Privacy Policy

Updated 01 June 2020.

Welcome to Central Texas Entrepreneur Network, including but not limited to TEN Capital Network Program, Wilco Funding Portal, and Investor Connect, heretofore to be referred to as “TEN”. Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Service, and your choices about the collection and use of your information. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service. If you do not agree with this Privacy Policy in general or any part of it, you should not use our online services or resources.

1. Information we collect and its use

We collect the following types of information about you:

(a) Information you provide us directly

We may ask for certain information such as your first and last names, phone number, profession and e-mail address when you sign up for any TEN program, or if you correspond with us. We also collect any correspondence you send us through the written communication. We use this information to operate, maintain, and provide the features and functionality of TEN’s service to you, to correspond with you, and to address any issues you raise about TEN.

(b) Information we collect from you automatically

We will directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for TEN. These tools collect information sent by your browser or mobile device, including the pages you visit and other information (in respect of which, please see the paragraph on log file information below) that assists us in improving TEN.

(c) Log file information

Log file information is automatically reported by your browser or mobile device each time you access TEN. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on TEN, domain names, landing pages, pages viewed, and other such information.

(d) Clear gifs/web beacons information

When you use TEN, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online or email usage patterns of our Network. In addition, we may also use clear GIFs in HTML-based emails sent to our Network to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of TEN.

(e) Location data

Location data may be collected and will convey to us information about how you browse and use TEN and enable us to offer you localized content.

2. How we use your information

We use the information we collect about you for the purposes set out above which we have described in more detail below:

Providing you with TEN’s products and services: We use the information that you provide us to provide TEN products and services to you. This includes allowing you access to TEN programs and resources, operating and maintaining TEN, and billing you for TEN subscriptions.

For data analytics: We use information about you to help us improve the TEN Service and our Network’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.

Customizing TEN for you: We use information you provide us and information about you to make sure that your use of TEN is customized to your needs.

To communicate with you about TEN: We use your contact information to get in touch with you and to send communications about critical elements of TEN.

To promote and drive engagement with the TEN Service: We use your contact information to get in touch with you about features and offers relating to TEN that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant information based on your use of TEN, and your preferences. You can opt-out of getting these communications as described below.

Customer happiness: We use information about you, information that you provide to our Client and Investor Engagement team, and information about your interactions with TEN to resolve any and all issues you experience with TEN, and to ensure that we can repair and improve TEN for all TEN Network.

For security measures: We use information about you to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations or this Privacy Policy or our Terms of Service.

For matters that you must specifically consent to: From time to time TEN may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.

For matters that we are required to use your information by law: TEN will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of TEN, our Network or others.

Legal bases for processing information under the GDPR (for Network in the EEA)

For the TEN Network in the European Economic Area (EEA) TEN processes your information in accordance with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how TEN may process your information, and the rights that EEA Network have in relation to it.

This means that TEN will collect and use your information only where:

We need it to provide you TEN and fulfill our obligations to you under our Terms of Service. This includes providing you with access to the information that you provide to and store within designated TEN tools.

It is in our legitimate interests to provide a useful Service, to enhance our Service via research and development (but only where our legitimate interest isn’t overridden by your interest in protecting your data).

You consent to us using your information in a certain way. It is necessary for compliance with our legal obligations.

If you have consented to our use of your information you can withdraw that consent at any time. Depending on the situation you can either withdraw your consent by emailing [email protected] Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so it may mean that it is not possible for you to continue using TEN and all affiliated resources.

3. Sharing your information

We will not rent or sell your information to third parties outside TEN and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted in this section:

(a) Who we share your information with

We share your information with third-party service providers for the purpose of providing TEN to you and to facilitate TEN’s legitimate interests in providing a service which is useful to you. Those service providers will only be provided with access to your information as is reasonably necessary for the purpose that TEN has engaged TEN provider, and we will require that such third parties comply with this Privacy Policy, appropriate data processing terms and any applicable laws.

Some of the third parties that TEN may share your personal information with include providers who assist TEN with functions such as:

  • Billing;
  • Client and Investor support and management;
  • Email services;
  • Hosting and storage;
  • Analytics; and
  • Delivery of physical products.

(b) Who you can choose to share your User Content with

Any information or content that you voluntarily disclose for sharing with the TEN Network, such as becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by the Network. If you remove information that you provide to and store with TEN, copies remain viewable in cached and archived storage of TEN, or if other Network have copied or saved that information. By default all content you post on TEN is privileged to the TEN Network unless otherwise agreed upon.

You may share your TEN material to your social media accounts, including LinkedIn, Facebook, Twitter, Pinterest and Tumblr. You should ensure that you familiarise yourself with the privacy policies of each of these services and any privacy settings that may apply to the content you choose to share on those accounts.

(c) Sharing with other third parties

TEN will also share your information with third parties in certain circumstances, such as where:

  • we are required to do so as a result of a court order, subpoena or other legal requirements;
  • we believe that it is necessary to protect you or TEN, such as where we consider that there is a need to investigate potentially fraudulent or criminal activity;
  • you have consented to our sharing it with a third party for a particular purpose.

TEN will also share your information with a third party in circumstances where we sell, divest or transfer TEN (including any shares in TEN), or any combination of its products, services, assets and/or businesses to a third party. Information such as customer names and email addresses, User Content and other user information related to TEN may be among the items sold or otherwise transferred in these types of transactions. We will also sell, assign or otherwise transfer such information in the event of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations, similar transactions or proceedings involving all or a portion of TEN. You will be notified via email and/or a prominent notice on TEN if such a transaction takes place and be given notice of any material changes to the way we handle your data under this policy.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

4. How we transfer, store and protect your data

Your information collected through your interaction with TEN and all affiliated programs will be stored and processed in the United States in which TEN or its subsidiaries, affiliates or service providers operate. TEN transfers information that we collect about you, including personal information, to affiliated entities, and to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you as described in this Privacy Policy.

5. Cross-border transfers of information (for Network in the EEA)

For Network in the EEA, where we transfer your information to a third party provider that is not located in the EEA, and is not subject to an adequacy decision by the EU Commission, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information, including by using the EU Model Clauses.

6. Keeping your information safe

TEN cares about the security of your information, and uses appropriate safeguards to preserve the integrity and security of all information collected through TEN. To protect your privacy and security, we take reasonable steps before granting you access to your campaign tools and resources. You are responsible for controlling access to your email communications from TEN, at all times. However, TEN cannot ensure or warrant the security of any information you transmit to TEN or guarantee that information on TEN may not be accessed, disclosed, altered, or destroyed.

7. Compromise of information

In the event that any information under our control is compromised as a result of a breach of security, TEN will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. Your choices about your information

(a) You control your information

You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests.

You may not opt out of Service-related communications (e.g., campaign updates, billing confirmations and reminders, changes/updates to features of TEN, technical and security notices) although you can object to us providing these emails by emailing [email protected]

If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected]

(b) Opting out of collection of your information

Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents TEN or its affiliates from tracking your browser’s activities in relation to TEN, and for use in targeted advertising activities by TEN, including via third parties’ websites. However, doing so may disable many of the features available through TEN. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at [email protected]

(c) Rights in respect of your Information

The laws of some countries grant particular rights in respect of personal information. In certain circumstances, our network members in the EEA have the right to:

  • Request a copy of your information;
  • Request that we correct inaccuracies relating to your information;
  • Request that your information be deleted or that we restrict access to it;
  • Request a structured electronic version of your information; and
  • Object to our use of your information.

Should you wish to make a request in respect of your personal information please contact us at [email protected] You also have the right to object to our processing of personal data about you in order to send you marketing and we will stop processing data for that purpose.

In some circumstances TEN will not be able to comply with a request that you make in respect of your personal data. For example, we may not be able to provide a copy of your information where it infringes on the rights of another member of the TEN network. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared your information with third parties, such as by publishing an article or mailer copy on a third party’s website. In that case TEN will not be able to delete the information, and you will need to contact that third party directly.

If we are unable to resolve your request, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. Where you have provided your consent to certain processing and no longer want us to use your information for that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of processing based on consent before its withdrawal.

9. How long we keep your information

Following termination or deactivation of your subscription, TEN will retain your profile information and Client Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, TEN will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

10. Links to other websites and services

We are not responsible for the practices employed by websites or services linked to or from TEN, including the information or content contained therein. Please remember that when you use a link to go from TEN to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not exercise control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through TEN.

11. California Users’ Privacy Rights

Californian users of TEN have additional rights afforded to them under the California Consumer Privacy Act (CCPA).

Categories of personal information collected by TEN

For more details about the personal information TEN has collected in the past year, please see section 1 “Information we collect and its use”. For details on how we use that information, and who we share it with, please see section 2 “How we use your information” and section 3 “Sharing your information”.

TEN does not “sell” (as defined in the CCPA) the personal information of TEN Network.

Making a request in relation to your personal information

The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):

  • Request to access the personal information TEN has about you; and
  • Request that TEN delete all of your personal information.

California consumers may make a request by contacting us at [email protected] We will authenticate your request using the email address associated with your TEN account and if necessary, proof of residency.

12. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you by prominently posting notice of the changes on our website and/or sending an email to the email address associated with your TEN account. We recommend that you check this page from time to time to inform yourself of any changes.

13. How to contact us

If you have any questions about this Privacy Policy or TEN, or wish to make a complaint please contact us via the following:

Email: [email protected]
Phone: 1-833-TNCAPTL

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