PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679
– “HabiSmart, Acceleration Program”
Last Updated: July 16, 2020
MassChallenge, Inc. (“we” or “us” or “MassChallenge”) is a US-based start-up accelerator with divisions in Israel, Mexico, and Switzerland, that runs a series of programs and competitions for select early-stage entrepreneurs (collectively, the “Programs”). We respect your privacy and are committed to protecting the personal information you share with us. This Privacy Notice explains how MassChallenge handles personal information obtained through your use of our websites (masschallenge.org) and its various subdomains such as accelerate.masschallenge.org (collectively, the “Site”), as well as your application to or participation in any of our Programs.
With respect to the collection of your information, if you do not want your personal information collected, please do not submit it to us. If you have already submitted information and would like to review, correct, or remove it from our records, please contact email@example.com.
By visiting and using the Site, you are deemed to have agreed to the provisions of this Privacy Notice, unless you are in the EEA or Switzerland in which case you are acknowledging that you have been provided this Privacy Notice.
1) Information that we collect
We collect different personal information from you depending on how you want to engage with us at MassChallenge. We also automatically collect non-identifiable data through the Site (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
a) Personal Information
When you register for the MassChallenge Newsletter we require your name and email address to enable delivery to you, and we request your company, and title so that we can know a little more about whom our programs attract. We also ask if you want to indicate which regional updates (e.g. Boston, Israel, Mexico, Switzerland) you prefer so we can customize our information to you.
If you apply to participate in a Program as a startup or you apply to participate as a MassChallenge Expert (such as a “judge, “mentor,” or “speaker,”), we ask you to create a User Profile and you will create a password and provide additional details about yourself, including your bio, a photo, your gender, social networking links, and fuller details of your educational and business background and/or business idea. Some of this information is required and some is optional, and the specific details collected vary depending on your role. We use this information to evaluate your application. If we select you to participate, then we will process the information you and others generate during the course of the Program, such as work papers, correspondence with other Program participants and MassChallenge experts, and of course your final submission. For instance, we collect information about how competitors are judged, their rank, and which Mentors are assigned to which competitor teams, etc. All of this information is necessary for us to operate an individual Program.
By applying to participate as a startup or as an expert, we will use your basic contact details to send you surveys concerning your opinion of how we run applications and Programs, and we collect information from you when you respond to those surveys.
If you wish to apply for an internship or employment with MassChallenge, separate links on the Site will bring you to a page listing current opportunities. We and our recruiting vendors (ClearCompany) will use the information you submit in an application only for the purposes of evaluating and interacting with you for that specific job posting.
Our Site may include social media features, such as the Facebook, YouTube, and Twitter buttons. These features may also collect your IP address, which page you are visiting on our Site, and may set a cookie (see below) to enable the feature to function properly. These features may also give you the option to post information about your activities on our Site to your profile page to share with others within your network. Your interactions with these features are governed by the privacy notice of the company providing them.
MassChallenge may invite you to participate in questionnaires and surveys. If you choose to participate and provide information in response to a questionnaire or survey (collectively, “Survey Responses”), this information will be used to conduct research and analytics (for example, relating to Program application, participation and outcome trends).
b) Cookies and Other Data Collection Tools
We also collect non-identifying information about your interaction with our Site so that we can better understand how visitors use our Site and thus how we can improve the Site functionality. For example, we collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type, and language, access times and referring website addresses. We may also use website analytics tools on our site to retrieve information from your browser, including the site you came from, the search engines and keywords you used to find our Site, the pages you view within our Site, the links you click on, and your browser add-ons.
Additionally, we may use technologies, such as cookies and web beacons, to collect information about the pages you view, the links you click and other actions you take on our sites and services. Cookies, web beacons and/or similar technologies were originally designed to help a website distinguish a user’s browser from a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site or to track the user’s activities. These can be helpful, for example, in recognizing your browser as you move between pages of the Site, login, and improve your experience on the Site when you have logged in.
A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you. Cookies cannot be used to retrieve any other data from your hard drive, capture your email address, run programs, or deliver viruses to your computer. A web beacon is a small transparent gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. These assist in delivering cookies on our Site and allow us to count users who have visited those pages. This technology is similar to a cookie in that it tracks your visit and the data can only be read by the server that receives the data. It is different than a cookie in that it is not browser-based, may not function as an identification card, and does not store any data on your computer. We refer to these technologies collectively as “Data Collection Tools.”
Some of the most common cookies, along with their primary purposes, that we use on our Site are listed below:
AddThis (_atssc, _atuvc, _attuvs, loc, mus, na-_id, ouid, ssc, uid, uvc): These cookies help enable social sharing tools on our Site that allows you to share the content on social media or by email. These cookies track interactions with the embedded sharing buttons and monitor its usage.
Facebook (_fbp): These cookies enable MassChallenge to deliver targeted advertising to visitors to our Site when they are on Facebook or a digital platform powered by Facebook Advertising.
Google Analytics (_ga, _gi): Registers a unique ID that we use to gather statistical data on how anonymous visitors use the Site.
If you wish to disable cookies, you can set your browser not to accept cookies. You can find out how to do so here: www.aboutcookies.org. Please note though that if you turn off cookies, there may be some features and functions of our Site that will not be available to you and some pages may not display properly.
Do-Not-Track Signals – Your browser may allow you to set a “Do Not Track” preference. We currently do not respond to “Do Not Track” or similar signals.
c) Data Collection by Third Parties and Google Analytics
We may integrate Data Collection Tools from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our Site.
We use Google Analytics to collect data about and to assess the performance of our Site. Google captures this Site usage data for use as described in “How Google uses data when you use our partners’ sites or apps.” You can prevent your data from being used by Google Analytics on websites including ours by installing the Google Analytics opt-out browser add-on here. We also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users. Portions of our Site may also use Google Analytics for Display Advertisers including DoubleClick or Dynamic Remarketing which provide interest-based ads based on your visit to this or other websites. You can use Ads Settings to manage the Google ads you see and to opt-out of interest-based ads.
2) How we use your information
We use your personal information to provide you with the information you have requested, to manage your participation application, to operate our Programs, and to market and improve our Site and Programs. We described above in the Personal Information section what sort of identifiable information we collect, the context in which we collect it, and examples of reasons why. As you can expect, we use personal information for our own internal business operations as well as to operate and promote MassChallenge and the Programs. For example, we may use your personal information to:
- Send you newsletters you request
- Manage your application for an internship or a job posting
- Verify your eligibility to participate in a Program
- Match you with mentors and judges
- Match you with partners
- Match you with other Program participants and MassChallenge staff in order to operate the Program
- Provide a technology platform for document submissions and communications with your mentors and others
- Match you with the event, category, or services best suited to your company’s needs
- Analyze and measure the success of our Programs and Program participants over time
We also may use your information to communicate with you and to provide ongoing service and support during a Program. Occasionally we may use your information to contact you to complete surveys associated with our Programs that we use for Program improvement purposes.
If you have expressly permitted us to do so, we may also use your personal information to send you (or have our business partners or marketing agencies send you on our behalf) marketing information or to contact you for marketing research. At a minimum, we will always give you the opportunity to “opt out” of receiving marketing materials you choose to unsubscribe from.
If we would like to use your personal information for any purposes other than those described, or as otherwise permitted under applicable law, we will obtain your prior consent.
3) Information sharing and disclosure
We may share your information with people and organizations MassChallenge trusts who need your information in order for MassChallenge to run its Programs or perform other services related to MassChallenge running its business and providing its services.
We may share your personal information with Program participants and MassChallenge staff insofar as it is necessary to run the Programs and otherwise conduct the business of MassChallenge that we have described in this Notice. The first category of third party recipients is our MassChallenge Partners. We will disclose to our Partners the following categories of personal information concerning that Program:
- Startup team and team participant names and basic contact details
- Basic Startup Profile Information, such as your elevator pitch
You may decide to put your Startup Profile information into “stealth mode”, under which circumstance we would only share your Startup Team and Startup Profile information with our Partners if you give us permission to do so. You can switch your Startup Profile into stealth mode at any time via our website, which will also make your Startup Profile no longer appear on https://masschallenge.org/startups.
If you choose to provide personal information in a Survey Responses, we may also share such with our Partners for their use to conduct research and analytics (for example, relating to Program application, participation and outcome trends).
Our current list of Partners is available here: https://masschallenge.org/partners
The second category of third party recipients largely consists of our vendors and service providers, who help us to run a Program and our business. These include, for example, ClearCompany for employment applications, Salesforce for CRM purposes, SurveyGizmo for surveys, Microsoft Office 365 and Google Apps for online communication purpose. We only share personal information with these third-parties for the purpose of performing services on our behalf. We require that these parties only process the personal information for limited and specified purposes consistent with this Notice.
We occasionally take photos, make videotapes, and/or make recordings of the events in order to document the competitions and also for promotional purposes. We may use your name, photo, likeness and information about you on our Site for the purpose of informing visitors about our programs. We will not use this information for any purpose other than in connection with promoting our services and programs and to document the programs unless we ask you and you permit us to do so in advance.We reserve our right to disclose your personal information if we have a good faith belief in our sole discretion that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Legal Notice and terms of Program participation, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of MassChallenge, its users or the public as required or permitted by law. We may also share personal information in connection with the sale, merger, divestiture, reorganization or any other corporate transaction involving MassChallenge.
We may share aggregated and non-personal information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis, including analysis into the success of our Programs and Program participants. We do not share the information you provide with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure.
We may share your personal information with academic researchers for statistical analysis and academic research and expression in various fields of study. If we share your personal information with academic researchers, it will only be provided in a pseudonymized format.
We do not sell your personal information under California or Nevada law, which defines certain disclosures of personal data for monetary or valuable consideration as “sales.”
4) How long we keep your personal information
We typically only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law.
We will typically retain personal information for the longer of the period a) required by law or b) a time-bound determination of legal and business risk. For examples of the latter, we will maintain: An internship or employment application for 3 years beyond the application submission A Startup or Expert application for 15 years beyond the application submission Participant contact details along with your Program role for 15 years beyond the specific Program work papers, communications, and such except for materials forming part of a team’s final submission for 15 years
5) Rights and access to your personal data
We make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
If you have created a User Profile and registered to participate as a startup or an expert, you can login to your Account from the Login Page, review your personal information, and make changes from there. If there is something you wish to change but cannot from your Account page, then contact us and we will help.
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please contact us at firstname.lastname@example.org.
*Rights for Nevada Residents: Under a Nevada privacy law, certain Nevada residents may opt out of the sale of certain categories of personal information. As of the effective date of this Privacy Notice, we do not sell any type of information covered by that law. However, if you are a Nevada resident who would like to opt-out of any future sale of your information in the unlikely event we change our practices, you may do so by contacting us at email@example.com. Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact you if needed to verify your identity and the authenticity of the request.
6) Children’s privacy
Our website is not intended for children under the age of 16.
We do not knowingly collect information from children. In the event that we learn that we have collected personal on the Site from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at firstname.lastname@example.org.
7) Visiting our Site from outside the United States
We store and process all personal information for the MassChallenge Programs within the US.
8) If you are visiting our Site from outside the United States
Or applying for an internship/employment, or participation in a Program, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your personal information is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Notice.Visiting our Site from the European Economic Area (EEA) or Switzerland.
a) The Legal Basis for Using European or Swiss Personal Information
When we collect information about you through our Site and you have not applied to participate in our Programs as a startup or an expert, the legal basis on which we process your personal information is fulfillment of an agreement between us, namely, to provide you with the internship/employment consideration or the MassChallenge Newsletters and other information marketing our Programs in response to your request.
When we collect information about you through our Program, the legal basis on which we process your personal information is the performance of our agreement with you to participate in the Program, whether as a startup or as an expert. When we use your personal information (as startup or expert) outside of what is strictly necessary for that Program, we are doing so toward our legitimate interest of a) informing you of related Programs, activities, and opportunities, or b) reporting to others, such as Partners, on the results of the Program and certain participant teams. When we share your personal information with academic researchers, we are doing so towards our legitimate interest of supporting academic expression and statistical research.
To the extent that we transfer personal information from the EEA or Switzerland to a jurisdiction outside the EEA or Switzerland that has not been adduced by the European Commission as providing adequate data protections (such as the US), we will ensure that such personal information is safeguarded through appropriate contractual terms.
b) Rights for EEA or Swiss Residents
In addition, if you are a resident of the EEA or Switzerland, you have the right to:
- Find out if we use your personal information, to access your personal information, and receive copies of your personal information.
- Withdraw any express consent that you have provided to the processing of your personal information at any time without penalty.
- Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
- If you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your personal information be deleted or restricted under certain circumstances. For example, if MassChallenge is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent.
If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal information, please contact us at email@example.com the details below.
If you are not satisfied with our response, or believe we are processing your personal information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) in your EEA country. For our operations within the EEA, our Lead Supervisory Authority is the UK Information Commissioner’s Office (www.ico.org.uk)
9) Account Information Security
MassChallenge safeguards the personal information you send us and takes reasonable physical, technical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to your personal information. We use industry-standard efforts to safeguard the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). While we strive to protect your personal information, we need your co-operation to ensure the security of the information you transmit to us. We urge you to take every precaution to protect your personal information while using the Internet. Change your passwords often, and use a passphrase instead of password with at least 8 characters in combination of letters and numbers. Make sure you use a secure internet browser, follow the vendor suggestion and apply updates when required.
10) Third Party Sites
Our Site may contain links to websites operated by other companies. Some of these third-party sites may be co-branded with a MassChallenge logo, even though they are not operated or maintained by MassChallenge. We do not share your personal information with those websites and are not responsible for their privacy practices. Once you have left our Site, you should check the applicable privacy notice of the third-party website to determine how they will handle any information they collect from you.
11) Forums and Blogs
12) Changes to this Privacy Notice
We review and update our Privacy Notice periodically and will post any changes on this page. If you continue using our Site, you will be agreeing to the revised Privacy Notice, unless required by applicable law otherwise. We recommend that you check our Site from time to time to inform yourself of any changes in this Privacy Notice. If we make significant changes to our Privacy Notice, we may notify you, where appropriate, by other means.
13) Contact, Questions or Feedback
If you are in the EEA:
Chemin du Closel 5
If you are in the US or elsewhere outside the EEA:
21 Drydock Ave, Suite 610E Boston, MA 02210
When we receive formal written complaints, it is our policy to contact the person regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between MassChallenge and an individual.