Last Updated: February 21, 2019 v1.9
01. Introduction
LAVA Connections is powered by Zenvoy, LLC, a US-based company specializing in the provision of bespoke networking communities for organizations world-wide.
Zenvoy (“Zenvoy”, “LAVA Connections”, “our”, “us” or “we”, “community”, “communities”) via our website (www.zenvoy.com, “lavaconnections.org”, “site”, “website”) is committed to protecting the privacy and security of all individuals who use our site. Our goal is to provide an Internet experience that delivers the information, resources, and services that are most relevant and helpful to you. In order to achieve this goal, from time to time we may collect information during your visits. This Privacy Policy is designed to help you learn more about the personal information we collect, who we might share it with, and how we protect it. Your use of our website is subject to this Privacy Policy and the applicable Terms of Service. By using our website, you are accepting the practices set out in this privacy statement and the applicable terms and conditions of service.
02. GDPR (General Data Protection Regulation)
Zenvoy recognizes and will comply with the GDPR for Zenvoy / LAVA Connections members that are EU citizens, except as limited by applicable law. The rights under GDPR include:
Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
Right to Correction. This is your right to request correction of your personal information.
Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfillment of your request may prevent you from using Zenvoy’s services and may result in the closing of your account.
Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed.
Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.
Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.
Right to not be subject to Automated Decision-Making. This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable European law, or is based on your explicit consent. Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at gdpr@zenvoy.com.
Processors we use. Zenvoy uses external processors, all of which are GDPR compliant. The full list of external processors we use is available to any entity that provide a lawful request to gdpr@zenvoy.com.
Law enforcement. We will not hand your data over to law enforcement unless a court order says we have to.
Security & Encryption. All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Data isn’t encrypted while it’s live in our database (since it needs to be ready to send to you when you need it).
Deleted data. When you cancel your account, we’ll ensure that nothing is stored on our servers past 30 days. Anything you delete on your account while it’s active will also be purged within 30 days.
Location of Site and Data. This Site is operated in the United States and the data is stored in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Data we process. When you sign up we ask for your: (*) Required information
- Full name*
- Age*
- Position*
- Experience (years)*
- Company name and address*
- Gender
- Email*
- Phone
- Public profile photo
- Skills & Services*
- Networking targets*
- Bio
- Commercial video
- Commercial attachments (brochure, CV)
We collect this data so we can:
- Address you
- Create introductions between you and members in your community
- Send emails related to our service and product
- Display relevant ads
- Enable you to log in and perform functions such as editing your profile, preferences and resetting your password
Note that with the exception of the public profile photo, all information is retained within the walled-garden community.
Cookies. Zenvoy uses session cookies to track your sessions. It is not possible to use Zenvoy without this session cookie so by subscribing you agree to us setting this cookie. Zenvoy is a free to use (unless clearly stated when you onboard for some communities) and we cover most of our expenses by advertising. These advertisers may set cookies to track your preferences.
GDPR statement v1.9 February 21 2019 prepared by Nick Brandt, DPO Zenvoy, LLC
03. EU-U.S. Privacy Shield Framework
Zenvoy complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Zenvoy has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
In compliance with the EU-US Privacy Shield Principles, Zenvoy commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Zenvoy at:
Zenvoy, LLC
11693 San Vicente Blvd, Ste #182
Los Angeles, CA 90049 USA
Zenvoy has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Zenvoy is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Pursuant to the Privacy Shield, LAVA Connections remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
04. Data Collection Policy
Information We Collect
Zenvoy collects personal information supplied:
- by our users;
- from information collected through web server logs;
- when you interact with third party services available through Zenvoy like surveys, polls or other third-party research undertaken with your consent; and
- through cookies.
Information Supplied by Our Users
Zenvoy collects personal information, such as your e-mail address, name, home or work address and telephone number. Zenvoy may also collect demographic information, such as your ZIP code, age and gender. Zenvoy does not collect any of this unique information about you except when you specifically and knowingly provide such information.
Information from Web Server Logs
Zenvoy records and saves information about you from our web server logs such as your Internet [Protocol] (IP) address, the time day you visited and your browser type. This information is used to verify our records and to provide better services to you.
Information from Third Party Services
When you interact with third party services available through Zenvoy like surveys, polls or other third-party research undertaken with your consent.
Information from Cookies
In order to offer and provide you with personalized services, Zenvoy may use "cookies" to store and help track your information. A cookie is a piece of data that identifies you as a unique user. Zenvoy will not disclose its cookies to third parties except as required by a valid legal process such as a search warrant, subpoena, statute, or court order.
Information from Mobile Devices
Zenvoy may collect information from mobile devices used to access this site, such as operating system and version information and IP address.
06. Disclosures
Use or Disclosure of your Personal Information to Third Parties and Co-Brand Partners
The services provided on Zenvoy’s website and mobile app may be provided by various companies and organizations you belong to who have a Zenvoy Group or Event account. Those companies and organizations want to create networking introductions internally and they may ask you to opt-in to participate so we may share your information among these companies so we can make it easier for you to use utilize our services seamlessly. You and your contacts information will be synced between the mobile app and our cloud based systems, so any information that you provide will not only be imported into the mobile app, but on our website (confidential just for the user only). We will also be sharing data with Event Organizers, Groups and Employers.
Certain Zenvoy services and content may be co-branded with another company. If you register for or use such services, both Zenvoy and the other company may receive information collected in conjunction with the co-branded services. In such cases, either a joint privacy statement or a link to the other company's privacy statement will be provided, which will provide you with information about how the other company will use the information and how you can contact the other company with requests to access the information or other inquiries.
We do not sell, rent, or otherwise provide personally identifiable information to third parties without your consent except where it is necessary to carry out your instructions (to process your payment information, for example) or to share information with Zenvoy Platform’s or affiliates that provide services. We also provide you with the means to control whether or not your contact information is viewable to other Users through your profile.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Zenvoy is potentially liable.
Compliance with Legal Process
We may disclose personal information if we are required to do so by law or we in good faith believe that such action is necessary to:
- comply with the law or with legal process;
- protect and defend our rights and property;
- protect against misuse or unauthorized use of our web sites;
- protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
Zenvoy also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
07. Data Security
Content Submitted Or Made Available For Inclusion On The Service
With respect to content you submit or make available for inclusion on publicly accessible areas of the Service, this information will be made public on the Internet. "Publicly accessible" areas of the Service are those areas of the Zenvoy network of properties that are intended by Zenvoy to be available to the general public. By way of example, publicly accessible areas of the Service would include message boards, and Blogs.
Access
Zenvoy acknowledges the right of EU individuals to access their personal data. Individuals can access data to review, edit, correct, or delete it by contacting us at team@zenvoy.com.
Our Commitment to Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
Protecting Your Information
While Zenvoy is committed to protecting your personal information, no data transmission over the Internet can be guaranteed to be 100% secure. You are solely responsible for maintaining the secrecy of any passwords you set up and/or any account information.
Links to Other Sites
Zenvoy encourages you to review the privacy statements of Web sites you choose to visit from Zenvoy so that you can understand how those Web sites collect, use and share your information. Zenvoy is not responsible for the privacy statements or other content on Web sites outside of the Zenvoy site
Children’s Privacy
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Correcting Inaccuracies
When you sign up for Zenvoy's products and service, we may send you an e-mail confirming your new account. The message will be sent to the address that you supplied to us at the time of sign-up and will describe ways for you to change or delete the account information provided. Remember to keep the confirmation e-mail as it will also contain information that will help you in case you run into problems accessing our services. We welcome your comments or questions. Send us an email to admin@zenvoy.com.