Propeller Industries
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Privacy Policy

Table of Contents

Introduction

Propeller Industries, LLC (“Company”) is a Delaware Limited Liability Company with its principal place of business located at 110 William Street, Suite 2200, New York, NY 10038 (United States). This statement (“Privacy Statement”) sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from individuals located within the European Union and the United Kingdom (together, for purposes of this Privacy Statement, the “EU”), the European Economic Area (“EEA”) and Switzerland, as well as from individuals located in the United States and elsewhere in the world. It is the Company’s policy to respect, and protect, personally identifiable information obtained from individuals as set forth in this Privacy Statement.

There are certain provisions of this Privacy Statement that only apply to individuals from the EU or EEA. Those sections are denoted as “EU/EEA Data Subjects Only.”

There are certain provisions of this Privacy Statement that do NOT apply to individuals from the EU or EEA. Those sections are denoted as “Not Applicable to EU/EEA Data Subjects.”

1. What Is the Scope of this Statement?

This Privacy Statement sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States from individuals, including by and through our website located at https://propellerindustries.com/ (the “website”) and information you provide to us based upon information from our website (i.e., if you send us an e-mail at an e-mail address identified on the website). This statement covers information received in electronic or other formats.

2. Terms

The terms “we”, “us” and “our” refer to the Company, and its officers, directors, owners, employees and agents.

The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term personal data may include:

  • Names and contact information, including phone number, physical address, fax and e-mail;
  • Social security number or other national identification number;
  • Gender and nationality;
  • Date of birth;
  • IP address;
  • Title, position, business/company name; and
  • Any other similar information provided to us by you or your company in connection with our services.

The term “data controller” means the person or entity that decides the purposes for which, and the way in which, any personal data is processed.

The term “data processor” means the person or entity which processes personal data on behalf of the data controller.

The term “processing” means any operation or set of operations performed on personal data. Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.

3. What Information We Collect About You

We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.”

You agree that we may collect and process all such personal data that you provide to us, or that your employer and/or company in which you own an interest or for whom you work, and/or which retains us and provides to us with your consent, to enable us to provide the services (the “Services”) for which we were retained, as identified on the website, and as otherwise set forth in the agreement related to such Services. These Services may include:

  • Providing outsourced financial management or other related services, primarily for early-stage startups.
  • Any other services described at https://propellerindustries.com/.

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

  • Updating our records;
  • In connection with any application for employment with the Company;
  • Internal analysis for our business management purposes;
  • Any statutory or regulatory purpose which requires the processing of your personal data;
  • Legal and regulatory compliance;
  • Fraud and crime prevention;
  • Internal or external audits; and
  • Any other purpose for which valid consent is obtained.

In addition to the above, we may also collect other data from you that is not personal data, such as information about your employer, customers, business partners, vendors, contractors, subcontractors, freelancers and family members.

Please do not supply the following to us:

  • Any other person’s personal data, unless the Company explicitly asks you to do so;
  • Any categories of your personal data that have not been explicitly requested by the Company;
  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
  • Any confidential, proprietary, secret or legally protected information that is under any legal obligation to not provide to or share with the Company.

4. How We Collect Information About You

We collect information about you (including personal data) when:

  • You Give Us Information. You may provide us information when:
    • you set up an account with us; you provide it to us by filling out forms;
    • you send us e-mail or provide information via phone or in person;
    • you provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);
    • you provide us with documentation.
    • you provide us with information that may contain personal data;
    • you provide it to use through our “Contact” page on the website;
    • you provide us with information in connection with seeking employment with the Company.
  • We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
  • We Collect Information From Other Sources – We may also obtain information about you from outside sources, for example, commercially available information about you obtained from third-parties. We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Statement.

5. Use Of Cookies

About Cookies

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  • Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

Cookies That We Us

We use cookies for the following purposes related to the services we provide for and to you and our users:

  • authentication – we use cookies to identify users of the website and/or the location of individuals accessing the website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalization – we use cookies to store information about your preferences and to personalize the website for you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • analysis – we use cookies to help us to analyze the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies Used By Our Service Providers And Vendors

Managing Cookies

6. Server Logs

A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term into a search box located on the website, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

7. How We Use Your Personal Data

  • We process your personal data identified in this Privacy Statement to perform the Services as defined above. The legal basis for this processing is your consent set forth herein, as well as our contractual obligations.
  • We may process your personal data identified in this Privacy Statement where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • We may process your personal data identified in this Privacy Statement where necessary for the purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  • We may process your personal data identified in this Privacy Statement where such processing is necessary or advisable for compliance with a legal obligation to which we are subject (in the United States, the EEA, the EU, Switzerland or otherwise), or in order to protect your vital interests or the vital interests of another natural person.

8. Providing Your Personal Data To Others

  • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement, including to provide or potentially provide Services to you or for your benefit.
  • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.
  • We may disclose certain of your personal data to the suppliers and subcontractors pursuant to separate consent provided by you to us.
  • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.
  • In addition to the specific disclosures of personal data set out in this Section 9, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.

9. International Transfers Of Your Personal Data – For EU/EEA Data Subjects Only

  • In this Section 9, we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom) or Switzerland.
  • Propeller Industries, LLC, is a Delaware Limited Liability Company with its principal place of business located at 110 William Street, Suite 2200, New York, NY 10038 (United States). The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
  • By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.
  • By using our Services, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

10. Retaining And Deleting Personal Data

  • This Section 10 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • It is often not possible for us to specify in advance the periods for which your personal data will be retained as the purpose for which it was obtained and the requirements of retention may vary. Therefore, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards.
  • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

11. Amendments

  • We may update this Privacy Statement from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this Privacy Statement.
  • We may notify you of significant changes to this Privacy Statement by email or through the private messaging system on our website.

12. Your Rights – EU/EEA Data Subjects Only

  • In this Section 12, we have summarized the rights that EU/EEA data subjects have under applicable data protection law, including the GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  • Your principal rights under data protection law are:
    • the right to access;
    • the right to rectification;
    • the right to erasure;
    • the right to restrict processing;
    • the right to object to processing;
    • the right to data portability;
    • the right to complain to a supervisory authority; and
    • the right to withdraw consent under certain circumstances.
  • You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  • In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.
  • In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails.
  • You may exercise the same rights as individuals from California (United States) pursuant to Section 15 below by using the contact information instructions set forth in Section 15, or below in this Section.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at:

Propeller Industries, LLC
110 William Street, Suite 2200
New York, NY 10038 (United States)
Attention: Privacy Officer (privacy@propellerindustries.com)

With a copy (including the words “Propeller Industries – GDPR” in the subject line) to:
OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq.
(mfeldman@olenderfeldman.com)

13. Your Choices About Information We Collect – Not Applicable to EU/EEA Data Subjects

  • If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its services, or those services may not be as good as they otherwise could be.
  • If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails. If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

Propeller Industries, LLC
110 William Street, Suite 2200
New York, NY 10038 (United States)
Attention: Privacy Officer (privacy@propellerindustries.com)

With a copy (including the words “Propeller Industries – Privacy” in the subject line) to:
OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

14. Privacy of Children Who Visit The Website

We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use this website or our Services.

15. California Consumer Privacy Act of 2018 Rights

a. Marketing

We collect various types of personal data about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us to disclose the categories or personal data of yours which we have shared with third parties, for the third parties’ direct marketing purposes during the prior year. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.  However, we do not share your personal data with any third-parties for the third parties’ direct marketing purposes.

Notwithstanding the above, if you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below with the words “CALIFORNIA OPT-OUT” in ALL CAPS in the subject line or clearly set forth elsewhere. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form so you may request that your personal data not be disclosed to third parties for their direct marketing purposes or we will confirm to you that we do not share your personal data with any third-parties for the third parties’ direct marketing purposes as explained above.

E-mail Address:

privacy@propellerindustries.com

Attention: Privacy Officer

Postal Address:

Propeller Industries, LLC

110 William Street, Suite 2200

New York, NY 10038 (United States)

Attention: Privacy Officer

Phone:

888-552-5710


b. Consumer Rights Under the California Consumer Privacy Act of 2018 (the CCPA)

To the extent the California Consumer Privacy Act is applicable, with certain exceptions and, including in connection with data subject to federal regulation (i.e., the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach Bliley Act California (GLBA), the Fair Credit Reporting Act (FCRA), or the Drivers’ Privacy Protection Act (DPPA)), contractual rights and obligations, and certain other exceptions, California residents have the following rights with respect to our data collection and data processing of California residents’ personal data which is collected in California, processed in California, or part of a transaction occurring in California:

(1) The right to know whether your personal data was collected by us.

In large part, the personal data we collect is set forth above in this Privacy Policy.

(2) The right to request the categories and specific pieces of personal data that we have collected about you in the past 12 months, the categories of sources for which that information is collected, the business purposes for collecting or selling the information, and the categories of third parties with whom the information is shared.

The categories and specific pieces of personal data that we have collected about you in the past 12 months are set forth herein, including Section 2: Terms; Section 3: What Information We Collect About You; Section 5: Use Of Cookies; and Section 6: Service Logs.

Sections 7 and 8 above set forth the business purposes of collecting personal data.

Sections 7 and 8 identify the categories of third parties with whom we may share your personal data.

(3) The right to know what information we are collecting about you and the purposes for which it is being used.

In large part, the type of information we collect and the purpose for which it is collected is set forth above in this Privacy Policy.

(4) The right to not allow us to sell any of your personal information.

We do not sell any of your personal information.

(5) The right to have your personal information deleted, subject to certain exceptions.

These exceptions may include:

  1. Complete the transaction for which we collected the personal information, provide a service that you requested or which was legitimately requested on your behalf, take actions reasonably anticipated within the context of our ongoing business relationship with you or an entity with whom you work or provide services, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(6) The right to not be discriminated against for exercising any of the above rights.

We will not discriminate against you if you exercise any of the above rights.  However, as explained, some or all of our Services necessarily require us to process your personal information, and share your personal information with certain third parties in connection with providing the Services.  Therefore, and as explained above, exercise by you of certain of the above rights may impact our ability to provide the Services to you.

TO THE EXTENT APPLICABLE, AND TO EXERCISE ANY OF THE ABOVE RIGHTS, PLEASE CONTACT US AT ANY OF THE BELOW AND INCLUDE THE WORDS “CCPA RIGHTS” IN ALL CAPS IN THE SUBJECT LINE, OR BE CLEAR BY PHONE THAT YOU WANT TO EXERCISE YOUR CCPA RIGHTS and CLEARLY LET US KNOW WHAT RIGHTS YOU SEEK TO EXERCISE.

Website:

privacy@propellerindustries.com

Attention: Privacy Officer

Postal Address:

Propeller Industries, LLC

110 William Street, Suite 2200

New York, NY 10038 (United States)

Attention: Privacy Officer

Phone:

888-552-5710