Last Revised: November 8, 2021

The Dcode Group, Inc. together with its affiliated entities (“Dcode“) is committed to protecting your privacy. This Privacy Policy describes how we collect, use and share data, and what choices you have with respect to your data.

 

Table of Contents

 

Applicability of the Privacy Policy

Information We Collect and Receive

How We Collect Personal Information

How We Use Your Information

Cookies and Similar Technologies

How We Share Your Information

Your Rights and Choices

Security

Other Sites and Services

User Generated Content

Changes to this Privacy Policy

Retention

Children’s Privacy

Contact Us

Information for California Residents

For Users in the EEA: International Data Transfers

 

Applicability of the Privacy Policy

This Privacy Policy applies to all websites that we own and operate, including the websites located at dcode.co and all related websites, our applications and/or APIs, and online services (our “Site“), as well as the Dcode Connect member platform and Nexus services (collectively, the “Platform“), other services, other offerings (including Dcode’s Training, Assessment, Accelerator, Advisory, and Partnering programs), and other interactions (e.g., customer service inquiries, or your participation in user conferences, community events, etc.) you may have with us that are subject to this Privacy Policy (together with our Site, collectively referred to as our “Services“). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our Site (“Third Party Services“), or any other third party products, services or businesses.

Information We Collect and Receive

We collect and receive information that relates to identified or identifiable individuals (“personal information“), including:

•   Identity Data: Information such as your name; address; email address; telephone number; date of birth, age and/or age range; photo/avatar; account login details (e.g., username and password); and information such as unique IDs and online identifiers.
•   Contact Data: Identity Data that includes personal and business contact information, such as postal address, email address, telephone number, or other identifiers used for communication.
•   Content: Unstructured or free-form content that you post on our Site or Platform that may include personal data (e.g., text, images, photographs, messages, comments, feedback and correspondence), such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our Site, receive customer support or otherwise correspond with us.
•   Financial Data: Information such as bank account details, payment card information, and information from credit reference agencies, including similar data defined in Cal. Civ. Code § 1798.80(e).
•   Commercial Data: Information from transactions and purchases you make through the Site, registrations through our Site, and billing details.
•   Device/Network Data: Information regarding your interaction with a website, application, or advertisement (e.g., IP Address, MAC Address, SSIDs, etc.), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, cookie data, web beacons, clear GIFs, pixel tags, and information about how you use our Site and interact with us.
•   Inference Data: Data such as your preferences for receiving marketing communications and details about how you engage with them, as well as information relating to your demographics and interests.
•   Audio/Visual Data: Recordings such as audio files and records (e.g., voice mails, call recordings, and the like).
•   Professional/Biographical Data: Data relating to professional and employment history, qualifications, and similar biographic information.
•   Government ID Data: Information relating to official government identification, such as driver’s license or passport numbers, social security numbers, etc., including similar Identity Data included in Cal Civ Code § 1798.80(e).

 

How We Collect Personal Information

 Information we get directly from you.

You may give us personal information when you apply for a Dcode program, register for the Platform or otherwise submit information to use through the Services or other communications with us. For example:

We may collect Identity Data, Professional/Biographical Data, and Content when you submit a form on our Site (“Profile Data”).

We may collect Commercial Data, Identity Data, and Financial Data when you enter into a commercial transaction or register for an event (“Transaction Data”).

We may collect Identity Data, Professional/Biographical Data, Content, Government ID, Protected Class Data, or Special Category Data when you submit an application to one of our programs (“Application Data”).

 Event Recordings

As part of our Services, we host, coordinate, and operate community events, accelerator events, government training events, demo days, mentor sessions, and other public or private events whether virtually or in-person (“Events“) where you may engage with Dcode, founders, teams, sponsors, investors, federal government leaders, active duty military and other community members. We may create audio or visual recordings of these events, take photographs, conduct interviews or surveys, or conduct similar activities at these Events (“Event Recordings“), and we will collect and process Audio/Visual Data incorporated into these Event Recordings. You may object to the processing of your personal information in connection with Event Recordings during the Event by speaking with organizers of the Event, or afterwards, by contacting us using the information below. Please note, the processing of personal information in connection with Event Recordings may be subject to additional terms and conditions to which you are a party (e.g. a release or consent) that will supersede the nature of processing or individual rights described in this Privacy Policy to the extent in conflict.

Information from Social Networking Sites

Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS“). If you connect to a SNS through our Site you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Privacy Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information we get from others

We may subscribe to databases or contract with third-party data providers from which we collect personal information such as Contact Data, Professional/Biographical Data, Inference Data, and other personal data regarding individuals that may be interested in our Events and programs. We may also collect, and combine with other personal data we maintain, personal data that is publicly available, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, and other similar information.

We also may obtain information from those in the Dcode network such as our event organizers, contractors, and local representatives who have agreed to a relationship with us in order to deliver our Services. This may include information about potential interest in our programs, company and individual progress, interest in local events, and attendance at other similar events.

Information automatically collected

We may automatically collect personal information such as Device/Network Data when you access and use our Site. For example, we may 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 Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section below for more details.

Changes to your personal information

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at info@dcode.co.

 

How We Use Your Information

To provide the Services you request

If you use our Site, sign up for, or request to participate in a particular Service, we will process your personal information you give us or that we receive from relevant parties as necessary or appropriate for us to provide that Service. For example, we may process your personal information as follows:

•   We process Device/Network Data to operate, maintain, administer and improve our Site, (e.g., to show the content you request, secure the Site, and understand how users interact with the Site);
•   We process Profile Data, Transaction Data, and Application Data to create, manage, and communicate with you regarding an account you may have on our Services, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
•   We process Profile Data, Transaction Data, and Application Data, Inference Data and other personal information to process and complete your commercial transactions or registration for an event, to better understand your needs and interests, and personalize your experience with the Services; and
•   We process personal information related to support and maintenance for our Services that you may request.

To Market our Services

If you request information from us, register on our Site, or participate in our surveys, promotions or events, where allowed by law, we or our third-party partners, mentors, and members of the Dcode network may use your personal information, such as Identity Data and Contact Data, as well as Inference Data or Profile Data, to send you updates, newsletters, surveys, offers, and other promotional materials, including communications that may be targeted to you based on your personal information, as permitted by law. We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information, or information obtained through the Dcode network, Events you’ve attended, or your participation in Dcode Services. You will have the ability to opt out of all such communications.

To document and promote Dcode and our events

If we create any Event Recordings, we or our event sponsors or participants may use those Event Recordings (including any Audio/Visual Data therein) as part of our marketing and promotional activities. Further, we may also publish the Event Records, including Audio/Visual Data or related Identity Data therein, in connection with our documentation of or publicity relating to those Events, for example, on the Dcode website or a relevant Event-specific page. We may seek your consent or a release from you in the event the nature of our processing requires such consent or release. However, in certain circumstances, we may process or publish certain video, images, etc. without your consent, such as when we publish on an Event page certain Event Recordings that include images of groups or crowds in attendance at an Event.

With your consent

We may use or share your personal information with your consent, such as when you: consent to participate in additional surveys (where legally permissible), let us post your testimonials or endorsements on our Sites, instruct us to take a specific action with respect to your personal information, or opt into third-party marketing communications.

You may revoke your consent to this processing at any time. Additional information regarding these programs, how your personal information will be shared, and the parties that may receive it, are available within program descriptions we provided at the time you agreed to participate in the program.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To create aggregated or de-identified information

We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners (local, state and federal, in addition to private sector), or sponsors for business or research purposes, such as when we analyze and report on demographic trends.

Miscellaneous processing

If we process personal information in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.

Data Sale

We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to third-parties in exchange for monetary or other valuable consideration. In order to provide our Services to you, we may need to share your personal information with third-parties or service providers that support us in providing those Services.  When we share your information, we prohibit these entities from using it for any purpose other than to provide our Services.

How We Share Your Information

 We generally disclose personal information to third-parties for the following purposes:

•   Partners, Mentors and User Groups. We may disclose your personal information to our partners, mentors, and other groups with whom we have contracted to sponsor and deliver industry-focused Accelerator and Startup Programs, and to other users of our Services, for the purpose of providing our products and services, including sharing with other members of the groups for which you are registered (e.g. founders, mentors). For example, when you participate in an accelerator program, your personal information may be shared with the identified accelerator partners to organize and deliver the accelerator. Also, when you register for an event through our Services, your personal information may be shared with the Event organizers and sponsors in order to communicate with you about the Event. Finally, you may request to join certain programs, initiatives, projects, or promotional opportunities operated by or in connection with third parties where your information will be shared with the parties you choose or that operate the relevant program.
•   Affiliates. We may disclose your personal information to our parent company, subsidiaries, joint ventures, or other corporate affiliates for purposes consistent with this Privacy Policy.
•   Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
•   Compliance with Laws and Law Enforcement; Protection and Safety. Dcode may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
•   Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, which may include your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.
•   Service Providers & Business Purposes. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, email delivery and database management services). We may also disclose your data in connection with certain other business and operational purposes, such as data security monitoring, service analytics, internal research, quality control, etc. We generally share your personal data as you request, or in accordance with certain business purposes. When we disclose information for business purposes (e.g., where we disclose information as part of our own internal operations, such as security operations, internal research, etc.), we may disclose the following categories of information: Identity Data, Contact Data, Content, Financial Data, Professional/Biographical Data, Commercial Data, Device/Network Data, Inference Data, Audio/Visual Data, Government ID Data.

 Your Rights and Choices

•   Access, update, correct or delete your information. All account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at info@dcode.co to accomplish the foregoing or if you have additional requests or questions.
•   Email communications. You may opt out of newsletters and marketing-related emails from us by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at info@dcode.co. You may continue to receive service-related and other non-marketing emails. If you authorized the sharing of your contact information with a third-party, contact that third-party directly to opt out of receiving any communications they may send.
•   Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at info@dcode.co.

Choosing not to share your personal information.

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

Uninstalling our applications. You can stop all collection of information by the application(s) by uninstalling the application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Cookies and Similar Technologies

We may collect personal 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 Site.

We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third-party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites or online services. To learn more about the types of cookies we use, please review our Cookie Policy.

Pixel tags

We may also use technologies that function similarly to cookies called pixel tags (which are also known as web beacons and clear GIFs) to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags can be used, for example, to measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can better understand how users interact with our Site.

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. If you do not accept our cookies or similar technologies, you may not be able to use certain features or services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

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 not respond to do not track signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Google Analytics. You must opt out of other third party technologies directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Retargeting and Behavioral Advertising. When we share your information with third parties for retargeting purposes, or for behavioral advertising, you have a right to revoke your consent (if provided) or otherwise opt-out of such services. Where a third party processes data on our behalf, (e.g. Custom Audiences, or Customer Match) you may contact us to opt-out. However, to the extent the third party processes your information for its own purposes, you should opt out with that third party directly. You can control your Facebook (and Instagram) privacy settings here, Google’s ad settings here, and LinkedIn’s privacy settings here.

Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Other Sites and Services

Our Site may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third-party. We do not exercise control over third-party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User Generated Content

We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will post an updated version of the Privacy Policy on our Site.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Children’s Privacy

Our Products and Services are not directed to children under the age of 13, and we do not intentionally gather personal information from visitors who are under the age of 13, without their parental or guardian’s consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the contact information provided below. We will delete such information from our files as soon as reasonably practicable.

Contact Us

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at info@dcode.co, or write to us at:

 

Dcode

2000 Pennsylvania Ave NW

#7000

Washington, D.C. 20006

 

Information for California Residents

Your California privacy rights

If you are a California resident, you have the following rights:

•   Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months:
•   The categories of personal information that we have collected about you;
•   The categories of sources from which personal information is collected;
•   The business or commercial purpose for collecting or selling personal information;
•   The categories of third parties with whom we share your personal information;
•   Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and
•   Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipients.
•   Access. To request a copy of the personal information that we have collected about you during the past 12 months.
•   Deletion. To request that we delete personal information about you that we have collected from you.
•   Non-Discrimination. You have the right not to be discriminated against with respect to the quality or level of services we provide as a consequence of your exercise of your rights under CCPA.
•   Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.

Exercising your California privacy rights

To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:

Website: https://dcode.co

Email: info@dcode.co

Toll-Free Number:  1-(800)-991-0215

We will request that you provide information necessary to verify your identity. That information may vary based on the context and scope of your request. For example, we may require you to verify access to an email address, or provide other forms of identification appropriate to the request. We may require agents submitting a request on your behalf to provide proof of agency in order to respond to a request.

Response Timing and Format

We aim to respond to requests for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

 

For Users in the EEA

Controller

Dcode is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details.

Dcode is headquartered in the United States and has affiliates and service providers in the US and around the world. Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation. 

Legal bases for processing

We will only process your personal information when we have a valid legal basis to do so.  Our legal basis will depend on the reason that we collected your personal information.  Our processing of your personal information for the reasons listed in this notice relies on the following legal bases:

•   Performance of a contract with you or your employer;
•   Our legitimate interest as a business, such as for administrative purposes or to improve our Services;
•   To comply with a legal obligation; or
•   With your consent.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

•   Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
•   Access. Provide you with information about our processing of your personal information and give you access to your personal information.
•   Correct. Update or correct inaccuracies in your personal information
•   Delete. Delete your personal information.
•   Transfer. Transfer a machine-readable copy of your personal information to you or a third-party of your choice.
•   Restrict. Restrict the processing of your personal information.
•   Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to info@dcode.co or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at info@dcode.co or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, we will do so either with your consent or subject to Standard Contractual Clauses.