Third Culture Capital Privacy Policy

  Last updated and effective: August 17, 2021

Third Culture Capital Privacy Item     Welcome to Third Culture Capital

Welcome to the website (the “Site”) of 3CC Management, L.L.C. and its affiliates (“3CC,” “we,” “us,” or “our”).

Your privacy is one of our top priorities. The following policy applies to the use of masstech.org and those domains associated/owned by MassTech.

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices.

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service. Before using the Service or submitting any Personal Data to 3CC, please review this Privacy Policy carefully and contact us if you have any questions.

Third Culture Capital Privacy Item     Information we collect

When you contact us or interact with our Service we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows:

Information You Provide to Us

We collect Personal Data that is entered on our Site or sent to us electronically, for example when you:

Complete a web form to give Personal Data to us directly (such as on our “Contact Us” form), subscribe to our mailing list or contact us with inquiries or respond to one of our surveys. We collect your first and last name, company, email address.

The data we collect about you may includes your name and contact details (including email address and phone number), address and job title, your professional background and qualifications and any other information you choose to include in the body of your email or message, including anything else you tell us about your technology and business.. If you submit any Personal Data about other individuals to us, you represent that you have the authority to do so and that you have informed the relevant individuals of the use of Personal Data relating to them as described in this Privacy Policy.

Events

We may collect Personal Data from you when you attend one of our events. The data we collect includes information that you voluntarily give to us, such as your business card or contact details. We will use this information to develop a business relationship and in a manner consistent with the purpose you gave the information for. Where required by applicable law (for example, if you are an individual in the EU), we will ask your consent before sending you marketing information by email. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.

Information We Collect Through Our Social Media Pages

We have pages on social media sites like Instagram, YouTube, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Information We Receive Automatically From Your Use of the Site

When you visit, use and interact with the Site, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Chrome, Safari, Firefox, Microsoft Edge, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.

Cookies: Please see the “Cookies” section below to learn more about how we use cookies.

Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.

Usage Information: We collect information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

Cookies

We may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider's website via your help screen.

We may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider's website via your help screen.

Advertisements

You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and installing our Service, you will become a user of the Service. Advertising platforms, which include Twitter and Facebook (and whose SDKs are integrated within our Service), may collect information for optimizing advertising campaigns outside of the Service.

Third Culture Capital Privacy Item     How we use information

We use Personal Data as necessary for certain legitimate business interests, described below:

To respond to your inquiries, comments, feedback or questions;
To process submissions of your start-up or your applications;
To send administrative information to you, for example, information regarding the Site, and changes to our terms, conditions, and policies;

To analyze how you interact with our Site and provide, maintain and improve the content and functionality of the Site (please see the “Cookies” section below to learn how we use cookies);
To prevent fraud, criminal activity, or misuses of our Site, block prohibited reseller traffic, and to ensure the security of our IT systems, architecture and networks; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
We use Personal Data we collect through our participation at trade shows, meetings or other events to follow-up with you regarding an event or meeting, send you information that you have requested on our products and services. Use of your data for such purposes is necessary for our legitimate interest in developing a relationship with you. With your permission, we will include your contact details in our marketing database.

For information about what we mean by legitimate interests and the rights of individuals in the European Union (“EU”), please see the “EU Users” section below.

Third Culture Capital Privacy Item     Sharing and disclosure of information

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

Vendors and Service Providers:

To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with providers of hosting, cloud services and other information technology services providers; event management, email communication software providers and email newsletter providers; customer relationship managers, online form providers, web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section below). Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.

Business Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.

Legal Requirements

If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.

Third Culture Capital Privacy Item     Data retention

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will 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 use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Third Culture Capital Privacy Item     Update your information

If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us at info@3cc.io. We will address your request as required by applicable law.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, your information may be part of the transferred assets.

Consent

We may transfer your information with your consent.

Related Companies

We may also share your information with our Related Companies for purposes consistent with this Privacy Policy.

Developers

Developers using our SDK or API will have access to their end users’ information, including message content, message metadata, and voice metadata. Developers must use such information only to provide the SDK/API functionality within their applications and/or services.

Agents, Consultants and Related Third Parties

Like many businesses, we sometimes hire other companies or individuals to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.

Legal Requirements

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Aggregated or Non-identifiable Data

We may also share aggregated or non-personally identifiable information with our partners or others for business purposes.

Third Culture Capital Privacy Item     California privacy rights disclosures

Online Tracking and Do Not Track Signals

We may allow third party service providers to use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Third Culture Capital Privacy Item     Children

Our Service is not directed to children who are under the age of 13. 3CC does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to 3CC through the Service please contact us and we will endeavor to delete that information from our databases.


Third Culture Capital Privacy Item     EU users

Scope

This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).

Data Controller

3CC is the data controller for the processing of your Personal Data. You can find our contact information in the “Contact Us” section below.

Your Rights

Pursuant to the European Union General Data Protection Regulation (or GDPR), you have the following rights in relation to your Personal Data, under certain circumstances:
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means.

Rights in relation to automated decision-making: You have the right to be free from decisions based solely on automated processing of your Personal Data (including profiling) which produce a significant legal effect on you, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.

Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
If we are processing your Personal Data for direct marketing. If we are processing your Personal Data for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above).

Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Please see the “Contact Us” section below for information on how to exercise your rights.

Legitimate Interest

“Legitimate interests” means our interests in conducting our business and developing a business relationship with you or your company. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Third Culture Capital Privacy Item     Links to other websites

The Site may contain links to other websites not operated or controlled by 3CC, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Third Culture Capital Privacy Item     Cookies

We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it.

A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use the Site after having been notified of our use of cookies and other technologies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). Our Site uses cookies from the third parties described below. For more details on cookies please visit All About Cookies.

How can I access the personal data you have about me?

If you would like to submit a data access request, you can do so from the “Settings” page of the Services, where there is a button to download your data. We will then start the process and provide you a link to access the personal data that Discord has on you within 30 days.

How do I correct, update, amend, or delete the personal data you have about me?

In addition to the functionality available through the “Settings” of the Services, in which you can correct, update, amend, or delete certain personal data, you can also request other modifications from us directly. Please write us at privacy@discord.com with the words “Personal Data Request” in the subject or body of your message, along with an explanation of what data subject right you are seeking to exercise. For your protection, we may take steps to verify identity before responding to your request.

Type of Cookies Used

We use cookies to recognize and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way our Site works, for example by making sure users are finding what they need easily.

In particular, the Site uses the following technologies

Google Analytics. For more information, visit https://policies.google.com/privacy?hl=en_US.

We use MailChimp to manage all subscriptions to our mailing lists and to manage the creation and sending of emails to subscribers of those lists. MailChimp uses a cookie to recognize whether a visitor to that user’s Site has previously viewed a popup form and ensures the same visitor does not see the form again for a period of up to one year. For more information, visit https://mailchimp.com/legal/cookies/. To refuse this cookie, you can change your browser settings as explained under the “Your Choices” section below.

Your Choices

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Microsoft Edge
Mozilla Firefox
Google Chrome
Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there or if you are located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Third Culture Capital Privacy Item     Security

You use the Service at your own risk. We comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Village Global via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

Third Culture Capital Privacy Item     Your choices

Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to use some features of our Site, you may be unable to use those features. You can also contact us to request access to your data or to ask us to update, correct, or delete your Personal Data.

Third Culture Capital Privacy Item     Changes to privacy policy

The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

California Consumer Privacy Act

Our Collection and Use of Personal Information

We collect the following categories of personal information: identifiers (such as your username, the email address you use to sign up, and your phone number, if you’ve chosen to provide it); commercial information (a record of what you’ve bought from Discord, if anything); financial data (payment information, if you’ve bought anything from Discord); internet or other network information (how you interact with the application); location information (because your IP address may indicate your general location); inference data about you; and other information that identifies or can be reasonably associated with you. For examples of the precise data points we collect and the sources of such collection, please see the “INFORMATION WE COLLECT” section above. We collect personal information for the business and commercial purposes described in “OUR USE OF YOUR INFORMATION” above.

Disclosure of Personal Information

We may share your personal information with third parties as described in the “OUR DISCLOSURE OF YOUR INFORMATION” section above. We disclose the categories of personal information mentioned above for business or commercial purposes.

No Sale of Personal Information

The CCPA sets forth certain obligations for businesses that sell personal information. We do not sell the personal information of our users.

Exercising Your Consumer Rights

If you are a California resident, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months, (2) deletion of your personal information, and (3) to opt out of sales of your personal information, if applicable. Details on how to make these requests are in the “YOUR DATA RIGHTS AND CHOICES” section above. We will not discriminate against you if you exercise your rights under the CCPA.

Requests Received

We received the following number of data requests between June 20, 2019 and June 20, 2020:

Third Culture Capital Privacy Item     International transfer

3CC is based in the United States. If you are accessing our Service from the EU or other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United States as necessary for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected. For more information, please contact us as described below.

Third Culture Capital Privacy Item     Contact us

If you have any questions about our Privacy Policy or the information practices of the Site, please feel free to contact us at info@3cc.io.