Privacy Policy | ImpactAlpha

Impact Alpha Inc. (“Company”, “we,” “our,” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, products and services, including the ImpactSpace platform and the ImpactAlpha Edge Database, that link to this policy (our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

Where you access the Services through a Team or Edge account, your account administrator may have access to certain information about your use of the Services, including account activity. ImpactAlpha’s collection and use of your personal data remains governed by this policy regardless of account type.

This policy applies only to information we collect:

Through the Services.
In communications, including email, text, chat, and other electronic messages, between you and the Services.
Through third parties such as through your interaction with our Services through various social media platforms, for example, by logging in through or liking us on Facebook or following us on X. The data we receive is dependent upon your privacy setting with such social network. You should always review, and if necessary, adjust your privacy settings on such third party websites and services before liking or connecting them to our Services.

It does not apply to information collected by:

Any website operated by any third party that does not link to this policy; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities including, for the avoidance of doubt, any supplemental information that may be collected for purposes of verifying accredited investor status.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, photograph, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, photograph, email address, credit card number, information used to determine accredited investor status, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include:

Account and contact information, including name, address (such as home address, work address, or other address), job title, place of employment, email address, phone number, username, and other contact information you provide us.
Payment information, including credit card or debit card information and information about the payment methods and services (such as PayPal or Venmo) you use in connection with the Services.
Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
General geographic location information such as country, state or province, or city.
Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
Content and information you elect to provide as part of your profile, form submissions, or emails, chats, or other communications with us.
Images, voice recordings, and videos collected or stored in connection with the Services, if you have consented to such information collection.
Information in connection with the verification of accredited investor status, if you have consented to such information collection.

Some of the information identified above, including certain information required to verify accredited investor status, may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

Accredited Investor Verification Data

In connection with verifying your accredited investor status as described in our Terms of Service, we may collect financial information, tax documents, and other sensitive personal data. This information is collected solely for the purpose of verifying eligibility for access to Restricted Content and is retained only as long as necessary to maintain your account or comply with applicable law. We do not use this information for advertising or marketing purposes.

We also collect:

Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, subscribe, or create, upload, post content to the Services, including media such as photos, videos, or audio recordings, register for one of our online webinars, register for in person events, complete surveys, or join any of our Slack channels.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
Web Beacons. Some parts of the Services and our emails 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 parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Log Files. Log file information, about your browser or mobile device each time you access our website, may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on our Services including our website, domain names, landing pages, pages viewed, and other such information.

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by sending an email to [email protected]. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

Advertisers, ad networks, and ad servers, including Google Ads.
Analytics companies.
Billing and payment processors.
Email service providers.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, and payment processors.

How We Use Your Information

We use or may use information that we collect about you or that you provide to us, including any personal data, to:

Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
Fulfill and manage subscriptions and payments.
Fulfill any other purpose for which you provide it.
Provide you with notices about your account and/or subscription, including expiration and renewal notices.
Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training, provided that any such use will be limited to improving ImpactAlpha’s own Services and will not include sensitive data such as accredited investor verification information.
Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services (including Google Ads) which may promote our Services on websites across the internet. We may use your information to model, segment, target, offer, market, and advertise our Services.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when Services updates are available and about changes to any products or services we offer or provide through them.
To verify accredited investor status.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

Estimate our audience sizes and usage patterns.
Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
Speed up your searches.
Recognize you when you return to our Services.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Your Rights and Choices About Your Information.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates, who will use your personal data in the same way as we do under this Privacy Policy.
Our business partners who offer a service to you jointly with us, or who partner with us to provide the Services to you.
To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Company is among the assets transferred.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Services, we will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by us when you provide the information.
With your consent.
To the public, if you are a contributor to the Services, we may share your name, photograph, and biography on our website and in our promotional materials.
With your consent, when you want to provide our content or invite your friends and contacts to connect with our Services. In time, when we invite your friends to join the Services, we will include your name and photo to let them know that you are the person extending the invitation. After sending these invitations, we may also send reminder emails to your invitees on your behalf. We may send invitations or other promotional materials to these contacts.

We may also disclose your personal data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Service https://impactalpha.com/terms/ and other agreements, including for billing and collection purposes.
If we reasonably believe disclosure is necessary to (a) protect the security or integrity of our website and/or (b) exercise or protect the rights, property, or personal safety of ImpactAlpha, our users, or others.

The categories of personal data we may disclose include:

First and last name.
Account and contact information.
Photograph and biography.
General location information.
Payment information if you register for an account.
Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
Device information.
Other content and information you elect to provide to us.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through the Services or other tracking technologies through the opt out pop-up when first visiting the Services or by emailing us at [email protected]. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services are not able to respond to all browser DNT signals at this time. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
Promotions by the Company. If you do not wish us to use your information to promote our own services, you can opt out by sending us an email stating your request to [email protected]. To stop receiving promotional email communications you can opt out by clicking on the “unsubscribe link” provided in such communications.
Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target audience preferences, you can opt out by emailing us at [email protected].
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out through the opt out pop-up when first visiting the Services or by emailing us at [email protected]. To opt out of Google’s use of cookies or device identifiers please visit Google’s Ads Settings. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”), see NAI: How to Opt Out.

Location data choices:

Location Data. You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please send an email to [email protected]. To appeal a decision regarding a consumer rights request please send an email to [email protected].

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We are located in the United States. Your information collected through our Services will be stored and processed in the United States or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities.

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Links to Other Websites and Services

The Services may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third party websites or services embedded in, linked to, or linked from the Services and your interactions with any third-party website or service are subject to that third party’s own rules and policies.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

Impact Alpha Inc. 2009 Francisco St. Berkeley, CA 94709 [email protected]