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thelighthouse Privacy Policy 
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Last Updated: October 19, 2019

Welcome to thelighthouse!  thelighthouse International, Inc. (“thelighthouse,” “we,” “us,” “our”) respects the privacy of our users.  This Privacy Policy describes how we collect, use, and share certain information about you (“you,” “your,” “user”) in connection with our website and service (the “Services”) which are located at https://www.thelighthouse.us.  It also explains your rights and choices with respect to such information and the steps you can take to protect your privacy.

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Please read this policy carefully.  By visiting or using the Service, clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to thelighthouse, you are consenting to the collection, use, and sharing of your information as described in this Privacy Policy.

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thelighthouse Users

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thelighthouse’s Services are available to different types of users, including Members and Insiders who use the coaching services, and website visitors (Users) who view the thelighthouse website (each individual or collectively a “user” or “you”).  The information that the Services collects from and shares about you may vary based on your interactions with our Services as a Member, Insider, or User.

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  • A Member is an individual who has registered for the coaching Services to obtain career advice and support, including through career counseling sessions with Insiders.

  • An Insider is an individual who has registered as a counselor and provides career advice to Members.

  • A User is an individual that visits or uses the website, and includes Members and Insiders.

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Information that We Collect 

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We and our service providers collect a variety of information through the Services.  We collect information from you directly when you provide it to us through the Services and when you engage in certain actions on the Services, as well as from third parties such as your employer when your employer subscribes to thelighthouse Services for your use.  We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Service. This information includes, but is not limited to:

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  • Account and profile information.  In order to create an account for you on thelighthouse as a Member or Insider, we collect your first name, email address, and password.  You may optionally provide us with your last name, a profile photo, your location, and/or a link to your LinkedIn profile. Insiders are asked to create a public profile,  which may be viewed by our members, and may also be asked to provide their phone number and their professional resume.

  • Career information.  We ask that Members complete a quiz about their career experience and goals, and that Insiders provide information about their own experiences in their industry and with coaching and mentoring.  This information becomes part of your Member or Insider profile and enables us to match Members with the appropriate Insiders.

  • Insider application information.  For individuals who apply to be Insiders, in addition to account and profile information we collect your telephone number, prior work experience information, motivation for joining thelighthouse, and information about your previous mentorship and/or coaching experience.  We may, during a telephone interview, ask for additional information about your motivation and experiences.

  • Social media information.  thelighthouse may allow Members and Insiders to log in to the Services using a third-party social media service, such as LinkedIn.  If you choose to do so, we may collect and store information about you from the social media provider, including, for example, your name, username, email address, and available profile information, such as your public profile URL, profile photo, birthdate, gender, and address. We will ask for your consent prior to your logging in to the Services using your social media account or connecting your social media account to the Services.

  • Payment information.  If you subscribe to our Services, our payment processors may collect your payment information, such as credit or debit card number, expiration date, and security code.  If you are an Insider, we ask for your PayPal account information in order to remit payments due to you when you participate in coaching sessions.

  • Chat messages.  Our Services integrate chat services, such as Slack messaging, in order to facilitate communications between Members and Insiders.  thelighthouse has access to, collects, and stores the contents of chat messages that occur and documents that are shared through the messaging features.

  • Video sessions.  We use live video platforms or integrations, such as Zoom Video Communications, Inc. (Zoom), to host Member and Insider career coaching video sessions.  These platforms store a recording of the video chat on their servers, and provide us access to that data. When you participate in a video session, the session is recorded as described above, and we store the recording both for you to access and for our own business purposes.  

  • Information you provide to us directly when you contact us.  We and our service providers also collect User information when Users communicate with us through the Services, such as through any “Contact” or “Help” feature, including any customer support chat messaging feature, on the Services.

  • Information provided by your employer about you.  When your employer subscribes to our Services in order to provide our Services to you, your employer may provide us with your name, job title, and email address in order for us to contact you about creating an account for our Services.

  • Feedback and surveys. After each session, we request feedback from Members and Insiders through a feedback form.  From time to time, we may also ask Users to complete surveys or interviews to help us improve the Services.  Such surveys or interviews may be used to collect information about you. Participation in these surveys and interviews is completely voluntary, and you therefore have a choice whether or not to disclose your information.

  • Information collected automatically.  When you use our Services, we or our third-party service providers may automatically receive and record certain information.  For example, this may include your device’s IP address, information about your use of the Services during your current session and over time (including the pages you view and the files you download), the date and time of your visit, how you interact with the Services including mouse movements and mouse clicks, links you click, searches conducted, the website visited before navigating to the Services, your software and hardware attributes (including browser and operating system type and version, device type, and device identifiers, such as IDFA or Google Ad ID), and your general location inferred from IP address.  To obtain such information, we or our third-party service providers may use the following technologies to recognize your device and collect information about your Services usage:

  • Server logs.  When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser.  To obtain such information, we may use server logs or applications that recognize your device and gather information about its online activity.

    • Cookies.  We also use cookies on the Services.  Cookies are small files that are stored on your device by your web browser.  A cookie allows us to recognize whether you have visited before and may store user preferences or other information.  We also use cookies for analytics and advertising purposes as described below in the section “Analytics and Interest-Based Advertising.”  If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.  You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.    

    • Web beacons, tags, pixels, and similar technologies.  The Services and the emails that you receive from thelighthouse may use an application known as a “web beacon” (also known as a “tag” or “pixel”) and similar technologies.  Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For example, it may allow an email sender to determine whether a user has opened a particular email.

    • Local storage.  We may use Local Storage Objects (LSOs) such as HTML5.  Your browser may offer its own management tool to manage LSOs.

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We may combine information collected through the Services with information that we collect in other contexts, such as information from our email communications or phone calls with you, and data we collect offline.  We will treat such combined information in accordance with this Privacy Policy.

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How We Use Information that We Collect

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We and our service providers use the information that we collect for a variety of purposes, including:

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  • Providing the Services.  To create an account for you on thelighthouse, to provide you with career coaching, to fulfill the terms of any agreement you have with us, to respond to your requests, and for other purposes related to managing our business;

  • Communicating with you.  To communicate with you regarding your account, updates regarding our Services, and other administrative issues, and to respond to your questions or requests;

  • Considering your application to become an Insider.  To consider you for a position as an Insider to provide career coaching and insights to Members through our Services.

  • Enabling chat and video sessions.  To enable messaging and video sessions between Members and Insiders.  As described above, our Services integrate Slack messaging and Zoom video conferencing.  The messaging that occurs through the Slack and Zoom platforms are recorded and retained for our internal business purposes, including without limitation for purposes of Insider evaluation, training, dispute resolution and to improving our Services, as well as for legal purposes, as necessary.  The video recordings may also be made available to you and/or the other party to the recording for future viewing through the Services, or to you individually for review;  

  • Sending newsletters or other promotional messages.  To send you newsletters or other promotional messages regarding our Services or other services that may be of interest to you;

  • Conducting analytics and improving our Service.  To count and recognize users of the Services, analyze how the Services are used, improve the Services and the User experience, create new products and services, and conduct analytics, including as described in the section below titled “Analytics and Interest-based Advertising”; 

  • Tailoring our content and advertisements.  To tailor content on the Services and target our advertising, including as described in the section below titled “Analytics and Interest-based Advertising”;  

  • Compiling aggregated and de-identified information.  To compile aggregated and de-identified statistics or reports that we may share with our partners or other third parties;

  • Legal purposes.  For legal or other necessary purposes, including as described below in the section below titled “How We Share information.”

  • Lawful business purposes.  Where permitted by law, for other purposes related to managing our business.

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How We Share Information

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We share information with third parties for a variety of reasons, including as follows:

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  • Members and Insiders.  Members can view the name, profile photo, and profile and career information of the Insiders with whom they are matched.  Insiders can view the profile information (including LinkedIn profile, career quiz responses, and booking form responses) of the Members with whom they are matched.  Once a calendar invitation is set for a meeting, Members and Insiders can view each other’s email addresses.

  • Employers.  We occasionally share Insider profiles with employers or other parties who are interested in obtaining our Services in order to explain our Services.  We do not share Member profiles with the Member’s employers or other parties, however, we may share insights that are based on aggregated information with employers about their employees using the Services.  We also may share with employers information about how frequently their employees use the Services, the number of sessions redeemed, and deidentified feedback from sessions collected through post-session feedback forms.

  • Service providers.  We use third-party service providers to help us manage and improve our Services.  These service providers may collect and use your information only to assist us in achieving the purposes discussed in this Privacy Policy.  For example, we use third parties to host our website and perform data storage and processing services, provide help chat service features, send emails, and perform analytics, provide our messaging and video conference platforms, and process payments, among others.

  • Facebook Custom Audiences and Similar Programs.  We may partner with Facebook, Twitter, and other social media partners to deliver advertisements to our Users via Facebook Custom Audiences or similar third-party programs.  In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address. For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

  • Third-party plugins.  The Services may also integrate third-party plugins (such as a Facebook “like” button and Twitter “follow” button).  Even if you do not click on these plugins, they may collect information about you, such as your IP address and the pages that you view.  They also may set and/or access cookies or use similar technologies. These plugins are governed by the privacy policies of the companies providing them.

  • Legal purposes.  We may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:

    • To comply with applicable law or a court order, subpoena, or other legal process; 

    • To investigate, prevent, or take action regarding illegal or prohibited activities, suspected fraud, violations of our rules or terms and conditions, or situations involving threats to other Members, Insiders, and Users, our property, or the property or physical safety of any person or third party;

    • To establish, protect, or exercise our legal rights or defend against legal claims.

  • Organizational transfers.  We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our organization or assets.

  • Aggregated and de-identified information.  We may share aggregated and de-identified information with third parties, such as by publishing or sharing reports with third parties about trends in the usage of thelighthouse’s Services.

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Analytics and Interest-based Advertising

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We partner with certain third-party service providers to collect information to engage in analytics, auditing, research, and reporting.  These third parties may use server logs, web beacons, tags, pixels, and similar technologies, and they may set and access cookies on your computer or other device.  

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In particular, we use Google Analytics on our Service to help collect and analyze certain information for the purposes discussed above.  You can learn more about Google Analytics’ data practices by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here.  

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We also partner with third parties to provide advertising services that are targeted based on your online activities across websites, mobile apps, and devices over time (commonly referred to as “interest-based advertising”).  Our advertising partners may collect information about your activities on our Services on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Apple’s IDFA or Google’s Advertising ID), cross-device linking, and similar technologies.  For example, our advertising partners may use the fact that you visited our websites or used our mobile apps to target advertising to you on other websites and mobile apps on your current device or on other devices you use. You can opt out of interest-based advertising in web browsers and mobile apps on your current browser or device by following the instructions below.  

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For more information about interest-based advertising and cross-device linking, please visit the Network Advertising Initiative website and the Digital Advertising Alliance website.  You may also opt out of interest-based advertising and cross-device linking in web browsers and mobile apps on your current browser or device by following the instructions below.  

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  • Web Browser Opt-Out. To opt out in web browsers, please visit http://optout.aboutads.info/ and http://optout.networkadvertising.org.  To help preserve the choices that you make in the DAA’s WebChoices page, you can install the DAA’s “Protect My Choices” extension that is available at http://www.aboutads.info/PMC.  

  • Mobile Application Opt-Out.  To opt out in mobile apps, you can adjust the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads).  You can also opt out for companies that participate in the Digital Advertising Alliance’s AppChoices tool by downloading it here and following the instructions in the app.  For more information about opting out on mobile devices, please see here.

 

Please note that the opt-outs described above will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices.  If you delete or reset your cookies or mobile advertising identifiers, change browsers (including upgrading certain browsers), or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again.  Our Service does not respond to Do Not Track signals at this time.

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Third-Party Links, Websites, and Apps

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The Services may contain links to websites or services of other third parties.  If you follow a link to any of these websites or services, please note that these websites (and any services that may be accessible through them) have their own privacy policies.  We are not responsible for the privacy practices of other websites or the information you share through such other websites. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites.  This Privacy Policy applies solely to information collected in connection with the Services.

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Data Security and Retention

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thelighthouse uses physical, technical, and administrative safeguards to protect your information against loss or unauthorized access, use, modification, or deletion.  However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information.  

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thelighthouse retains your information for as long as reasonably necessary for its legitimate business purposes, to provide the Services to you, to fulfill the purposes described in this Privacy Policy, or as required by law.

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Your Rights and Choices

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You may review your account information on the thelighthouse at any time by logging in and viewing your profile.  You may update your name, email address, password, company reference ID (as applicable), at any time through your profile.  Insiders can also review and update their profile photo, location, public and Insider profiles.  

  

You may unsubscribe from promotional communications from us by clicking the “Unsubscribe” link at the bottom of each message.  Please note, you will still receive administrative messages related to your account from us. 

If you would like to opt-out of interest-based advertising, please follow the instructions in the above section “Analytics and Interest-based Advertising.”

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You may have rights under applicable laws to request access to, correction of, deletion of, or restrictions on the processing of certain information.  You may also have rights under applicable laws to opt out of or withdraw consent to further processing, request copies of your personal data, or lodge a complaint with a data protection authority in your jurisdiction.  To make such request and/or inquire about such rights, please send us an email at yourfriends@thelighthouse.us.  For your protection, we may only implement requests related to information that we have associated with the email address used to send us your request, and we may need to verify your identity before implementing your request. 

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Information for Individuals Outside the United States

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The information that we collect through or in connection with our Services is controlled by thelighthouse, which is headquartered in the United States at the address listed in the “Contacting Us” section below.  The data that we collect through or in connection with our Services is transferred to and processed in the United States for the purposes described above. thelighthouse also may subcontract the processing of your data to, or otherwise share your data with, third parties in the United States or other countries outside your country of residence.  The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By visiting or using the Services, clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to thelighthouse, you expressly consent to such transfer and processing.

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Children’s Privacy

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The Services are not intended for nor directed to individuals under the age of 18.  We request that such individuals do not provide information to us through the Services. 

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Changes to This Privacy Policy  

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We may revise this Privacy Policy periodically in the future.  If we make any material changes, we will post the revised Privacy Policy on our website with an effective date indicating when the revised Privacy Policy will take effect.  Your continued use of our Services will serve as an acceptance of any changes to the Policy. We encourage you to review this Privacy Policy periodically.

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Contacting Us

If you have any questions or comments regarding our Privacy Policy, please email us at yourfriends@thelighthouse.us or contact us at: 81 Prospect Street, Brooklyn, New York 11201.

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