Privacy Policy

Digital Executive Network
Effective Date of Current Policy: January 29, 2024

Wunderkind Corporation (“DEN”), an invite-only community of consumer focused business leaders (our “Members”) from early-stage startups to large enterprises. DEN members exchange learnings and best practices, and innovative strategies in building a world class organization. DEN connects with peers and talent and accesses emerging technologies through events, content, and partnerships. This Privacy Policy describes the information that we collect through our websites, including theden.co  (the “Websites”), our products, our services (“Services”), including information we receive from Members. This Privacy Policy also describes how we use that information.  If you have any questions about our Privacy Policy, please contact us at privacyrequests@wunderkind.co. 

The Types of Information that We Collect and How We Use it

The Websites and our general business operations

Our Websites are directed to our Members, which are generally individuals. We collect two types of information from visitors to our Websites: personally identifiable information and pseudonymous information. Personally Identifiable Information (“PII”) is information that may be used to identify an individual and includes email address, telephone number or postal address. Pseudonymous information doesn’t enable us to identify anyone but may help us recognize a particular browser or device over time. Both PII and pseudonymous information are considered personal data and/or personal information in many places. We believe that maintaining the distinction between what we consider directly identifiable and what we consider to be pseudonymous can be helpful in describing our privacy practices, but recognize that some privacy laws don’t distinguish between the two types of data.

 

We don’t generally knowingly collect sensitive or special category data such as ethnicity, religion, sexual interest, health data or data from minors as defined under applicable law other than in an employment context which is covered under a different policy. We ask our Members not to send this type of information to us. Some places consider precise location to be sensitive. We don’t collect or otherwise process precise geolocation data (e.g., lat/long) but we may obtain more general GEO data such as postal code or city (e.g., when we infer such information from an IP address).

 

We also generally don’t collect PII via the Websites unless it is provided to us. For example, if you purchase our products or Services, we may request certain personally identifiable information from you on our order form.  This includes contact information such as your name, email address, and address, as well as financial information such as a credit card number and its expiration date.  We use this information for billing purposes and to fill orders. If we have trouble processing an order, we also will use this information to contact you. We do not sell this information and generally will only use it for the purpose it was provided.

 

In addition, if you contact us by email or otherwise provide your email address to us through our Websites, we may keep a record of your contact information and correspondence.  We reserve the right to use your email address and any other PII that you provide to us to respond to your inquiries and to send you marketing materials for our own products and Services.  We also reserve the right to share contact information you provide to us in connection with accessing certain content through our Websites (for example, webinars with industry partners) to our production partners or sponsors of such content. To the extent that such sharing of this data would be considered a sale under applicable law, we’ll provide a privacy notice and provide data subjects with the right to opt-out. We will not otherwise share your contact information with outside parties for the purposes of marketing other products and Services to you without your consent.

 

We also collect pseudonymous information via the Websites such as the name of your internet service provider, the IP address of the computer or device you are using, the type of browser and operating system that you use, the date and time you access our Websites, the website referrer address and other log file information.  Like most websites, our Websites use “pixel tags”, “web beacons”, “cookies” and/or similar tracking technologies that allow us to track the actions of visitors to our Websites as described here. We use this information to help us improve our Websites and the products, Services, applications, content and features that we provide. We also enable third parties to collect pseudonymous data via the Websites. This process may be deemed a sale of information in certain jurisdictions, and we will provide a notice and provide the ability to opt-out of such sales in those jurisdictions. We reserve the right to aggregate information collected from visitors to the Websites for any purpose, including publishing aggregate statistics about our Clients’ and/or Websites’ visitors, counting and better understanding our site visitors and protecting our Websites from security issues or fraud.

 If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

 

 

 

 

You can opt out of receiving any further marketing or promotional text (e.g, SMS/MMS) messages from DEN at any time by replying “STOP” to any SMS message you receive from DEN.  For help, reply “HELP” to any SMS message you receive from DEN.  In addition to any fee of which you are notified, your mobile provider’s standard message and data rates may apply to the SMS message correspondence with DEN according to your individual rate plan provided by your wireless carrier.  Please consult your mobile service carrier’s pricing plan to determine the charges for browsing data and sending and receiving SMS messages.  Under no circumstances will DEN or DEN’s affiliates be responsible for any SMS messaging or wireless charges incurred by you or by a person that has access to your wireless device or telephone number. If your carrier does not permit SMS messages, you may not receive the SMS messages.

The Tracking Technologies used by our Platforms and our Services

Our Platforms and our Services may utilize tracking technologies such as pixel tags, HTML5 cookies, HTTP cookies, web beacons, statistical identifiers, and mobile o/s advertising identifiers such as Apple’s IDFA, the Android Advertising ID and other pseudonymous information. For more information about cookies and web beacons, please visit allaboutcookies.org. Statistical identifiers are created when our systems read pseudonymous information about your computer or device, including the user agent, IP address, and the browser and operating system of your computer and device. Statistical identifiers enable our systems to determine within a reasonable level of certainty that they are encountering the same computer or device, including in environments where third-party cookies are not supported. If you want to see whether our are using a statistical identifier on the browser you are currently using, please visit https://optout.networkadvertising.org/?c=1#!/. If you would like to reset the value of this identifier, you may do so here. More information on this reset functionality under “choice mechanisms”  below.

How We May Transfer the Information We Gather to Third Parties

Generally, we will not disclose the PII that we collect through your use of our Websites to unaffiliated third parties without consent.  We reserve the right, however, to provide such information to our affiliates, employees, contractors, agents, service providers and designees to the extent necessary to enable them to perform certain services for us, including order fulfillment and Website-related services such as web hosting, to improve Website-related services and features, to perform maintenance services, to distribute advertisements and other marketing materials on our behalf and to host our data. Other third-party service providers used by DEN include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors. These agents work on our behalf and use data only as directed by us under written agreements which outline how they may use such data and require that such third party agents provide at least the same level of privacy protection as we do.

DEN may transfer data collected through DEN’s Website, and our marketing activities to entities such as: (i) website analytics vendors, who collect cookie and website engagement information to help understand website performance, (ii) advertising vendors, who collect cookie and website engagement information to target relevant advertising, and (iii) email marketing and lead database vendors, who collect email address and other personal information to improve email marketing efforts. Some of the transfers to these entities would constitute a sale or sharing of personal information under applicable law.

We reserve the right to disclose any information that we collect to any third party if we believe that we are required to do so for any or all of the following reasons: (i) to comply with the law; (ii) to comply with legal processes or governmental requests including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Websites or our network; and/or (iv) to protect the rights, property, safety and security of DEN and its employees, our Websites’ visitors, and/or the public. Finally, we may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change and will provide notice of such change on our Websites.

We also may aggregate the data processed by our Website in order to derive insights. For example, we may publish a report that reflects aggregated statistics. By aggregating this data, we have removed any identifiable or pseudonymous personal data.

Precise Location Choices.  While we don’t generally collect or otherwise process precise location data such as lat/long, we offer the following information as a courtesy. If you’d like to adjust your choices regarding the use of precise location data by third parties, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.

While our systems are able to recognize a Do Not Track (DNT) setting in a browser, we currently take no response to such signals.

Children’s Privacy

DEN adheres to the Children’s Online Privacy Protection Act. Our Websites are not directed at children. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.

We are Committed to Making Sure Your Information is Protected

Our physical, electronic, and procedural safeguards meet or exceed current industry standards regarding the protection of the information in our systems.  We also require contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us.  Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure.  Consequently, while we use commercially reasonable efforts to protect information in our systems, we cannot guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Websites.  Any information that you provide to us is done so entirely at your own risk.

Data Minimization and Retention

DEN has internal procedures which are designed to ensure that we only process the minimum data as requested by Members. We retain the IBA data that we collect for up to 13 months from the date of collection. Cookies used for IBA expire 13 months after they are last updated. EU data subjects may have additional rights or information as described below.

Data Subject Access Rights

Upon request, DEN will provide you with information about whether we hold any of your PII. If you’d like to update, correct, delete, or deactivate any PII that you have provided to the company on this Website, please send your request to privacyrequests@wunderkind.co, and we will process your request. We will respond to your request to access within a reasonable timeframe. EU and California data subjects may have additional access rights as described below. 

We Reserve the Right to Update and Revise this Privacy Policy at Any Time.

From time to time we review this Privacy Policy to ensure that it complies with applicable law.  Consequently, we reserve the right to update and revise this Privacy Policy at any time.  You will know if this Privacy Policy has been revised since your last visit to the website by referring to the “Effective Date of Current Policy” date at the top of this page.  Your use of our Websites constitutes your notice and acceptance of the terms of the Privacy Policy as amended or revised by us from time to time, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

In the Event We Engage in a Business Combination, We Reserve the Right to Transfer Any Information in Our Systems.

If we sell all or any part of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or other transfer or disposition of any part our business, we reserve the right to access, transfer or disclose any and all information that we collect from our Websites’ visitors, or that we otherwise collect in connection with the Websites, to the party or parties involved in the transaction as part of that transaction.

U.S. DATA SUBJECTS IN APPLICABLE STATES

Certain U.S. States each provide additional privacy protections for data subjects located within their jurisdictions, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your computer or device,   d) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information), and e) the right to port such data to a different company. We do not discriminate against you if you exercise any of the above rights. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal information) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.  While we attempt to honor these rights for data subjects located in all U.S. states, please note that we may not be able to honor a right if doing so would otherwise violate applicable law. Further details about exercising these rights can be found on our data request page.  Data subjects may access those rights with respect to DEN by calling our toll-free California privacy hotline at (888) 594-0111 or sending us an email to privacyrequests@wunderkind.co.

Special Data Protections for EU, UK and Brazil Data Subjects.

The General Data Privacy Regulation (“GDPR”) and similar country specific data protection laws afford additional rights to data subjects located in applicable jurisdictions such as the European Economic Area, the United Kingdom and Brazil:

  • requesting information about the processing of your data, as well as the receipt of a copy of your personal data;
  • correcting your data;
  • deleting or blocking your data;
  • restricting the processing;
  • objecting to the processing of your data;
  • revoking your consent to the processing of your data in the future, and
  • complaining to the competent supervisory authority about inadmissible data processing.

These rights can be exercised by visiting our data request page. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal data) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.  Where DEN is a processor of data , the legal basis for processing such data and the retention period is determined by our Members. Where DEN is a controller of data, the legal basis will be both legitimate interest (e.g., where we have evaluated that our interests are not overridden by Users’ fundamental rights) and consent depending on the type of information subject to processing and the information we receive from upstream partners. Where DEN receives a request to cease processing of data from a data subject located in the EU or Switzerland, DEN will stop all data processing with respect to the opted-out browser or device unless such processing is required by law. DEN’s Data Protection Officer is Alan Chapell and DEN’s EU representative is Verasafe and both may be contacted at dpo@wunderkind.co or by mailing to the address found below. DEN’s UK contact details are also provided below.

Cross-border data transfers between the EU, Switzerland, UK and the U.S.

DEN is based in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence.  DEN complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses and similar contract language required under applicable data protection laws.

 

Our Websites may Contain Links to Other Websites.

Please be aware that we are not and cannot be responsible for the privacy practices of any websites that you access through our Websites and that this Privacy Policy applies solely to the information which we collect.  We encourage you to ensure that you read the privacy statements of all the destination websites which you visit.

Changes to This Privacy Policy

This Policy may be amended from time to time, consistent with applicable laws. When we do, we will also revise the “Last Updated” section above. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the information we collect.

Contact DEN Regarding Our Privacy Practices.

If you have any questions or concerns regarding this Privacy Policy, please contact us at privacyrequests@wunderkind.co.  We will make every effort to resolve your concerns. Alternatively, you may contact us at the address below:

Wunderkind Corporation

Attn: Privacy Officer

1 World Trade Center, FL 74

New York, NY 10007

 

Wunderkind UK:

16 Dufour’s Place

London

W1F 7SP

 

UK GDPR Representative:

Wulfric Light-Wilkinson

General Manager, EMEA

Email: privacyrequests@wunderkind.co