Privacy
April 2017

Welcome to GreatNewCity, a service provided by GreatNewCity Limited (“GreatNewCity”, “we”, “our”, or “us”), Schipvaartstraat 14, bus 204, 3000 Leuven, Belgium, with company registration nr BE0500.772.396.

Your privacy is important to us. This Privacy Policy explains how we collect, store, use and disclosure your information when you use the GreatNewCity website, at the url www.greatnewcity.com and related urls (the “Website”), and all current and future services, software, tools, applications, data and the GreatNewCity API (the “Services”). The Website and the Services are referred to together in these Terms & Conditions as the “Platform".

By using the Website, the Apps or any of the Services, and in particular by registering a GreatNewCity® account, you are consenting to the use of your information in the manner set out in this Privacy Policy. The Cookies Policy forms part of the Privacy Policy, and whenever we refer to the Privacy Policy, we are referring to the Privacy Policy incorporating the Cookies Policy. Please take some time to read this Privacy Policy (including the Cookies Policy), and make sure you are happy with our use and disclosure of your information. If you do not agree to any of the provisions of this Privacy Policy, you should not use the Website, the Apps or any of the Services. If you have any questions or concerns, you can contact us at privacy AT greatnewcity DOT com. Please note that this Privacy Policy only applies to the Website, the Apps and the Services (together, the “Platform”). When using the Platform, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. GreatNewCity is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your GreatNewCity® account or sharing any personal data.

Our Principles

We have a pretty simple approach to data protection and privacy, which can be summarised as follows: You should know exactly what we do with your information This Privacy Policy is designed to give you full transparency regarding our data protection practices. If there’s anything that’s not clear from this Privacy Policy, please feel free to email us at privacy AT greatnewcity DOT com. You should have full control over your information We’ve designed the Website to give you control over the information you publish and share using GreatNewCity® and other sites and services to which you connect your GreatNewCity® account. Please take full advantage of these tools and make sure you only share what you want to share.

Information we collect about you

We collect information about you from various sources:

Information provided by you

You don’t need to provide us with any personal data in order to visit the Website. However, certain Services do require that you register for a GreatNewCity® account and, by doing so, you will provide us with certain information: • Essential information: When you register any kind of GreatNewCity® account, you will need to provide your email address, your name, and choose a password. In addition, if you purchase a Subscription, you will also need to provide your billing address and payment verification information. • Profile information: You may choose, at your discretion, to provide additional information for your public profile on GreatNewCity® – for example: • the city and country in which you live • a profile picture, profile header image or avatar • information about your passions / skills • details of your other websites and social media profiles, including links to those websites and profiles • None of this profile information is mandatory, and any information you do provide may be deleted, edited, changed or amended by you at any time. For more information, see the Choice and Control section below. • Information from correspondence: You will provide certain personal data if you contact us by email, use any of the webforms on the Website, or contact us by mail, fax or other offline means. • Survey information: If you participate in any survey, you will provide certain personal data as part of your response, unless you respond anonymously. • Information that you post: You may provide personal data when you upload content to the Platform, or when you post comments, or contribute to community discussions.

Information we collect automatically

There is certain information that we collect automatically as the result of your use of the Platform, or through the use of web analytics services as described in our Cookies Policy. This information includes but is not limited to: • the Internet Protocol (IP) address of the device from which you access the Platform (this can sometimes be used to derive the country or city from which you are accessing the Platform) • the site that you visited immediately prior to visiting the Website • the specific actions that you take on the Platform, including the pages that you visit, your favourite companies, interests and company size, connecting your Facebook, Twitter or LinkedIn account, sharing content with another user, following or unfollowing companies, posting a comment, or performing a search • any search terms that you may enter on the Website • the time, frequency and duration of your visits to the Platform • your browser type and operating system • the nature of the device from which you are accessing the Platform, for example, whether you are accessing the Platform from a personal computer or from a mobile device and its device-ID • your location data (e.g. GPS) when using GreatNewCity Apps, • information collected through cookies and similar technology, as described in our Cookies Policy • information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message

Information from other sources

Facebook / Twitter / LinkedIn Connect GreatNewCity allows you to sign up and log in using your Facebook / Twitter / LinkedIn account. If you sign up using Facebook / Twitter / LinkedIn, Facebook / Twitter / LinkedIn will ask your permission to share certain information from your Facebook / Twitter / LinkedIn account with GreatNewCity. This includes your first name, last name, email address in order for us to verify your identity and gender, general location, a link to your Facebook / Twitter / LinkedIn profile, your timezone, birthday, profile picture, your "likes" and your list of friends. This information is collected by Facebook / Twitter / LinkedIn and is provided to us under the terms of Facebook / Twitter / LinkedIn’s privacy policy. You can control the information that we receive from Facebook / Twitter / LinkedIn using the privacy settings in your Facebook / Twitter / LinkedIn account. If you sign up to GreatNewCity® using Facebook / Twitter / LinkedIn, your GreatNewCity® account will be connected automatically to your Facebook / Twitter / LinkedIn account, and information regarding your activity on GreatNewCity®, will be shared with Facebook / Twitter / LinkedIn and will be published in your timeline and your Facebook / Twitter / LinkedIn friends’ newsfeeds. If you do not wish to share your GreatNewCity® activity with your Facebook / Twitter / LinkedIn friends, you can control this from the Settings page on the Website – for more information, see the Choice and Control section below. If you signed up using Facebook / Twitter / LinkedIn by mistake, you can delete your account from the Account page within your Settings at any time, or you can email us at privacy AT greatnewcity DOT com.

How we use your information

We use the information that we collect about you for the following purposes:

Use of and interaction with the Platform:

• To operate and maintain your GreatNewCity® account, and to provide you with access to the Website and use of the Apps and any Services that you may request from time to time. Your email address and password are used to identify you when you log into the Platform. • To identify you as the creator of content that you upload, the comments that you post and/or the other contributions that you make to the Platform. • To seek your participation in surveys, and to conduct and analyse the results of those surveys if you choose to participate. • To provide you with technical support. • To respond to you about any comment or enquiry you have submitted. • To prevent or take action against activities that are, or may be, in breach of our Terms of Use, Community Guidelines or applicable law. • Any additional information that you provide as part of your public profile, such as your real name, and links to your website and other social media profiles (but not your email address), will be published on your profile page. This information will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services. Please bear this in mind when considering whether to provide any additional information about yourself. • If you purchase a Subscription, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment. All payment verification information is transmitted using industry-standard SSL (Secure Socket Layer) encryption. GreatNewCity also complies with the Payment Card Industry Security Standards. • Your email address will be used to send you service updates and notifications regarding your account, and (if you have elected to receive them using your account preferences) newsletters, marketing messages and certain email notifications. For information about how to change your preferences, and to unsubscribe from newsletters, marketing messages and email notifications, please see the Choice and Control section, below. • If you are a Facebook / Twitter / LinkedIn user, and one of your Facebook / Twitter / LinkedIn friends registers for a GreatNewCity® account, we may let your friends who already are on GreatNewCity know that you joined or will suggest to your Facebook / Twitter / LinkedIn friend that you might be someone they may wish to follow on GreatNewCity. • If you are a Facebook / Twitter / LinkedIn user and sign up using Facebook / Twitter / LinkedIn, we may also use the information we receive about you from Facebook / Twitter / LinkedIn to suggest or connect you to users that you may wish to follow on GreatNewCity®. It will be up to you if you choose to follow these users and you can unfollow them at any time.

Improving and customizing the Platform and advertising:

• To analyze the use of the Platform, and the people visiting the Website and using the Apps and Services, in order to improve GreatNewCity® and customize it to your needs and interests. • To show you ads on behalf of advertisers, we use information that you make available to us when you interact with the Platform, including location data, together with information you provide to us through the Platform, e.g. demographic information, you choose to make available to us (such as your age or gender) directly or through third party services. This allows us to show you ads that are more relevant and interesting to you. Please note that we do not share personal data with advertisers. Instead, advertisers pre-define a specific audience by certain generic criteria (e.g. the city of residence, the age range, or the number of followers of an unidentified user) for a specific ad campaign. If your profile matches these generic criteria, we may choose to display a suitable ad to you. We may also display ads based on the content that you have recently viewed or searched. Before we may use location data from the app for the first time, your mobile device will generally ask you for permission first. In case you gave permission to do so, location based services in your device will collect location data for a couple of seconds. These will then be shared with us or a respective service provider. • To customise your use of the Platform and/or the content of any email newsletter or other material that we may send to you from time to time.

For other purposes, provided we disclose this to you at the relevant time, and provided that you agree to the proposed use of your personal data.

Sharing of your information

We will not share your information with any third party, except as described in this Privacy Policy (including our Cookies Policy). There are circumstances where we may need to share some of the information we collect about you or which you provide to us - these circumstances are as follows: • Other users: Any information in your public profile will be accessible by other users of the Platform, who may view your profile information, consume and comment on your content, add themselves to your list of followers, and send you messages. • With your consent: We will disclose your information if you have explicitly agreed that we may do so. We will make this clear to you at the point at which we collect your information. • Service providers: We use certain reputable third parties, some of whom may be located outside of the European Economic Area, to provide us with certain specialised services related to the Platform. These third parties will have access to certain information about you, but only where this is necessary in order for those third parties to provide their services to us. Where we transfer personal data to these third parties, we ask and require these third parties to implement appropriate organisational and technical security measures to protect against unauthorised disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. • Users of our API: GreatNewCity has an open API, which enables application developers to integrate elements of the Platform into exciting new apps. Some of these developers may be located outside of the European Economic Area. Any information that you choose to make public on the Platform, including your public profile information and any public sounds, may be accessible to these developers. Please bear this in mind when deciding what information to publish on your profile. For information on how to limit the information that is available over the API, please see the Choice and Control section below. • Other networks and connected apps: If you choose to connect your GreatNewCity® account to other apps or social networks such as Facebook, LinkedIn, Pinterest, Google+, Tumblr or Twitter, you will be sharing certain information with these apps or networks. In the case of Facebook, LinkedIn, Pinterest, Google+, Tumblr or Twitter, any new public content that you post on GreatNewCity® or any new favourites will be shared to those networks and will be visible to your followers and friends on those networks. In the case of connected apps, you will need to provide the app developer with full access to your GreatNewCity® account in order to upload and download information, or comment on, favourite or repost content from within the app. This will mean sharing your public information, plus access to your private content. GreatNewCity is not responsible for these other apps or networks, so please make sure you only connect your account with apps or services that you trust. For information on how to control the information that your share, and how to disconnect your account from other networks or apps, please see the Choice and Control section below. • As aggregated data: We may aggregate your personal data with similar data relating to other users of the Platform in order to create statistical information regarding the Platform and its use, which we may then share with third parties or make publicly available. However, none of this information would include any email address or other contact information, or anything that could be used to identify you individually, either online or in real life. • If required by law: We will disclose your information if we believe in good faith that we are permitted or required to do so by law, including in response to a court order, subpoena or other legal demand or request. • To protect our interests: We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors or shareholders, and/or to ensure the safety and security of the Platform and/or the GreatNewCity® community. • In the context of a business transfer: We may transfer your information to any person or company that acquires all or substantially all of the assets or business of GreatNewCity, or on a merger of our business, or in the event of our insolvency.

Choice and control

We networks do our best to give you as much choice as possible regarding the amount of information you provide to us, and the control you have over that information. It is not necessary for you to provide us with any personal data in order to visit the Website, although certain information will be collected automatically by virtue of your visit (as described above). However, if you do decide to register a GreatNewCity® account, you can control your information in the personal settings section.

Access to your data

As described above, most of the personal data and other information you provide to us can be accessed and updated in the Settings page of your GreatNewCity® account. If you wish to access, amend or delete any other personal data we hold about you, or if you have any objection to the processing of any personal data that we hold about you, please contact us at privacy AT greatnewcity DOT com. If you ask us to delete your account (either via the Settings page or by email), we will do so within a reasonable period of time, but we may need to retain some of your personal data in order to satisfy our legal obligations, or where we have a legitimate reason for doing so.

International data transfers

GreatNewCity is based in Europe, and your personal information is collected, stored, used and shared in accordance with European laws. However, from time to time, it may be necessary for us to transfer your personal data to the United States. You should be aware that privacy laws in the United States may not be equivalent to the laws in your country, and by using the Platform, you consent to the transfer, storage and processing of your personal data in the United States in accordance with this Privacy Policy and applicable law.

Children

GreatNewCity® is not intended for use by children. Anyone under the age of 16 is not permitted to use the Platform and must not attempt to register an account or submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 16 or allow them to register an account. If it comes to our attention that we have collected personal data from a person under the age of 16, we will delete this information as quickly as possible. If you have reason to believe that we may have collected any such personal data, please notify us immediately at privacy AT greatnewcity DOT com.

Changes and updates to this Privacy Policy

We may occasionally update this Privacy Policy, and when we do so, we will also revise the Effective Date set out below. Any changes to our Privacy Policy will always be available here so that GreatNewCity® users are always aware of what information we gather, and how we might use and share that information. Please be sure to check back here from time to time to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account and/or by posting a notice of the change on the Website.

How we use cookies

A cookie is a small file which may be placed on your computer's hard drive. Once the file is added the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We also use cookies to identify you as a valid user and to help personalise your GreatNewCity experience in conjunction with your profile. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log onto our Website. Please note, our advertisers may also use cookies over which we have no control. We use Google's remarketing features to improve your experience of online advertising. This means that third-party vendors, including Google, can use cookies to serve ads based on your past visits to GreatNewCity. This increases the relevancy of ads which you see as you browse other pages on the Internet. You can opt out of a given third-party vendor's use of cookies by visiting the Network Advertising Initiative website here.

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Paid subscriptions

Subscription fee amount: A subscription fee for use of Pro/Premium services is payable monthly. The subscription rates are posted on our website and we may vary these from time to time: please see our Pricing Page for the rates in force for the current month. If you change your subscription package in the future, the change in the subscription payment amount will take effect at the next billing cycle.

Non-payment: We shall be under no obligation to provide The Service if the subscription fee is not paid to us on time. The Account Holder must ensure that we have complete and accurate billing and contact information throughout the subscription period, including the full name of the Account Holder, its business address, and a billing contact email address. If subscription fees become overdue, because for example the Account Holder's credit card has expired, we reserve the right to suspend your access to The Service until the balance is paid and we may close the Account Holder's account permanently.

Fees for multiple accounts: If you would like to use The Service to manage more than one account, you will need to sign up for multiple accounts and pay the subscription fee charged by us for each additional account.

Cancellation: You may cancel your subscription at any time, for any reason. Upon cancellation you will continue to receive the subscription benefits until the end of the current billing cycle, and no future payments will be taken.

Cancellation by you: You can cancel your subscription at any time by accessing The Service and using the "Cancel" option on the "Account Settings" page. No further subscription fees will be billed and no refund will be made of any subscription fees already billed and paid.

Suspension and closure by us: If you (or any other user of the account) fails to abide by these Terms of Service, or if payment of the subscription fees is not paid on time, we reserve the right to suspend your access to The Service or permanently cancel the account. If we withdraw access to The Service because these Terms of Service have been breached, no refund will be payable by us. We also reserve the right to close any account (including during any 'free trial' or 'beta trial' period) for any reason, by giving one months notice. Our VAT number is: BE0500.772.396