categories of personal information (a) directly from you (such as when you sign-up for an account or complete assessments), (b) from third-party social networking sites (e.g., LinkedIn), (c) from the device and browser that you use to access our Service, or (d) from cookies.

We may collect your name, email address, account username and password, and phone number.

We may collect your name, email address, account username and password, and phone number.

We collect the information and content you post or otherwise share through the Sites and App. This may include your profile picture, status updates, responses to assessments, interests or hobbies, comments, and communications between you and other users of the Service. In addition, if you send a message to us (such as through email or social media), we collect any personal information you choose to share with us through those messages.

If you participate in an event (live or virtual) held by Bleeker, we may record the event and capture your image, photograph, audio recording, and/or video recording. We may also collect your profile picture as indicated in User-generated Content, above.

We may collect demographic information from you, such as your race, ethnicity, national origin, gender, gender identity and expression, sex, physical or mental disabilities or conditions, and health status.

We may also draw inferences from the information we collect from you that reflect your preferences, characteristics, abilities, and aptitudes.

We may collect device information when you visit our Sites or App. Device information may include your device type, browser type, online identifiers, IP address, access times, and geolocation information.

We may collect information concerning your interaction with our Sites and App, including when you access our Sites or App and your browsing activity on our Sites or App (such as which pages you visit, in what order, and for how long). This may include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving our Sites.

You are not required to provide all personal information identified in this Privacy Policy to use our Service or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to respond to your requests, allow you to register an account, or provide you with promotional notices that we believe you may find valuable.

We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on our websites are generally divided into the following categories:

• Strictly Necessary Cookies. These are required for the operation of our Sites. They include, for example, cookies that enable you to log into password-protected portions of the Sites. These cookies are session cookies that are erased when you close your browser.
• Analytical/Performance Cookies. These allow us to recognize and count the number of users to our Sites and understand how such users navigate through our Sites (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).  

We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics—learn more by going to https://tools.google.com/dlpage/gaoptout.

• Functional Cookies. These improve the functional performance of our Sites and make them easier for you to use. For example, cookies are used to remember that you have previously visited a Site and asked to remain logged into it (e.g., this saves your username). These cookies qualify as persistent cookies because they remain on your device for use during your next visit to the Site. You can delete these cookies as detailed below.
• Targeting Cookies. These record your visit to our Sites and the pages you have visited and the links you have followed, to recognize you as a previous visitor, and to track your activity on the Sites and other websites you visit. These cookies are used to display our ads on other websites based on your visits to our Site and other online activity. These cookies qualify as persistent cookies because they remain on your device. You can delete these cookies as detailed below.

You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Sites, however, you might not be able to access or use important functions or features of our Sites, and you may, for example, be required to re-enter your log-in details.

Do-Not-Track Signals

At this time, we do not recognize automated browser signals regarding tracking mechanisms, which include “do-not-track” instructions.

The Service is not intended for users under the age of 16 and Bleeker does not knowingly collect personal information from individuals under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Service without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.

We collect and use your personal information for the following purposes:

• Providing the Service to you and providing products or services requested by, or reasonably anticipated within the context of our relationship with, you;
• Managing our relationship with you, and if you decide to establish an account, creating and managing your account;
  
• Responding to your inquiries or requests, and requesting feedback;
• Evaluating your eligibility for career and job opportunities with us or our business clients that have engaged us for our executive recruiting services;
• Developing an understanding of our community and providing programming that meets their needs;
• Tracking use of your username and password to access our Sites and App;
• Personalizing our Sites and App (e.g., displaying your name after you log in);
• Analyzing use of our Sites;
• Providing promotional material or other marketing materials that we believe will be of interest to you;
• Tailoring advertisements to what we believe will be of interest to you (including working with our advertising partners to display advertisements on third-party websites that you may visit);
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
• Complying with legal and regulatory obligations.We collect and use your personal information for the following purposes:

We may share your personal information with the following third parties:

• Service providers, including hosting providers and IT outsourcing, web analytics providers, and companies that provide marketing assistance. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
• Our business clients, as part of our leadership development services and executive recruiting services.
  
• Other users, such as when you post or share content through our Sites or App or when you interact with users on our Sites or App. In some cases, you may be able to opt-out or limit the sharing of your information with other users.
• Advertising networks, to tailor advertisements to you.
• Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
• With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counter-parties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
• Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant or other lawful request for information we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

a.  Bleeker has adopted a policy that provides for the suspension and/or termination of anyuser who is found to have infringed on the rights of Bleeker or of a third party, orIf you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time selecting the “unsubscribe” option in the communication itself. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account. otherwise violated any intellectual property laws or regulations. Bleeker’s policy is to investigate any allegations of copyright infringement brought to its attention.

By logging into your account, you may update your password and view and update certain elements of your profile (e.g., your avatar, career vibe, biographical information, Mind Patterns, and Thinking Talents). If you wish to delete your account, please contact us at the contact information in the How to Contact Us section below.

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alternation, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the information in the How to Contact Us section below.

This section contains additional disclosures for residents of Canada. As noted above, you may update your password and certain elements of your profile (e.g., your avatar, career vibe, biographical information, Mind Patterns, and Thinking Talents) by logging into your account. If you wish to request access to or correction of other personal information, or to opt-out of the processing of your personal information or request that we delete your personal information, you may contact us at legal@bleeker.co with the subject line “Canada Privacy” so that we can get your email to the right team. You may also contact us for information about how foreign-based service providers process your personal information or if you have any questions or complaints about the manner in which we treat your personal information.

We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.

For your convenience, we may link to third-party sites and services, provide functionality for users to post links to third-party sites and services, or otherwise display third-party content through the Service to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.

This Privacy Policy is effective as of the date at the top of this policy. Bleeker has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Policy, we will provide a message through our website or via email informing you of the change.

If you have any questions about this Privacy Policy or our Service, please contact us at legal@bleeker.co.