Privacy Policy

1. Scope and responsible entity

This Privacy Policy applies to Euuler’s websites, mobile applications, software, communications, and related services (collectively, the “Services”). Euuler Technologies LLC (“Euuler,” “we,” “us,” or “our”) is responsible for personal information processed under this Policy and is the data controller where applicable.

This Policy does not govern independent organizations, members, issuers, sponsors, intermediaries, or other third parties, even when you encounter them through Euuler. Their privacy notices apply to information they process for their own purposes.

2. Personal information we collect

Information you provide

• Contact and identity data: name, email address, telephone number, location, and identity-verification information.
• Professional and affiliation data: employer, title, biography, experience, skills, community memberships, education, and professional interests.
• Profile and matching data: people, expertise, introductions, opportunities, or assistance you seek or offer; preferences; and visibility settings.
• Communications and content: messages to us, survey responses, application information, support requests, feedback, and content you submit through the Services.
• Eligibility information: information used to assess access, community affiliation, identity, jurisdiction, or investment eligibility where relevant.

Information collected automatically

• Device and network data: IP address, browser type, operating system, device identifiers, language, and approximate location derived from IP address.
• Usage data: pages and features viewed, links clicked, referring pages, navigation paths, dates and times, session duration, and interaction and diagnostic data.
• Cookie data: identifiers and information collected through cookies, local storage, pixels, and similar technologies, as described in our Cookie Policy.

Information from other sources

We may receive information from participating communities, people who invite or refer you, other members, service providers, publicly available professional sources, and third parties involved in an opportunity. We may combine this information with information we collect directly.

3. How we use personal information

We use personal information to:

• provide, operate, maintain, and support the Services;
• create and administer accounts and verify identity, affiliation, and eligibility;
• personalize the Services and identify potentially relevant connections, communities, and opportunities;
• facilitate introductions and member-requested communications;
• respond to inquiries and provide administrative, security, and support messages;
• send marketing communications where permitted and manage communication preferences;
• measure audience engagement and analyze and improve functionality, usability, and performance;
• detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms;
• establish, exercise, or defend legal claims and comply with legal, regulatory, tax, and recordkeeping obligations; and
• create aggregated or de-identified information that cannot reasonably identify you.

We do not use sensitive personal information to infer characteristics about you. Please do not provide sensitive information unless specifically requested and necessary for a stated purpose.

4. Legal bases for processing

Where European Economic Area, United Kingdom, or similar law applies, we process personal information under one or more of these legal bases:

• Contract: processing necessary to provide the Services you request and administer your account.
• Legitimate interests: operating, securing, improving, and promoting the Services; facilitating professional connections; and protecting Euuler and others, where those interests are not overridden by your rights.
• Consent: for non-essential cookies, certain marketing, or other processing where consent is requested. You may withdraw consent at any time without affecting earlier processing.
• Legal obligation: processing necessary to comply with applicable law or lawful requests.
• Legal claims and vital interests: processing necessary to protect rights, safety, and legal interests where applicable.

5. Google Analytics

We use Google Analytics 4, a web-analytics service provided by Google LLC, to understand how visitors find and use our websites. Google Analytics may collect or derive information such as online identifiers, cookie identifiers, IP address, device and browser information, approximate location, referring URLs, pages viewed, interactions, and session timing. Google processes this information on our behalf to provide reports, audience measurements, diagnostics, and related analytics services.

We do not intentionally send Google Analytics your name, email address, message contents, or other information that directly identifies you. Google may process data on servers in the United States and other countries. Google’s handling of information is also described in its “How Google uses information from sites or apps that use our services” disclosure and Google Privacy Policy.

Where law requires consent, Google Analytics is disabled until you consent to analytics cookies. You can decline or withdraw consent through our cookie controls, block or delete cookies in your browser, or use the Google Analytics Opt-out Browser Add-on. Your choice may be device- and browser-specific. See our Cookie Policy for more details.

6. How we disclose personal information

We may disclose personal information to:

• Members and intended recipients: according to your actions, settings, and mutual opt-in choices.
• Participating communities: to verify affiliation, administer participation, and support community-related features, consistent with applicable permissions.
• Service providers: companies supporting cloud hosting, authentication, communications, customer support, security, analytics, and professional services, including Google for Google Analytics.
• Opportunity providers: where you request information, an introduction, or participation and authorize the disclosure.
• Professional advisers: lawyers, accountants, auditors, insurers, and consultants subject to appropriate duties.
• Authorities and other parties: when reasonably necessary to comply with law or legal process; protect rights, safety, or security; investigate misconduct; or enforce agreements.
• Transaction parties: in connection with an actual or proposed financing, merger, acquisition, reorganization, sale of assets, or similar transaction, subject to appropriate safeguards.

We may disclose aggregated or de-identified information that does not reasonably identify you for lawful purposes.

7. Sale, sharing, and targeted advertising

We do not sell personal information for money. We do not use or disclose personal information for cross-context behavioral advertising or targeted advertising as those terms are defined by applicable U.S. state privacy laws. We use Google Analytics for measurement and product analytics, not to serve third-party behavioral advertisements. If our practices change, we will update this Policy and provide legally required choices before the change takes effect.

8. Data retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain business and transaction records, comply with legal obligations, resolve disputes, enforce agreements, and protect security. Retention depends on the nature and sensitivity of the information, the context and purpose of processing, legal requirements, and whether the purpose can be achieved by other means.

Account and profile information is generally retained while your account is active and for a reasonable period afterward. Security logs, support records, consent records, and backup copies may remain for limited periods after deletion. Google Analytics retention is configured within our analytics account and cookie lifetimes are described in the Cookie Policy. We may retain de-identified information indefinitely.

9. Security

We maintain reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for protecting your credentials and using appropriate care when sharing information.

10. International data transfers

Euuler is based in the United States, and we and our providers may process information in the United States and other countries whose laws may differ from those where you live. Where required, we use recognized safeguards for international transfers, such as adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful mechanism. You may contact us for information about applicable safeguards.

11. Your choices

• Profile: update certain information and visibility settings through the Services or by contacting us.
• Marketing: unsubscribe using the link in a promotional email. We may still send essential service or legal messages.
• Cookies: manage non-essential cookies through our cookie controls and your browser settings.
• Account deletion: request deletion by contacting us. We may retain information where legally permitted or required.

12. U.S. state privacy rights

Depending on your state of residence and subject to legal exceptions, you may have the right to request access to or confirmation of processing; correction; deletion; portability; and a list of specific third parties to which data was disclosed where required. You may also have rights to opt out of sale, targeted advertising, or certain profiling. As stated above, we do not currently sell personal information or use it for targeted advertising.

To exercise a right, email contact@euuler.com with “Privacy Request” in the subject line. We may verify your identity and residency before completing a request. You may use an authorized agent where permitted; we may request proof of authority and direct identity verification. We will not discriminate against you for exercising a privacy right. If we deny your request, you may appeal by replying to our decision and stating that you wish to appeal.

California notice at collection

In the preceding 12 months, we may have collected the categories described in Section 2: identifiers; customer-record information; internet or electronic-network activity; geolocation at an approximate level; professional or employment-related information; education information; and inferences drawn from profile, preference, and usage information. We collect, use, disclose, and retain these categories for the purposes and periods described in this Policy. We do not knowingly sell or share personal information of consumers under 16.

13. EEA, UK, and Swiss privacy rights

Subject to applicable law, you may request access, correction, deletion, restriction, portability, or objection to processing, including objection to direct marketing and processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time. You may lodge a complaint with your local data protection authority. We encourage you to contact us first so we can address your concern.

14. Children

The Services are intended for adults and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us so we can take appropriate action.

15. Third-party links and services

The Services may link to third-party websites or services. We are not responsible for their privacy or security practices. Review their policies before providing information.

16. Changes to this Policy

We may update this Policy to reflect changes in our practices, technology, Services, or legal obligations. We will post the revised Policy and update the date above. If changes are material, we will provide additional notice as required by law.

17. Contact us

To ask a privacy question, exercise a privacy right, or request information about international-transfer safeguards, contact:

Euuler Technologies LLC
Attn: Privacy
450 7th Avenue, 31st Floor
New York, NY 10123
contact@euuler.com