Flywheel

Privacy Notice

Last Modified: 09.13.2022

Welcome and thank you for your interest in Flywheel (“Flywheel,” “we”, “our” or “us”).  Flywheel represents and manages talent. We focus on all aspects of your career, including providing concierge job search, personal brand development, management training, executive coaching, and skill development. This Privacy Notice explains how information about you, that directly identifies you, or that makes you identifiable (“personal information”) is collected, used and disclosed by Flywheel in connection with our website https://www.tryflywheel.co (the “Site”) and our full suite of services provided to job seekers (collectively with the Site, the “Service”).  Please note that this Privacy Notice does not cover or apply to our processing of information about our employees or independent contractors.  

1. 1. HOW WE COLLECT AND USE INFORMATION
   We may collect personal information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other technologies.
   Information That You Provide
   We may collect personal information from you when you use our Service. The categories of information we collect can include:

• ○ Service Inquiries and Access Requests. We collect personal information that you provide when you inquire about our products or sign up to request access to the platform. This information includes your name, the company you work for or your most recent employer if you are unemployed at the time you inquire about our Services, employment status (which is inferred from your answer about your current or most recent employer), your LinkedIn profile URL, and your email address and whether you are authorized to work in the US. 
• ○ Consult Call. When you participate in a consult call, we collect any personal information provided by you during our conversation. This information may include your past and current work experiences, career goals, compensation history and current salary, salary goals, and visa status and geographic preferences. For Firms, it will be current portfolio companies, what you are looking to grow, and which roles you have a current or future interest in hiring for.
• ○ Registration Information. When you register for our Service we collect personal information that we will use as part of the Service. This information may include your name, email address, phone number, home address, date of birth, work experience, education, references, writing samples and portfolio documents, race, ethnicity, gender, disability status, veteran status, LinkedIn URL, log-in credentials to various services including your tryflywheel.co account, and any other information that would be included in your resume or in a job application. We also collect payment transaction information such as your name, transaction date, and transaction details. Please note that we use a third-party payment processor to process payments made to us. Because we use a third-party payment processor, we do not retain any personally identifiable financial information such as credit card numbers. Rather, all such information is provided directly to the third-party payment processor. The payment processor’s use of your personal information is governed by their privacy notice. Please review each processor’s privacy notice to understand how they will manage or otherwise process your personal information, including your financial data. 
• ○ Information Collected through the Use of the Service. After registration, you may create resumes, emails, blog posts, or other documents and work samples related to your job search or the service we are providing (e.g., employment applications, information on your current role once you have been placed, personal branding efforts). We use this information to provide the Service, including facilitating the job application and interview process, securing a job, for training and skill development, enhancing your brand, and to provide general support. In addition, with your consent and at your direction, the team may also manage email communications related to current or potential job prospects, and throughout the hiring process, which may include your personal information and any other content included in those communications. We will only use that information in the provision of the Service, and for no other purpose. A Firm account may input their current portfolio companies, any current or outstanding jobs, as well as any relevant info pertaining to these listings and sufficient information necessary to attract operators.
• ○ Inquiries and Feedback. If you communicate with us through any paper or electronic form, we may collect your name, email address, mailing address, phone number, or any other personal information you choose to provide to us.  We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.  
• ○ Marketing Emails. If you sign up to receive news or alerts from us, we collect your email and  applicable interests and communication preferences in order to send you regular updates about the Service.  We use this information to manage our communications with you and send you information about products and services we think may be of interest to you.  If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication.  Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, confirmation of services or notifications related to your account, or technical or legal notices).
• ○ Events, Surveys, and Promotions. If you fill out any forms relating to Flywheel events, surveys, contests, sweepstakes, potential salary calculations, or other promotional events, we collect your contact and demographic information, and any other information requested on the form or at sign up.  We use this information to fulfill the purpose of the form or sign up, facilitate the event, survey, contest, sweepstakes, and promotion, and to inform you about future programs that may be of interest to you.
• ○ Employment Applications. If you apply for employment, we collect your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide.  We use the information provided to evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process.  

1. 2. Information from Third Party Sources
   We may receive personal information about you from our business partners and service providers and combine this information with other data we collect from you.  The third parties may include website and service operators, customer merchants, payment processors, and marketing partners.  The information may include contact information, demographic information, information about your walks and other activities, and information about your orders.  We use this information to administer and facilitate our services, your orders, and our marketing activities.

• ○ Referrals: If someone refers you to our Service, we may receive information from the referral such as your name, email, phone number, and general experience or background.  
• ○ Social Media. When you interact with our Site through various social media, such as when you click on the social media icon on the Site, follow us on a social media site, or post a comment to one of our pages, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive may be dependent upon your privacy settings with the social network. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. 
• ○ Information from Other Sources.  We may obtain information from other sources, including through third-party information providers, through transactions such as mergers and acquisitions, or through publicly available sources. This information may include contact information, employment-related information, and interest-in-services information. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, to better understand the demographics of the individuals with whom we interact, as well as to communicate directly with you such as to send you email messages about products and services that may be of interest to you.  

1. 3. Other Uses of Personal Information
   In addition to the uses described above, we may collect and use personal information for the following purposes:

• For our business activities, including to operate the Service and to provide you with the features and functionality of the Service;
• To communicate with you and respond to your requests, such as to respond to your questions, contact you about changes to the Service, and communicate about account related matters;
• For marketing and advertising purposes, such as to market to you or offer you with information and updates on our products or services we think that you may be interested in. While we may use your personal information in this manner, please note that we do not use your User Content to serve you ads, and we will never share User Content with any third parties for marketing or advertising purposes, unless you have explicitly submitted it to us for that purpose;
• For analytics and research purposes;
• To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• To comply with contractual and legal obligations and requirements;
• To fulfill any other purpose for which you provide personal information; and
• For any other lawful purpose, or other purpose that you consent to.

1. 4. HOW WE SHARE PERSONAL INFORMATION
   We may share your personal information in the instances described below.  

• Employers. We may share your personal information with potential employers as part of the Service. 
• Service Providers.We share personal information with third party contractors and service providers who perform services on our behalf, which are subject to reasonable confidentiality terms, and which may include processing payments, providing web hosting services, technology support providers, email communications providers, video conferencing providers, analytics providers, data storage providers, and web and video hosting providers and developers. For certain aspects of the Service (e.g. interview preparation), we may also provide certain information to industry “domain experts” so that they can provide you with additional guidance.
• Business Partners. We may disclose personal information to our business partners  for transactional and marketing purposes, including to promote their products or services.  For example, we may share personal information with other business partners with whom we partner to provide events, contests, sweepstakes, or referral programs in which you choose to participate. 
• Other Flywheel Clients. With your strict consent and at your direction, we may share your contact information and general industry or expertise with fellow Operators or Firms, industry leaders, and subject matter experts to generate networking opportunities and enhance your experience with our Service. With your consent, we may also feature your name, profile photo, and review of our Service on the Site.
• Online Advertising Partners.  We also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see Third-Party Tracking and Online Advertising below.
• Our Brands. We may share with other companies and brands owned or controlled by Flywheel, and other companies owned by or under common ownership as Flywheel.  These companies will use your personal information in the same way as we can under this Privacy Notice.
• Corporate Transaction. We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets.  Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.
• Legal Requirements. We may share your information with third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or other agreements or to protect the security or integrity of the Flywheel services, including to prevent harm or financial loss, or in connection with preventing fraud or illegal activity; and/or (c) to exercise or protect the rights, property, or personal safety of Flywheel, our Customers, visitors, or others. 

• With Your Consent. We may disclose your information publicly or with another third party with your prior authorization. 

1. 5. How We Use Cookies and Other Tracking Technology to Collect Information
   We, and our third-party partners, automatically collect certain types of usage information when you visit our Site, read our emails, or otherwise engage with us.  We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). 
   We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

• Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• When you access our sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.  
• Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the Sites.
• We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at https://policies.google.com/technologies/partner-sites and view its opt-out options at https://tools.google.com/dlpage/gaoptout. 

1. 6. We use the data collected through tracking technologies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
   We and our third-party partners may also use cookies and tracking technologies for advertising purposes.  For more information about tracking technologies, including your choices regarding this technology, please see Third-Party Tracking and Online Advertising below.
2. 7. Third-Party Tracking and Online Advertising
   We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information.  This information is used to display targeted ads on or through our services  or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, Twitter, Google, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services or our clients’ services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
   Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
   Cookies and Other Tracking Technologies Opt-Out. Depending on your browser or mobile device, you may be able to set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. 
   If you would prefer not to accept cookies, most browsers will allow you to:  (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the sites, as some features and services on our sites may not work properly.  Depending on your mobile device and operating system, you may not be able to delete or block all cookies.  You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). 
   To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).  You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
   Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services.  It means that the online ads that you do see from DAA program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.
3. 8. Security
   Flywheel cares about the security of your information and uses commercially reasonable physical, technical, and organizational measures designed to preserve the integrity and security of all information we collect.  However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.
4. 9. Links to Third-Party Websites and Services
   For your convenience, our Site may provide links to third-party websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.
5. 10. Children’s Privacy
   Our Service is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible.  If you believe that we might have collected information from a child under 13, please contact us at hello@tryflywheel.co.
6. 11. Region-Specific Disclosures
   California - Your California Privacy Rights: If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To opt out of having your information shared in this manner, please email us at hello@tryflywheel.co.
   Nevada: Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident.  Note we do not sell your personal information within the meaning of Chapter 603A. However, if you would still like to submit such a request, please contact us at hello@tryflywheel.co.   
7. 12. Changes to Privacy Notice
   We reserve the right to change this Privacy Notice from time to time in our sole discretion.  We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Flywheel account and/or by placing a prominent notice on our Site.  It is your responsibility to review this Privacy Notice periodically. When we do change the Privacy Notice, we will also revise the “last modified” date. 
8. 13. Contact Us
   For additional inquiries about this Privacy Notice, please send us an email at hello@tryflywheel.co