Effective Date: April 2, 2011
By using the Gust platform, you agree to be bound by the terms described in this Privacy Policy.
The Gust platform is a set of tools for investors and entrepreneurs. It is also a portal where entrepreneurs and investors may exchange information. Gust licenses the Gust Platform to investor groups for the management of the investments of their members.
This Privacy Policy applies only to your relationship with Gust. It does not apply to the interactions that you have with any other individual, investor group, or other group through the Gust platform. For example, the administrator of an investor group has the ability to disclose or share with other members of the investor group any information that you submit to the Gust platform. Gust has no control over this disclosure or sharing, and is not responsible for it. The protection of your personal data when you interact with an investor group through the Gust platform is governed solely by any agreements that you may have with that group and is beyond the scope of this Privacy Policy.
This Privacy Policy is a part of the Terms of Service for the Gust platform. The terms 'Gust,' 'Gust Platform,' 'Gust Services' and 'Gust' Website have the same meaning as set forth in the Gust Terms of Service
" Personal data " is any data that (1) is recorded in any form, (2) is about or pertains to a specific individual and (3) can be linked to that individual. For example, your name, contact information, and the deals in which you have participated are " personal data. "
Personal data does not include website data , aggregated data , or uploaded documents.
We collect personal data at different stages of your use of the Gust site.
If you provide any information about a third party (such as a person's name or photograph), you must make sure that you have the right to do so. By providing the personal data of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from this individual to enable us to collect, use and disclose his or her personal data as set forth in this Privacy Policy.
We collect personal data directly from you when you provide it through your use of the Gust platform, such as in emails or when you fill out forms that are displayed on our website.
We also use cookies that are sent to your computer, or action tags that are placed on our website. For additional explanation on cookies and action tags, see Cookies and Action Tags.
Gust uses your personal data to maintain your account and to provide you with the angel group and deal-flow management services that serve as the core of the Gust platform. We also use your personal data to respond to requests that you make of us, and to contact you and to provide you with information that we believe may be of interest to you.
We may also use your name and contact information to make queries against social networking sites, such as LinkedIn, to show you how you are linked or connected to other individuals who are also Gust users.
Under certain business or legal conditions, Gust may have to disclose your personal data to others as follows:
All registered users of the Gust website can have access to the personal data that Gust holds about them and is listed in their profiles. They can correct, amend, or delete this data at their convenience and on their own time.
For auditing and security purposes, Gust keeps a log of all users' activities, which is retained in its archives as necessary for Gust to fulfill its obligations. Users may be able to have access to the personal data that pertain to them. However, the administrative and technical burden associated with the retrieval of these archived data is substantial. Gust would need to be compensated for this effort in a manner that is consistent with its actual cost. In addition, each user's right of access may be limited to the extent that providing access might infringe on a third party's privacy rights. Requests for access to this archived information are handled on a case-by-case basis, after Gust has verified the identity of the requestor. Inquiries should be made as provided in the section Contacting Gust.
You can delete any personal data that is recorded in the profile that you create for yourself as an investor or for your company, or as an entrepreneur (or student entrepreneur).
You can request the administrator of your Angel Group to delete any messages that contain personal data and your request will be handled by your Angel Group according to its policies.
Data aggregation is a process in which information is gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. Data used for aggregation purposes are collected in a form that removes all identifiers, and may be combined with other data for which all identifiers have also been removed. Gust uses aggregated data to generate accurate metrics about the early stage private equity industry.
Aggregated data are packaged and licensed to third parties such as governments, economic development agencies, and financial institutions. Examples of aggregated data may include:
Website data is aggregated data about the overall traffic to, and usage of our website. Examples include the number of visitors to the gust.com web site and the number of registered users of the Gust platform. Gust may extract and use website data for internal purposes, in order to analyze the performance of its website and applications. For example, we may use these data for traffic analysis and business decision making, in order to determine how we can improve our site or its functionalities.
The statistics generated in this manner contain no personal data and cannot be used to gather any information about individual visitors to the site.
Gust uses physical, technical, and administrative procedures in order to safeguard and protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, while we do our best to implement reasonable security measures, we do not guarantee that our safeguards will always work.
Gust uses industry-standard technological means to protect your personal data while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, please remember that no security system on the Internet is 'perfect'.
Documents that are uploaded to the Gust platform for sharing are stored at a third-party data-storage service. All uploads and downloads are transmitted through the Internet between users and the data storage service using the same encryption techniques as those that are used with personal data. However, Uploaded Documents are neither stored redundantly, nor backed up. Therefore, we recommend that Gust users keep back-up copies of their documents if they upload them to the gust.com website.
Gust will communicate with you in response to your requests for service or customer support. We will contact you by phone or by email, according to your preference.
Gust will send you service-related emails if it becomes necessary to do so. Gust may also send you an email in order to notify you of new products, services or features, or updates to our Privacy Policy, Terms of Service, or other agreement that you have with Gust.
Gust may provide links to other websites. We are not responsible for the privacy practices or content of these sites. In order to safeguard your privacy, please review the privacy policies of any sites that you may visit before providing any personal data to these third party sites.
Gust exercises reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. Gust will not be liable for unauthorized disclosure of personal data that occurs through no fault of Gust including, but not limited to, errors in transmission, access to your account by anyone uses your user ID and password, your failure to comply with your security obligations, and the unauthorized acts of Gust's employees.
Gust does not provide products or services for individuals under the age of 18. We do not intentionally collect nor maintain information from users actually known to be under the age of 18, and we will not use that information if we learn that it has been provided by someone under 18.
If at any time Gust wishes to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, Gust will give you the opportunity to choose (opt out) whether your personal data (1) may be disclosed to a third party and (2) may be used for a purpose other than the purposes that are set forth in this Privacy Policy.
From time to time, Gust may update this Privacy Policy in order to reflect changes in its practices. Whenever such changes are made, Gust will post an updated Privacy Policy on its website, and may email registered users.
All changes will apply to the personal data that are already collected, and to personal data that are collected after the effective date of the revised Privacy Policy.
If any proposed change is unacceptable to you, you will have the right to terminate your account.
If we decide to change this Privacy Policy in a material way, we will obtain the necessary consents required under applicable laws if we seek to collect, use or,disclose personal data for purposes other than those for which consent has been obtained, unless this change is otherwise required or permitted by law.
If you have any concerns or claims with respect to our Privacy Policy, please contact us as indicated in Contacting Gust. We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of personal data.
If the complaint or dispute cannot be resolved through our internal process, and Gust does not adequately respond to your question, please contact the New York office of the American Arbitration Association, which will serve as a liaison with Gust to resolve your concerns.
If arbitration is necessary, it will be conducted by telephone and email, and if it must be done in person, it will be conducted in New York, NY. The arbitration will be conducted by one arbitrator member of the American Arbitration Association, and under the rules of commercial arbitration of the American Arbitration Association. Both parties will bear equally the cost of arbitration (exclusive of legal fees and expenses). All decisions of the arbitrator(s) will be final and binding on both parties and enforceable in any court of competent jurisdiction.
Gust LLC owns and operates the gust.com web site and the Gust service platform. Our mailing address is 158 West 29th Street, New York, NY 10001 USA.
If you have any questions about this Privacy Policy, or believe that its terms have not been complied with, please email Gust at: support@gust.com.
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