This “Privacy Policy” describes the privacy practices of Helm, LLC. (d/b/a The Helm) when you interact with or use our website, www.the-helm.com (the “Site”), when you interact with or use our social media pages, public forums or events, sales marketing or other online and offline activities, and generally any other services offered and made available by us via our Site (collectively we refer to any combination of the above as the “Service”), and the rights and choices available with respect to your personal information.

When you access or use our Services, you acknowledge that you have read this Privacy Policy and understand its contents. Your use of our Services and any dispute over privacy is subject to this Privacy Policy and any applicable service terms.

Table of Contents

1. Personal Information We Collect
2. How We Use Your Personal Information
3. How We Share Your Personal Information
4. Your Rights and Choices
5. Third Party Sites and Services
6. Security Practices
7. International Data Transfers
8. Storage and Retention
9. Children’s Privacy
10. Changes to this Privacy Policy
11. How to Contact Us
12. Information for California Residents’

1. Personal Information We Collect

Information you provide to us. When you use our Services we may collect the following personal information.

Business contact data, such as your first and last name, email and mailing addresses (including email address for any person assisting with your scheduling) and phone number.

Profile data, such as your interests and preferences, your date of birth, and any content uploaded to the Service (such as text, images, audio, and video, along with the metadata associated with the files you upload).

Registration data, such as information that may be related to a service or an account or an event you register for, including, but not limited to, the following:

Personal and professional goals, such as what you are passionate about, how you look to grow personally and professionally, how powerful you consider your professional network, how satisfied you are with your current career accomplishments and how you rank your personal well-being.

Other goals, such as why you joined The Helm as a member, what you want to get most out of your Services (i.e., strengthen network of senior coaches, connect on deeper level with like-minded people, sharpen senior leadership skills, partake in interesting events and programming), what you want to make the biggest priority of your Services, and what you would love to learn more about.

Protected classification characteristics, such as your ethnicity, sexual orientation, gender identity, relationship status and family overview. If you choose to provide any such protected classification characteristics, we will request your consent to our processing in accordance with this Privacy Policy.

Sponsorship information, such as whether you requested and/or received sponsorship from your company for your Services.

Communications, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

Professional and employment data, including, but not limited to, the following:

• Company information, such as your company’s name, industry, type of company and size of company.
• Role information, such as your professional title, function, and any professional credentials (e.g., your role history) and skills (e.g., those related to your real estate experience)
• Financial data, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history.

Other information, including information we may collect that is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources such as:

• Public sources, such as social media platforms. When you visit or interact with our social media pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the third party platform, and we will treat such information in accordance with this Privacy Policy.
• Other users, such as the coaches that provide you mentorship and coaching through our Services and that may provide information to us in accordance with professional, legal, or ethical obligations.
• Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Services:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our Site, and general or inferred location information such as city, state or geographic area from your IP address.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Precise geolocation data, such as when you authorize our mobile application to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your mobile device settings. We also may look up your IP address to determine your general location.

For example, the Services uses Google Maps API to visually display geographic information for demonstrating where jobs are located. Pursuant to the Google Maps APIs Terms of Service, use of this location feature is subject to Google’s Privacy Policy. Both the Google Terms of Service and Google Privacy Policy are incorporated into this Privacy Policy by reference.

Cookies and similar technologies. Like many online services, we use common information gathering tools such as cookies, web beacons and similar technologies to automatically collect certain information from your computer or mobile device as you navigate our Site, our Services or interact with emails we have sent as further described above:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality and helping us understand user activity and patterns.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Software development kits, or SDKs, which are used to incorporate third party computer code into our App that allows our third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media or to add features or functionality to our App.

2. How We Use Your Personal Information

We use your personal information for the following purposes and in reliance on the legal bases described in this Privacy Policy:

Service delivery. We use your personal information to:

• provide and operate the Services and;
• provide information about our products and Services;
• establish and maintain your profile;
• communicate with you about your Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or groups in which you participate, including introductions to other members and groups;
• provide support and maintenance; and
• to respond to your requests, questions and feedback.

We process your personal information in reliance on our contract with you. Where we have not entered into a contract with you, we process your personal information in reliance on our legitimate interests in operating and improving our internal operations, systems and Services, and to provide you with the content, products or Services you access and request.

Research and development / Improving and developing the Services. We use your personal information for research and development purposes, including to analyze and improve the Service and our business. We use data to analyze trends to identify future opportunities for the development, promotion, and improvement of our Services, in reliance on our legitimate interests in developing and improving our Services, or where required, with your consent.  For example, we use data, often in a de-identified form, to develop new features, capabilities, or products, improve the user experience, assess capability requirements, and identify opportunities.

Marketing. We may collect and use your personal information for marketing purposes:

• Direct marketing. We may send you The Helm-related or other direct marketing communications in accordance with your marketing preferences as necessary for our legitimate interest in conducting direct marketing, or to the extent you have provided your prior consent. You may opt-out of our marketing communications as described in the “Your Rights and Choices” section below.

Compliance and protection. We may use your personal information to comply with our legal obligations under applicable laws, including to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern our Service;
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

For our business purposes. We may use data for other legitimate business purposes in reliance on our legitimate interests, such as to update, expand, and analyze our records, identify new customers, data analysis, to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, as well as operating and expanding our business activities.

Other purposes with your consent. In some cases, we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.

3. How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

• Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
• Partners and sponsors. We may share your personal information with partners. For example, if we co-host an event with a third party, we may share your information to the extent related to such event. If required by applicable law, you can consent to such sharing via the registration form. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not want your information shared, you can choose to not opt in upon registration, or you can opt out according to the “Your Rights and Choices” section below.
• Coaches. As part of the Services, The Helm connects you to mentorship and coaching programs. Therefore, if you indicate interest, we may disclose your personal information to our coaches and experts in order to provide these Services to you.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. 
• 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 they render to us.
• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business transferees. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

We may also share aggregated or de-identified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends in the use of our Services.

For further information on the recipients of your personal information, please contact us (see the “How to Contact Us” section below).

4. Your Rights and Choices

(a) All users. In this section, we describe the rights and choices available to all users.

• Access or update your information. If you have submitted an application and / or receive Services directly from The Helm, you may review and update certain personal information in your account profile by contacting us (see the “How to Contact Us” section below).
• Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at hello@the-helm.com. You may continue to receive service-related and other non-marketing emails.
• Cookies. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. 
• Do Not Track. 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” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• 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 Service 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 our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

(b) Individuals located in California

If you are a resident of California, please see the “Information for California Residents” section below for more information about additional rights you may have regarding your personal information.

(c) How to exercise your rights

If you would like to exercise your rights (for which we reserve the right to charge you a fee, where permitted by applicable law), please contact us (see the “How to Contact Us” section below). We will review and process your request in accordance with our obligations under applicable law.

5. Third Party Sites and Services

The Service may contain links to other websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

6. Security Practices

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 personal information.

7. International Data Transfers

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers in the United States.

Therefore, we may transfer personal information from other countries that may not have the same level of data protection that applies in your jurisdiction. In these cases, we use a variety of legal mechanisms designed to ensure that the recipient of your personal information offers an adequate level of protection, including entering into the Standard Contractual Clauses for the transfer of data approved by the European Commission, or where required, we will ask you for your prior consent.

8. Storage and Retention

We may retain your personal information for as long as necessary for the purposes it was collected, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation).

After expiration of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that data.

For further information on applicable data retention periods, please contact us (see “How to Contact Us” section below).

9. Children’s Privacy

The Service is not directed at, and The Helm does not knowingly acquire or receive personal information from, children under the age of 16. If we learn that any user of the Service is under the age of 16, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Services. If you are a parent or guardian and you learn that your children under 16 have provided us with personal information, please contact us (see “How to Contact Us” section below).

10. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we will post an amended version and update the “Last Updated” date above. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as by posting a conspicuous notice on our Site or via email (if you have an account where we have your contact information) or another manner through the Services.

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

11. How to Contact Us

If you have any questions about this Privacy Policy, or if you wish to lodge a complaint about our privacy practices, please email: hello@the-helm.com.

12. Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share 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 third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights by emailing us at hello@the-helm.com. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
• We do not sell your personal information. Based on our understanding of the term “sell” under the CCPA, we do not “sell” your Personal Information and have not sold it to third parties for a business or commercial purpose in the 12 months preceding the effective date of this Privacy Policy.

Personal information that we collect, use and share.

We are required to explain the categories of Personal Information we collect by reference to the categories specified by the CCPA (in bold), as defined here, which are described in the list below. For each category, we list the type of data we collect, and the source of that data as described in the section above entitled “Personal Information We Collect.” We have not sold your personal information in the preceding 12 months.

• Identifiers
  • What we collect: Business contact data, profile data, registration data, communications
  • Sources: You, business partners
• Commercial Information
  • What we collect: Business contact data, profile data, registration data, online activity data
  • Sources: You, business partners, automatic collection
• Financial Information
  • What we collect: Financial data
  • Sources: You
• Geolocation Data
  • What we collect: Device data, precise geolocation data
  • Sources: Automatic collection
• Online Identifiers
  • What we collect: Business contact data, profile data, online activity data, device data
  • Sources: You, automatic collection
• Internet or Network Information
  • What we collect: Device data, online activity data
  • Sources: Automatic collection
• Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and behavior.
  • May be derived from: Profile data, registration data, device data, online activity data
• Professional or Employment Information
  • What we collect: Business contact data, profile data, registration data, professional and employment data
  • Sources: You
• Protected Classification Characteristics,
  • What we collect: Registration data, may also be revealed in other data we collect
  • Sources: You

The business/commercial purposes for which we use each category of Personal Information above are described in the section above entitled “How We Use Your Personal Information.” The categories of third parties to which we disclose each category of Personal Information above of Personal Information for business purposes are described in the section above entitled “How We Share Your Personal Information.”

The above summary of how we collect, use, share Personal Information describes our practices for the 12 months preceding the effective date at the top of this Privacy Policy. Information that you choose to provide to us may include other categories of information

Shine the Light Law

Under California’s “Shine the Light” law (California Civil Code Section § 1798.83), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an email message to hello@the-helm.com with “Request for California Privacy Information” on the subject line and in the body of your message.