Privacy Policy

Effective Date: March 1, 2024

This Privacy Policy describes how Sylva, Inc. (“Sylva,” “we,” “us,” “our”) collects, uses, and otherwise processes Personal Data of individuals in connection with such individuals accessing our online properties (including the websites where this Privacy Policy is posted (our “Properties”)) and associated content and services (collectively, the “Services”).

“Personal Data” (or “Data”) means information relating to an identified or identifiable individual. Your Personal Data may identify you directly (e.g.name, address, telephone number, email address) or indirectly when combined with other information linked or linkable to you (e.g. IP Address & Device Identified Information).

Your use of the Properties and Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

1. APPLICABILITY SCOPE AND LIMITATIONS

The applicability of this Privacy Policy to our processing of your Personal Data is dependent on various factors, including your relationship with us and the context of our interaction. Circumstances there this Privacy Policy does not apply or applies in part are:

1. Employment Candidates. If you access our careers portal, this Privacy Policy is supplemented by the Sylva Global Candidate Privacy Notice.
2. Third Party Websites/Services/Platforms. This Privacy Policy does not apply to the other websites, including social media sites and Third-Party Services you access and use, including those you may access from the Services. Your information is subject to the privacy policies of such other websites.
3. Business Customer End Users. Sylva provides certain services (“Business Services”) to business entities (“Sylva Customers”). In connection with our provision of these services, Sylva Customers provide us with Personal Data related to their end users (such end users, hereinafter “Customer End Users” and Personal Data related to them, hereinafter “Customer End User Data”). In these circumstances, the applicable Sylva Customer, not Sylva, chooses the type of Customer End User Data collected and submitted to Sylva for processing in connection with the applicable Sylva Business Services. Sylva processes Customer End User Data on behalf of Sylva Customers according to the agreements between us. Sylva Customers are responsible for complying with all data privacy laws applicable to their collection of Customer End User Data and the transfer to and processing of such by Sylva. If you are a Customer End User, processing of End User Data related to you is subject to the privacy policy and terms of use of the Sylva Customer. Sylva is not responsible for the privacy practices of Sylva Customers.

2. PERSONAL DATA COLLECTED

a. Data You Provide.

Depending on how you interact with our Services, you may provide us, our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) and/or our business clients, event/program operators, organizers or sponsors, and other business partners (“Business Partners”) with, and the Services may include hyperlinks to websites, locations, platforms, applications or services operated by such third parties (collectively, “Third-Party Services”) through/into which you may provide certain Data that may include:

• Personally Identifying Information (“PII”): information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline;
• Professional or Employment Information: information related to your work history, education history, certifications, licenses, patents, summary information, and any other job application or resume-related information;
• Personal Data that you otherwise provide us, such as when you contact us (e.g., for help);
• Content of Communications: data you enter into any ‘free text’ fields to contribute to chat forums or blogs or utilize 1:1 and/or group messaging services made available in connection with the Services (See Communication Platforms); and
• other Data related to your use of certain offerings on our Services (See User Generated Content, Events, and Social Features).

You can learn more about cookies and other tracking technologies and how to exercise your choices over the use of these in the section titled Cookies and Tracking Technologies below.

‍b. Data Collected Automatically.

We, our Service Providers, or Third-Party Services use common information-gathering tools such as cookies, web beacons, pixels, and other similar tracking technologies (collectively, “Trackers”) to automatically collect information as you navigate our respective online properties, your accounts with us, our advertisements and/or when you interact with emails sent by or on our behalf.

The Data collected via Trackers may include:

• Service Use: information about your use of the Services, which may include a history of the pages you viewed, content you searched for, functionality you used, and Third-Party Services you accessed.
• IP Address: a unique number known as an Internet protocol (IP) address. We may obtain your general (imprecise) geolocation, information related to your Internet Service Provider and information about privacy promoting systems you may be using (e.g., if you are on a VPN or using a proxy server) from your IP Address. IP Addresses are assigned and reassigned by Internet Service Providers and companies regularly.
• Device Identified Information (“DII”): data that is linked to a particular browser or device. DII may include but is not limited to, unique identifiers associated with browsers or devices, such as:

• Cookies: text files placed on a computer’s browser that can be used to recognize you as a website user or to provide personalized content.
• Mobile Advertising IDs or MAIDs: Apple assigns an “ID for Advertising” (IDFA) to each iOS device, and Google assigns an “Advertising ID” to all Android devices. These pseudonymous ID can be used to deliver ads and for advertising analytics in mobile applications.
• Statistical Identifiers: Statistical IDs are generated by using information about your computer or devise including operating system, user-agent string, IP Address, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device over time, including in environments where Cookies are not supported.

• Internet Log Data: In addition to your IP Address, this Data may include your Web request, IP address, browser type, browser language, configuration settings, operating system, Internet/mobile provider referring/exit pages and URLs, number of clicks/pages viewed, pseudonymous IDs such as Cookies, service-specific information such as Service Use, Event Data, and data relating to malfunctions or problems that may occur when you use our Services; and
• Event Data: data related to ads you see (advertiser ID, campaign ID), where and when you see the ad (date/time stamp, URL), and how you react to the ads you see (click, hover, convert, etc.). This data may be associated with pseudonymous IDs such as DII and other pseudonymous data such as Internet Log Data.

‍c. Third Party Sources.

We may obtain Personal Data from third parties, including our Business Partners, Service Providers, and Third-Party Services, as follows:

Data Inferences & Insights generated

• Data Providers. We may obtain Personal Data from reputable third-party providers of licensed data derived from public and non-public sources to correct or supplement Personal Data we collect.
• Business Partners. If access to any Services is obtained for you by a third-party organization (e.g., your employer or representative trade organization), such third-party may provide us with your Personal Data pursuant to the agreement between us. If you participate in a professional or social event sponsored by or otherwise contributed to by Sylva, the event operator/organizer may provide us with your Personal Data pursuant to the agreement between us. 
• Service Providers. Our Service Providers, such as third parties who conduct marketing/advertising and analytics activities may share with us some or all of the Personal Data they collect in the course of performing services to us. For example, we may engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on Third-Party Services. Some of these ads may be tailored to your interest based on your browsing, across time, of the Services and elsewhere on the Internet, which may include use of data from cross-device usage, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-Based Advertising”), which may include sending you an ad on a third-party service after you have left the Services (i.e., “retargeting”). Our advertisers’ and ad networks’ use of Trackers is governed by their own privacy policies.
• Third-Party Services. In connection with your use of the Services, you may provide Personal Data to Third-Party Services (see Data You Provide), and/or such Third-Party Services may use their own Trackers to independently collect Personal Data (See Data Collected Automatically) that is shared with us.some text
  • Communication Platforms: As part of the Services, we may make available certain third-party communication tools as Third-Party Services (“Communication Platforms”), which may include Slack.com, Zoom.com, and Circle.so, to facilitate your contributions to chat forums, blogs, webinars, and/or 1:1 and group messaging. Communication Platforms may serve both as a source of Data collection and as recipients of Data you submit as discussed below in Sharing of Personal Data.
  • Artificial Intelligence: We may use advanced AI technologies to enhance our Services and provide a more personalized experience, including generating and using Data Inferences & Insights as described below. We currently employ OpenAI’s ChatGPT Enterprise and its associated API for this purpose and in doing so, OpenAI may serve both as a party with whom we share Data and a source of . 
  • Social Networks: Sylva may maintain its own branded pages on various social networks. When you visit these branded social media pages, the provider of the social network and other Third-Party Services may set Trackers on your browser or device and provide us with the types of Personal Data identified in the section titled Data Collected Automatically above.

‍d. Data Inferences & Insights.

We may make inferences and derive insights regarding your preferences, characteristics, predispositions, behavior, attitudes, and aptitudes from other Personal Data we have collected, obtained from our Service Providers or Third-Party Services or that is available publicly. This may involve sharing your data with 3^rd party AI technology providers as described above (Artificial Intelligence) to improve and personalize our Services for you. Purposes for which we may use these inferences and insights include:

• Recommendation and creation of content based on your interests and interactions.
• Personalization of features that adapt our Services to better suit your individual interests and preferences, ensuring that the Services you receive are highly relevant and engaging.
• Adaptation of our user interfaces and the anticipatory nature of our service design, enhancing convenience and intuitiveness in your interactions with our Services. 
• Improve our visibility into key community touchpoints to improve community management, communication, and engagement.

In employing automated processes, including Artificial Intelligence, to process Personal Data for making inferences and generating insights, we acknowledge that such activities may be considered 'profiling' under specific data privacy laws. Profiling, as defined, could be subject to restrictions and may grant you rights to challenge or restrict this practice.

We commit to transparency in our use of such technologies and assure you that no profiling will be conducted for making decisions that have legal or similarly significant effects on you without your explicit consent or where not permitted by law. You may opt-out of our use of your Personal Data in connection with these activities by contacting us at privacy@withsylva.com.

‍e. Non-Personal Information & Information You Disclose Publicly or to Others.

We will treat information that does not personally identify you as non-personal information, and we may de-identify, anonymize, or otherwise convert your personal information to non-personal information. As permitted by applicable law, we reserve the right to use, process, share and otherwise exploit your non-personal information without limitation.

The Services may permit you to post or submit User Generated Content (“UGC”), including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Data. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and may be accessible by anyone, including Sylva. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Data included in UGC is not subject to our usage or sharing limitations or other obligations and may be used and shared by Sylva and third parties to the fullest extent not prohibited by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Terms of Use, click here.

3. OUR USE OF PERSONAL DATA

We may use Personal Data to:

• process your registration, manage your account (if applicable);
• deliver and improve our Services;
• fulfill our obligations pursuant to agreements with those Business Partners that have supplied Personal Data to us;
• fulfill other purposes disclosed to you at the time you provide us with your Data or otherwise where we are legally permitted to do so;
• personalize content and offers and serve you advertising that may be of interest to you;
• respond to your inquiries;
• provide you with updates and other information regarding the Services;
• keep our Services safe and secure and to prevent and detect fraud and abuse;
• evaluate candidate submissions for Sylva jobs;
• comply with our legal obligations, policies, and procedures;
• administer and manage our Services, including content and layout, website usage, troubleshooting, data analysis, testing, research, statistical and survey purposes; and
• improve our Properties to ensure that content is presented in the most effective manner for you and your computer, device, or other item of hardware through which you access our Properties.

4. SHARING OF PERSONAL DATA

We may share your information as follows:

• With our Service Providers in connection with their work on our behalf.
• If you register for, attend, or participate in any in-person, online, telephonic or virtual events operated by or on behalf of Sylva (e.g., webinars, meetings, workshops, training and social or networking events) (“Events”), we may share your Personal Data with event sponsors in circumstances where either you agreed to be contacted by the applicable sponsor(s) or where such sponsor(s) are otherwise permitted by local law to contact you for marketing purposes. Please refer to Event sponsors’ privacy policies for information on how to opt out of their communications.
• If access to any Services is obtained for you by a third-party organization (e.g., your employer or representative trade organization), we may share your Personal Data with such organization. The use of your Data by such organizations will be governed by their privacy policies.
• If you use of certain Services, such as participating in Events or registering to participate in a subgroup within a Property, we may disclose your identity as an Event or subgroup participant, as applicable. 
• With Third-Party Services including:
  • Communication Platforms: Where the Services permit interactions with third-party Communication Platforms to facilitate Member contributions to chat forums, blogs, webinars, and/or 1:1 and group messaging. The use of Communication Platforms is subject to the Terms and Privacy Policies of the respective platforms. Members are encouraged to review the Terms and Privacy Policies of a Communication Platform before utilizing it and to exercise caution when making decisions regarding what Personal Data they disclose through or upload to such platforms.
  • Artificial Intelligence (AI): When we enhance our Services and provide a more personalized experience, including generating and using Data Inferences & Insights as described above by employ OpenAI’s ChatGPT Enterprise and its associated API. It's important to note that OpenAI has committed to refrain from using ChatGPT Enterprise and API data, inputs, and outputs for training its models. You can review OpenAI’s Enterprise Privacy Commitment here. 
  • Social Features: Where the Services permit interactions initiated by you between the Services and certain third-party social networks (“Social Features”). Examples of Social Features include enabling you to send content such as contacts and photos between the Services and a Third-Party Services; “liking” or “sharing” Community content; logging into the Services using your Third-Party Services account (e.g., using Facebook Connect to sign-in to the Services); and to otherwise connect the Services to a Third-Party Services (e.g., to pull or push information to or from the Services). 

If you use Social Features, Communication Platforms, and potentially other Third-Party Services, information you post or provide access to, including the contents of your communications, may be publicly displayed on the Services (see Information You Disclose Publicly or to Others section above) or by the Third-Party Services that you use. Similarly, if you post information on a third-party service that references the Services (e.g., by using a hashtag associated with the Community or its affiliates in a tweet or status update), your post may be used on or in connection with the Services or otherwise by Sylva and its affiliates. Also, both Sylva and the third party may have access to certain information about you and your use of the Services and any Third-Party Services.

• with companies and websites under common ownership with Sylva;
• with our family of Sylva affiliates who may have content and offers of interest to you;
• With our trusted third-party advertising partners to serve you ads about our products or those of others;
• if we believe your actions are inconsistent with our terms of use or other applicable terms or policies, or to protect the rights, property, life, health, security and safety of Sylva, the Services, or its users, or any third party;
• in the event of a change of ownership as a result of a merger, acquisition, or any transaction involving the transfer of some or all of our assets by another company, your Services information may be transferred. We will provide you notice prior to any such transfer of your Personal Data;
• to comply with law, law enforcement, or other legal process, and, where permitted, in response to governmental requests or legal process (for example, a court order, search warrant, or subpoena); and
• to other circumstances in which we have a good faith belief that a crime has been or is being committed by a user.‍

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

a. Types of Trackers.

Trackers that collect the Personal Data identified above in the section titled Data Collected Automatically used by us and our Service Providers and Third-Party Services may include:

• Cookies: Text files that a website sends to your computer’s browser that can be used to recognize you as a website user or to provide personalized content.
• Pixel Tags / Web Beacons / Clear GIFs: Images (often transparent) placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and are often used in combination with Cookies.
• Flash Cookies or Locally Shared Objects (Flash LSOs): Messages used in Adobe Flash that are sent from a Web server to a Web browser and are then stored as a data file in the browser. Flash cookies behave like conventional cookies by personalizing the user’s experience, but they can hold much more data than conventional Cookies. Flash LSOs may stay installed on a drive after ordinary Cookies are deleted.

b. Your Tracking Choices.

• Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Trackers is subject to your browser settings and limitations.
• Many advertisers and service providers that perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such Interest-Based Advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-Based Advertising for DAA members, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.
• Please be aware that even if you are able to opt out of certain kinds of Interest-Based Advertising, you may continue to receive other types of ads. Opting out only means that those selected participating members should no longer deliver certain Interest-Based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device, or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.
• In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one or more of our databases (“Matched List Ads”). This is done by using Trackers, or by matching common factors between our databases and the databases of the third-party services. We are not responsible for these third-party services, including without limitation their security of the data. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions as they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
• Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit; such signals may prevent third parties from collecting information about your online activities over time and across different websites. California law requires us to disclose how the Services respond to these kinds of “Do Not Track” signals. Like many websites, the Services currently are not designed to respond to “Do Not Track” signals from visitors’ browsers. To learn more about “Do Not Track” you may wish to visit this site.

6. DATA RETENTION & SECURITY

Sylva will retain your Personal Data only for as long as necessary for the purposes it was retained, such as to enable you to use our Properties and provide the Services to you. In some instances, we may retain data for longer periods in order to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business. All Personal Data we retain will be subject to this Privacy Policy and our internal retention guidelines.

We take reasonable measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we cannot guarantee the security of Personal Data collected through the Services.

‍7. YOUR RIGHTS

a. Choices Concerning Analytics.

We may use Third-Party Services such as Google Analytics to help us analyze our performance and our delivery of services and advertising to you. For example, we may use Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager and Google Analytics Demographics and Interest Reporting.‍

• You may exercise your choices regarding the use of cookies by Google Analytics by using the Google Analytics Opt-out Browser Add-on or by going to https://tools.google.com/dlpage/gaoptout/ and following the instructions.
• We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. You may limit the use of these Cookies as provided in the Your Tracking Choices above.

‍b. Opting Out of Promotional Communications.

You can make choices about how your Data may be used by us to provide information and offers to you. You may opt out of commercial messages by clicking on the “opt out” or “unsubscribe” link provided with each message. These preferences do not apply to transactional communications, such as those that are related to your registration with us, required or important notices related to your use of our Services, or the fulfillment of a specific transaction.

‍c. Accessing and Changing Information.

We may provide web page(s) or other mechanisms or processes allowing you to delete, correct, or update some of the Personal Data that we collect from you, and potentially certain other information about you (e.g., profile and account information). We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data: (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

d. Region Specific Rights.

Your personal information may be stored in, transferred to, and processed in the United States and in any other country in which we, and/or Service Providers and Third-Party Services maintain facilities. The data protection laws in these countries may provide a different standard of protection for Personal Data than the country in which you are located or your country of residence.

We may choose or be required by law to provide different or additional disclosures about our data privacy practices depending on your state or country of residence:

• European Economic Area or United Kingdom: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) please see the 'European Privacy Notice' section for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, and your rights in respect of your personal data.
• California: If you are a California resident, please see the 'California Privacy Notice' section below.

‍8. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to change at our discretion. We will indicate changes, including material changes, to the Privacy Policy by updating the “Effective Date” at the top of this page. Your continued use of the Services and our Properties after any update to this Privacy Policy will constitute your acceptance of the changes.

9. HOW TO CONTACT US

Please direct comments or questions regarding this Privacy Policy via email to privacy@withsylva.com.