Penn West Equity and Innovation District Privacy Policy

Last Updated: March 2023

Introduction

The Penn West Equity and Innovation District (“Penn West”, “we”, “us”, or “our”), under the purview of the Golden Triangle Business Improvement District, is an inclusive, collaborative, innovation hub for big ideas and groundbreaking technology. Located in the nation’s capital, Penn West is dedicated to solving for a more sustainable, equitable and vibrant future for everyone.

We respect your personal privacy and understand that you are aware of and care about your own personal information. This Privacy Policy (“Privacy Policy” or “Policy”) describes the Penn West policies and practices regarding its collection, uses, and/or disclosure of your personal data, and sets forth your privacy rights and choices. This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage.

How We Collect Information

We mainly collect your personal information through your use of our website https://pennwestinnovation.com/) (“Site”) both directly from you or indirectly through your use of the website. On occasion, we may collect your information from your attendance at one of our events or through a third-party, who is affiliated with the programs and/or services that we offer.

Additionally, we may obtain your personal information from other third-party sources and social media platforms that you may use to engage with us as well as from our affiliates, partners or third parties, including, but not limited to public databases, for the purposes provided below, and/or to supplement information we already possess.

By using our website or by attending our events and/or programs (collectively, the “Services”), you agree to the terms of this Privacy Policy. Moreover, if you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Policy.

Types of Information We Collect

The Penn West website collects personal information that you manually provide us, including but not limited to, when you register with us, fill out surveys, fill out other forms, or otherwise provide information via our Services or interact with our Services as outlined on the Site. The categories of information that we may collect directly from you include the following:

• Contact information, such as your name, mailing address, e-mail address, phone number, and business interests (if any), which may include signing up for some of our communications; and
• Communications between you and us, such as via e-mail, web form, mail, phone, or other channels.

In addition, as is true of most websites, the Penn West website collects certain information automatically that is associated with your use of the website. Cookies are a commonly used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We and our service providers may use such technology to collect information about your use of the Services by such automated means, including but not limited to cookies, pixels and other similar technologies. There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org.

These technologies may help us automatically identify you when you return to our Services. Cookies help us review website traffic patterns, improve the Services, and determine what Services are popular.

When you use the Services, the information that we may collect by automated means includes, for example:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, and referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, and mobile network information); and
• Location Information where you choose to provide the Services access to your device’s location information.

If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features that our Services provide. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

Finally, we may combine information about you that we have with information we obtain from your participation in our events or through third-party partners or affiliates. The personal information collected through these means is similar to the above described information.

How We Use Information We Collect

We use the information collected to enhance the user’s experience with our Services. Respectfully, we use this information for purposes permissible under applicable laws, including, but not limited to:

• To contact you for marketing and promotional purposes by various means, including email, text and phone;
• To pre-fill or pre-populate offer forms on the Site;
• Provide our Services to you and respond to your inquiries and other communications;
• Tailor the content that we display to you in our Services and communications, and offer products and information that we believe may be of interest to you;
• To enhance and validate the data we have in our database;
• Operate, evaluate, and improve our Services, including to diagnose or fix technology problems;
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns, as well as analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Provide you with notices and updates concerning our Services; and
• Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights.

We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing and advertising, as well as improvement of our Services.

How We Share Your Information

We do not sell personal information to anyone and only share it with third parties who facilitate the delivery of Penn West services. As such, your personal information will not be shared without your consent, except in the following circumstances:

• We may share your information as permitted by law, including, but not limited to, with our corporate affiliates and/or service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, maintenance and hosting of our Services, marketing partners, and other service providers). We only provide such vendors with information so that they can perform their required functions on our behalf.
• We may also disclose information about you: (i) if we are required to do so by law or legal process; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users, or the public.
• We reserve the right to transfer the information that we maintain in the event that we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

Where appropriate, we will limit sharing of your information in accordance with the choices that you have provided us and applicable law.

Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative alerts.
• Marketing Short Message Services (“SMS”): We may use personal information to provide the services you’ve requested, including services that may display customized content. In addition to any fee of which you are notified, your provider’s standard messaging rates apply to our confirmation and all subsequent SMS correspondence. You may opt-out and remove your SMS information by sending “STOP” to the SMS text message you have received. If you remove your SMS information from our database, it will no longer be used by us for secondary purposes, disclosed to third parties, or used by us or third parties (such as a vendor) to send promotional correspondence to you.
• Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.

Links to Other Websites and Third-Party Content

Our Services may contain links to other websites or apps, including social media integrations and/or services offered by third-party vendors. Please be aware that we are not responsible for the content or privacy practices of other websites or apps. Our Privacy Policy does not extend beyond our own website even if you accessed that website through a link from our website. If you are concerned about your personal privacy, you should consult the privacy policies of other websites to assess their treatment of personal information.

How We Protect Information

We endeavor to maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information that we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information that you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

How We Retain Your Personal Information

Your information is stored by Penn West on its servers, which are located in the United States. We retain personal information regarding you or your use of the Services for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for purposes that include, but are not limited, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements, or to protect our and others’ interests.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period for which we keep a support message is based on how long has passed since the last submission in the thread.

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

Children

We do not knowingly collect personal data from children under the age of 13 on our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us. We endeavor to delete personal information from our systems in the event that we learn that we collected it from a child under the age of 13.

International Data Transfers and Use

Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Any information that you provide through use of the Services may be stored and processed, transferred between, and accessed from, the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information, potentially including sensitive data, by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.

Updates to Our Privacy Policy

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. We will post an updated version of our Privacy Policy as it is updated.

We will indicate on our Privacy Policy when it was most recently updated. Your continued use of our Services after such updates will constitute your: (i) acknowledgment of such updates; and (ii) agreement to abide and be bound by the updated Privacy Policy.

Contacting Us

If you have any questions, concerns, comments, or would like to exercise your rights above, regarding this Privacy Policy, please contact us via e-mail at info@pennwestinnovation.com.