Privacy Policy

Malartu, Inc. respects your privacy and is committed to protecting it through our compliance with this policy.

Last Modified: May 28th, 2018

Note: We updated our Terms of Use/Privacy Policy on May 28th to make our data practices more transparent and comply with the GDPR. The changes primarily clarify what types of data we collect from you, how we may use that data, and your rights regarding your personal data.

Malartu (the “Company,” “we,” “ours,” “us”) respects and values your privacy, and we are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit or utilize www.malartu.co (the “Site,” a component of the Service), www.benchmarkdata.io, reader.malartu.co, the Malartu application programming interface (the “API,” a component of the Service), or utilize or interact with any other products, applications, or features provided by us (collectively, the “Service”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Any capitalized terms used but not defined in this Policy are defined in our Terms of Use. 

By accessing or using the Service, you fully agree to all the terms of this Policy. If you do not agree with this Policy, or our Terms of Use, you must not use the Service. This Policy may change from time to time. Your continued use of this Service after such changes are made is deemed to be acceptance of those changes. It is your responsibility to check this Policy periodically for updates. Our contact information is located at the end of this Policy.

How this Privacy Policy Applies
This Policy applies to information we collect: (1) on this Site; (2) in any electronic communication between you and the Service; (3) through any mobile or desktop application (if any and when available) you download, which provides off-browser interaction between you and this Site; (4) through the API, and (5) when you interact with our advertising or applications on third-party websites and services.
This Policy does NOT apply to information collected by: (1) us offline or through any other means, including on any other website or service operated by the Company or any third party (including our affiliates and subsidiaries); or (2) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Service.

Children Under the Age of 18  
The Service is not intended for persons under the age of 18, and persons under the age of 18 are not permitted to register for access to the Service. We do not knowingly collect personal information from minors. If you are under 18, do not use or provide any information on this Site or attempt to register or use any features of the Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information on the Site. If you have reason to believe that a child has provided personal information through the Site, please contact us by email at info@malartu.co. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.

Types of Information We Collect
We, along with any third-party companies or individuals with whom we work, may collect information directly and voluntarily from you when you use the Service. The information we collect, use, and share includes “Personal Information” and “Non-personal Information.”

Personal Information is generally information that can be used to identify you, either by itself or in conjunction with other information, which may be Non-Personal Information. It does not include data which has been anonymized to remove the identity (anonymous data), and it does not include data about a company.

Non-Personal Information includes information that is about you, and your equipment or usage details, but does not identify you personally. 

The categories of Personal and Non-Personal Information we may collect, use, and store are as follows:

  • Identity & Employment Data includes first name, last name, username or similar identifier, job title or role.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology or devices you use to access this website.

  • Profile Data includes your username and password, purchases or orders made by you, details about payments to and from you and other details of products and services you have purchased from us your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use the Site and Service.

  • Marketing and Communications Data includes your preferences for receiving marketing information from us, newsletters, and any other communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offenses.

Aggregated Data is combined information, which may include information derived from your Personal Information but is not considered Personal Information, because it is anonymized and does not directly or indirectly identify you. For example, we may aggregate your Usage Data with the Usage Data of other Users in de-identified form to calculate usage trends with respect to a feature of the Service. If we use Aggregated Data in combination with your Personal Information, it will be treated as Personal Information.

 *The preceding descriptions of Personal Information and Non-Personal Information we may collect are illustrative, not exhaustive.

Failure to Provide Personal Information
If you fail to provide personal information when it is required by law or necessary for us to perform our obligations under a contract with you, we may not be able to perform the contract. For example, if you fail to provide us with your billing information to pay for a service we offer, we may not be able to provide you with the service you requested.

How We Collect Information from You
Information we collect from you on or through the Service depends on how you utilize the Service and what information you agree to provide. We may collect information that you provide when you register to use the Service; communicate with us through our online chat feature or via email; provide billing information and authorize payment(s) for the Service; enter a contest or promotion sponsored by us; sign up to receive our email newsletter; report a problem with our Service; or respond to polls or surveys distributed for research purposes. We also collect information when you import, submit, or give us direct access to obtain External Platform Data for use in connection with the Service, which may include information obtained from third party platforms or services. Additionally, we may collect information from you based on your interaction with our API; such information may be the information of third parties with whom you have interaction. We require that you have the requisite consent and legal permission to provide us with information about any Client, individual, or other entity.

Our API also collects information, which may or may not be Personal Information, based upon the inputs to and utilization of the API by the third-party using the API. We cannot control how a third-party uses our API, but any information provided to us through the API will be collected and stored in accordance with this Privacy Policy and our Terms of Use. Furthermore, a third-party may use our API to extract information from the Service, in which case we cannot control how that third-party uses such information.
We also collect information through automatic data collection technologies, which is described in more detail below.  

Automatic Data Collection and How We Use It
In an effort to improve the quality of the Service, the Company and our service providers may track information provided to us by your device or browser, or by our analytics tools when you use the Service. As you access, use, and interact with the Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to the Service, including traffic data, location data, logs the device from which you connected to the Service, website you came from (known as the “referring URL”), and other communication data and the resources that you access and use on the Service;

  • Information about your computer and internet connection, including your IP address, operating system, and browser type;

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically is statistical data and may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve the Service and deliver a better and more personalized user experience. 

Automatic Data Collection Technologies May Include
The technologies we use for the automatic data collection described above may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

  • Flash Cookies. Certain features of the Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

  • Web Beacons. Components of the Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

External Platform Data and Other Third-Party Information
In addition to the categories of Personal and Non-Personal Information described above, we collect, aggregate, and analyze data from other platforms or services maintained by our Clients (“External Platform Data”). External Platform Data that we collect, use, and store from External Platforms at your direction may include information about: (a) Client’s own company, (b) one or more companies in which Client is an advisor (each a “Portfolio Company”), (c) Personal Information and/or Non-Personal Information about individuals who may be officers, directors, employees, customers or target customers of Client’s Company or a Portfolio Company. We collect External Platform Data only after the Client or authorized User has submitted such data, or prompted the Service to obtain the External Platform Data through an integration with the Client or User’s account(s) maintained by External Platforms. External Platform Data may include Personal Information and Non-Personal Information about individuals associated with the Client or its affiliates, and will be collected and stored in accordance with this Privacy Policy and our Terms of Use.

Client and each User acting on Client’s behalf, acknowledges that in accessing or submitting data from External Platforms for use in connection with the Service, Client’s username(s), password(s), and any other security or access information for Client’s account(s) on such External Platforms, and External Platform Data, may be collected and stored through the Service. In connection with Malartu’s provision of the Service, Client authorizes Malartu to: (a) access Client’s account(s) on External Platforms, and collect and process Client’s External Platform Data; (c) access the applicable third party websites and External Platforms using Client’s External Platform Data; and (c) take such other actions as are reasonably necessary to perform the actions described in (a) and (b) above, or as otherwise may be necessary to facilitate the Service. For further explanation regarding how we protect External Platform Data, please see our Data Security page. 

Third Party Use of Cookies and Other Tracking Technologies
In order to facilitate the Service, we allow you link accounts you maintain on various External Platforms with your account on Malartu. While we will only obtain and use data obtained from such third parties in accordance with the terms of this Privacy Policy and as necessary to facilitate the Service, we cannot control or verify how any third parties may collect, use, or track information. Malartu shall not be responsible or liable for the policies or practices of any third party service provider. We strongly encourage you to review the terms and privacy policies of any third-party application or service with which you integrate or otherwise use in connection with the Service. 

We also partner with various technology providers in order to facilitate the Service, conduct sales and marketing activities, analyze usage trends, and continuously improve the Service for all Users. These third party services and applications may have access to data (which may include Personal Information) from your account or generated in connection with your use of the Service, and we may also receive information from such third party services. The types of providers we work with include analytics services, advertising services, and search information services. We encourage you to review the privacy policies of the technology providers and tools listed below. This list is illustrative of some of our technology providers, but is not exhaustive and is subject to change from time to time. Please contact us if you would like more information. 

  • Google Analytics – LINK https://policies.google.com/technologies/partner-sites?hl=en

  • Hubspot – https://legal.hubspot.com/privacy-policy

  • Mailchimp – https://mailchimp.com/legal/privacy/

  • Intercom.io – https://www.intercom.com/terms-and-policies#privacy

  • Mailshake – https://mailshake.com/privacy/

  • Hunter.io –https://hunter.io/privacy-policy

Location Information
We may, from time to time, track use location through IP logging for security and fraud prevention purposes.

Do Not Track Disclosure
You may set your web browser to transmit a “Do Not Track” signal to websites and online services you visit. At this time, Malartu does not respond to or alter its practices when it receives a Do Not Track signal from a user’s web browser. For more information on Do Not Track, please visit www.allaboutdnt.com.
 
How We Use Personal Information
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes your Personal Information with third parties without your consent. We may share Personal Information with vendors who are performing services for the Company, such as the providers of servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. 
*The following is a non-exhaustive list. 
We may use your Personal Information to:

  • Communicate with you. For example, we use Personal Information to contact Users in response to questions, solicit feedback from Users, provide technical support, and inform Users about promotional offers;

  • Facilitate and carry out the functions of the Service, including generating performance reports for a Client which may contain information about a Client’s employees submitted by an authorized User in accordance with this Policy;

  • Verify your identity, including during account creation and password reset processes;

  • Enforce our Terms of Use and other policies, and preventing prohibited or illegal activities, or violations of our Terms of Use;

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  • Improve the Service, including by customizing your user experience;

  • Provide targeted marketing, provide service update notices, and deliver promotional offers based on your communication preferences;

  • Administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events;

  • Comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements;

  • For other purposes necessary for our legitimate interests; and

  • For any other purpose disclosed to you and to which you consent.

 
How We Use Non-Personal Information
In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information, and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. 

Malartu may compile information and data in an aggregated form related to the performance, operation, and use of the Service, and may use such aggregated data for security, statistical, or operations analyses, and for research and development purposes (collectively, “Data Reports”). Malartu may use and share Data Reports without restriction for its business purposes. Data Reports shall not incorporate External Platform Data in a form that would identify Client, sensitive information of Client, or any individual. Malartu shall retain all right, title, and interest in and to the Data Reports, including all associated intellectual property rights.
 
How We Disclose Information
We may disclose aggregated information about our Users and any information that does not identify any specific individual, without restriction. We may also disclose any Personal Information or Non-Personal Information you share with us for the purpose of facilitating and providing the Service. We may also share External Platform Data, which may or may not include Personal Information, with other Users or third parties as authorized by you. For example, we may share information about a Portfolio Company with both the President of that Company and Advisors of that Company if both the President and Advisor have accounts on the Site.

In the event that Client or any User on Client’s behalf shares or provides access to any External Platform Data or other information stored on the Service, with any third party who is not an authorized representative or otherwise permitted to access such External Platform Data or information, or instructs Malartu to provide access or release such External Platform Data or information with such third party, Client acknowledges and agrees that the Company (and its officers, directors, agents, subsidiaries, joint ventures and employees) will not be liable or responsible for any disputes, claims, losses, damages, or liabilities that are in any way related to or arising from such third-party obtaining or gaining access to such information. 

We may also disclose your personal information: (1) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (2) to ensure compliance with our Terms of Use and other agreements, such as billing; and (3) to protect the rights, property, or safety of the Company, our customers, or others. In addition, we retain the right to share your personal information with other companies and organizations for purposes of fraud protection.

International Transfers of Data
Malartu’s principal business operations are conducted in the United States, but the Service may be available to users outside the United States. If you are visiting this Site from a country other than the United States, your communications with us may result in the transfer of information outside of the country from which are reside or use the Service. By visiting the Site, communicating electronically with us, and/or using the Service, you consent to any and all such transfers.

Data Security
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls, and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks, and the Company shall not be responsible for the circumvention of any of the Service’s privacy settings or security measures. For further explanation about how we protect your information, please see our Data Security page.

Your Rights Related to Your Information
Malartu aims to provide transparency, security, and accessibility when it comes to your personal data. 

You may request a copy of your personal data from us at any time. If you request a copy of your data, we will provide you a copy in a structured, electronic format. 

You may also request that your personal data be corrected if you believe it is incorrect or incomplete, or that it be deleted entirely. We will delete your personal data upon your request if you send us a request with a description of the basis for your request; however, we may first restrict processing of your data as permitted under applicable law in order to assess your request prior to any deletion of data. We may not be able to accommodate a request to change or delete information if the change or deletion would violate any law or legal requirement, or if such change would cause the information to be incorrect. We may not be able to delete your Personal Information except by also deleting your user account. 

You may object to our processing of your personal data, or request that we restrict the processing of your personal data. We will stop processing your data, but we may still store your data as permitted under applicable law pending an assessment of your request. 
You may revoke consent to our processing activities that are based on your consent. For example, you may revoke consent to receive our email newsletter if you wish to stop receiving the newsletter. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please direct all requests related to your personal data and account information to info@malartu.co. 

Data Retention
In general, we will only retain Personal Information for as long as necessary to fulfill the purposes we collected it for, and as may be necessary to satisfy any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please note that legal obligations (such as tax reporting) may require us to retain your data for certain specific time periods. 

California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@malartu.co or write us at: 310 S Harrington St, Raleigh, NC 27603.
 
Links to Other Websites
As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Policy applies solely to information collected by us through the Site and the Service. Therefore, this Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy Policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
 
Changes to Our Privacy Policy
We reserve the right to change this Policy and our Terms of Use at any time. We will notify you of significant changes to our Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. 
 
Contact Us:

Malartu, Inc.
Jon Spinney
info@malartu.co
310 S Harrington St. Raleigh, NC 27603
(919) 435-2033

You have the right to make a complaint at any time to your local data protection authority if you have concerns regarding your rights under applicable law. We would, however, appreciate the chance to address your concerns so please contact us first so that we can discuss a resolution with you directly. 

If you have any questions regarding this Policy or the practices of this Site, please contact us by sending an email to info@malartu.co.