Privacy Policy

1. Who We Are.

1.1 GradGreenhouse Services.

Welcome to GradGreenhouse. We are a dedicated Virtual Events and Virtual Careers Fairs platform, empowering universities to bring students and employers together through the virtual environment. We enable users from all over the world to join events.

GradGreenhouse.com, its holding company (Saturn V PTE Ltd) and its subsidiaries (“GradGreenhouse” or “Company”) and affiliates may revise these Conditions of Access at any time without prior notice.

1.2 Who’s Who.

When this Privacy Policy uses the term “Organiser” we mean event creators using the Services to create events for consumers using our Services (a) to consume information about, or attend, events (“Consumers”), or (b) for any other reason. Within the GradGreenhouse system Consumers are identified as “Graduates” and “Companies”. Organisers, Consumers and third parties using our Services are all referred to in these Terms collectively as “Users”, “you” or “your”.

If you have any questions or concerns at any time, please do not hesitate to contact us at [email protected]

2. Our Privacy Statement.

 Application.

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected from Users on or through the Services. We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. Please read this Privacy Policy as it includes important information regarding your Personal Data and other information.

“Non-Personal Data” as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.

3. Personal Data That We Collect.

When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Organiser using our Services to run an event. This is an important distinction for purposes of certain data protection laws and is explained in more detail below.

3.1 Information Collected From All Users.

Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and any other information that you choose to provide and/or that enables Users to be personally identified. By engaging with our services, the user has given Consent for GradGreenhouse to process the user data.

Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services (“Automatic Data”). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies.

When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.

3.2 Information Collected From Organisers.

If you are an Organiser we will collect additional Personal Data from you.

Information you provide to us: including and not limited to your name, email address and other contact information.

3.3 Information Collected From Consumers.

If you are a Consumer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Organiser.

Information you provide via GradGreenhouse: If you register for a paid event, you will provide financial information (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data. This information is not stored by GradGreenhouse and is processed using PayPal (Paypal terms of use: https://www.paypal.com/us/webapps/mpp/ua/useragreement-full).

In addition, Organisers have access to the data from event to collect the information provided when Consumers register (either as a “Graduate” or “Company”), or otherwise provide information to GradGreenhouse in conjunction with an Organiser event or activity, whether that information is yours or a third party’s, in connection with a purchase, registration, or transfer, that Organiser will receive and may use the information you provide.

Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Organisers, other Consumers, social media or other third party integrations.

4. How We Use Your Personal Data.

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy, and applicable privacy laws. We may use the Personal Data as follows:

4.1 Specific Reason.

If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.

4.2 Access and Use.

If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyse your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications and institution where they were obtained (University or College) to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services.

4.3 Internal Business Purposes.

We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.

4.4 GradGreenhouse Marketing.

We will not use your Personal Data for our marketing and advertising purposes.

4.5 Other Purposes.

If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.

4.6 Aggregated Personal Data.

In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.

5. How We Disclose And Transfer Your Personal Data.

5.1 Background.

We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth in this Privacy Policy.

5.2 Agents, Consultants and Service Providers.

We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of GradGreenhouse to perform certain business-related functions. These companies include our data enhancement and data services providers, database service providers, backup and disaster recovery service providers, email service providers, payment processing partners, customer support, tech support, hosting companies and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.

5.3 Organisers.

In addition, when you register for an event, sign up for communications, enter a contest, or otherwise input your Personal Data (such as through a web form) to communicate with an Organiser or participate in an Organiser event, that Organiser will receive that information. For instance, if you input your name and email address into a web form for an Organiser offer, activity or event, the Organiser will receive that information. The Organiser may then send you marketing or other communications, which may be subject to its own, separate privacy policy. Likewise, if you provide your mobile phone number, you may receive information messages related to the service, event, activity or information in which you’ve expressed interest.

We are not responsible for the actions of these Organisers, or their Third Party Organisers (or other downstream recipients of your Personal Data), with respect to your Personal Data. It is important that you review the applicable policies of the Organisers, and if applicable and available, their appointed Third Party Organisers, of an event (and the related fundraising page, if applicable) before providing Personal Data or other information in connection with that event or related fundraising page.

Similarly, if you are a member of an Organiser’s organisation within GradGreenhouse, your Personal Data will be available to the Organiser and shared with those Third Party Organisers granted permission by the Organiser to view all members of the Organiser’s organisation.

5.4 Facebook, Social Media and Other Third Party Connections.

  1. Connecting Your GradGreenhouse Account to Social Media Services.

You can connect your GradGreenhouse account to your accounts on third party services like Facebook, in which case we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy. For example, if you connect with Facebook, we store your Facebook id, first name, last name, email, location, friends list and profile picture and use them to connect with your Facebook account to provide certain functionality on the Services, like recommending events that your Facebook friends are interested in and sharing the events you are interested in, or attending, with certain groups of people like your Facebook friends.

  • “Liking” or “Following” GradGreenhouse on Social Media.

In addition, when you “like” or “follow” us on Facebook, Instagram, Twitter or other social media sites (to the extent we provide that capability), we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We likewise may collect your information if you sign up for one of our promotions or submit information to us through social media sites.

  • Facebook Plug-Ins and Links on Our Pages.

GradGreenhouse’s own website may contain links to Facebook as well, such as through the Facebook “Like” or “Share” button or other social plug-ins. When you interact with these features and links, your browser will establish a direct link with the Facebook servers, and Facebook will receive information about your browser and activity, and may link it to your Facebook user account. For more information about how Facebook uses data, please see Facebook’s own policies.

d. Additional Facebook Marketing and Connectivity.

In addition, if you are a member of Facebook (or another social media platform), and you provide Personal Data to an Organiser (such as in the ways described in Section 5.5), the Organiser may use that Personal Data to send you advertising and offers through Facebook (or another social media) platform, including when you are on Facebook or another social media platform. The Organiser may work with us and with third parties to enable this data integration and advertising. Facebook and other social media platforms may provide a way to opt out of this type of advertising. Please review their user settings and support pages to learn more about how they help you to manage privacy and marketing choices.

e. Third party services and integrations.

GradGreenhouse may provide you with opportunities to contract directly with third parties, and/or to integrate with third party services or applications, through our platform. In such instances, we will disclose your Personal Data to other entities in order to fulfill a request by you, or to provide services you have requested.

5.5 Legal Requirements.

We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

6. How We Store Your Personal Data.

We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorised use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

7. How You Can Access, Update, Correct or Delete Your Personal Data.

You can access or delete your Personal Data stored by us. If you are a registered User, you can do this by logging in and visiting the Account Settings page to access and edit your Personal Data. To delete all data, please contact [email protected] to handle this request.

If a Consumer initiates a data deletion request, GradGreenhouse is authorised to delete or anonymize Personal Data of the requesting Consumer from the Services even if that means removing its availability to the Organiser through the Services. However, if you are a Consumer, you understand that even if GradGreenhouse deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Organiser’s own databases if transmitted to the Organiser prior to GradGreenhouse receiving or taking action on any deletion or anonymization activity.

8. How Long We Retain Your Personal Data.

We may retain your Personal Data as long as you are registered to use the Services. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

9. Your Choices.

Limit the Personal Data You Provide.

You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to buy tickets as a Consumer, your name and email address will be required by the Organiser.

10. Exclusions.

10.1 Personal Data Provided to Others.

This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means, including to Organisers on event pages or information posted by you to any public areas of the Services.

10.2 Third Party Links.

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

12. Changes To This Privacy Policy.

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances GradGreenhouse may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective thirty (30) days following the “Updated” date or such other date as communicated in any other notice to you.

Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

13. Dispute Resolution.

If you have a complaint about GradGreenhouse’s privacy practises you should write to us at:

GradGreenhouse, 202 Telok Ayer Street Floor 2 & 3, 068639  or by email. We will take reasonable steps to work with you to attempt to resolve your complaint.

14. EEA, SWITZERLAND AND UK ONLY

The EU General Data Protection Regulation (GDPR)

In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) went into effect. The GDPR requires GradGreenhouse and Organisers using the Service to provide Users with more information about the processing of their Personal Data.

Here is what you need to know:

Legal grounds for processing your Personal Data

The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:

• you provided your consent;

• it is necessary for our contractual relationship;

• the processing is necessary for us to comply with our legal or regulatory obligations; and/or

• the processing is in our legitimate interest as a virtual event platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).

Personal Data retention

We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

If you have an account with us, we will typically retain your Personal Data for a period of ninety (90) days after you have requested that your account is closed or if it’s been inactive for seven (7) years.

Your rights.

Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.

For the most part, you can exercise these rights by logging in and visiting the My Account page or changing the “cookie settings” in your browser (see our Cookie Statement for more information). If you can’t find what you’re looking for in the My Account page, please contact us. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.

If you have a complaint about how we handle your Personal Data, please get in touch with us. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

GradGreenhouse as a data controller and a data processor

EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process personal data on behalf of other organisations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

GradGreenhouse may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.

For example, if you create an account with us to organise your events, GradGreenhouse will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or GradGreenhouse Properties, which could relate to Organisers or Consumers. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform.

15. Your Right To Complain

If you have a complaint or concern about our use or retention of your information you can do so with the relevant supervisory authority within the EU to which you are a resident, whom may refer the complaint to the UK supervisory authority.

Complaints in the UK can be made to the Information Commissioner’s Office via their website:

ico.org.uk/make-a-complaint/

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Cookie Policy

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, GradGreenhouse) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

GradGreenhouse uses first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Online Properties to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us to track and target the interests of our Users to enhance the experience on our Online Properties. Third parties serve cookies through our Online Properties for advertising, analytics and other purposes. This is described in more detail below.

The specific types of first and third party cookies served through our Online Properties and the purposes they perform are described under “Essential 1st party cookies” and “Analytics and customization cookies” below (please note that the specific cookies served may vary depending on the specific GradGreenhouse Property you visit).

Essential 1st party cookies

These cookies are strictly necessary to provide you with Services and to use some of the Site or Application, such as access to secure areas.

Who serves these cookies:

• Gradgreenhouse.com and related top level domains.

How to refuse:

Because these cookies are strictly necessary to deliver the Online Properties to you, you cannot refuse them.

You may block or delete them by changing your browser settings, as described below under the heading “How can I control cookies?”, but you may not be able to use every Site or Application features, and in some cases the GradGreenhouse Property simply will not perform.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. Web beacons (sometimes called “tracking pixels” or “clear gifs”) are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Online Properties or taken an action in relation to our Online Properties. We also facilitate our organizers ability to learn more about your interest in their event at their request through their use of these tracking pixels on our Online Properties. In many instances, these technologies are reliant on cookies to function properly. As a result, declining cookies will impair their functioning.

Does GradGreenhouse allow for Social Networking Cookies?

Yes, these cookies are used to enable you to share pages and content that you find interesting, or events you might attend, through third party social networking and other websites. These cookies may be used for advertising purposes too by those social networks. The best way to refuse these cookies is to turn off the social options within your GradGreenhouse account settings.

What about Flash Cookies or Local Shared Objects?

Our Online Properties may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs”) to, among other things, collect and store information about your use of our Services, fraud prevention and for other Site or Application operations. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Online Properties.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links or you can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies via your browser, you may still use our Online Properties through your access to some functionality may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

How often will you update this Cookie Statement?

We may update this Cookie Statement from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Statement regularly to stay informed about our use of cookies and related technologies.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at [email protected]