OUR PRIVACY POLICY Last Updated: Jan 11, 2024

This privacy policy and our related Privacy Notices (see below) describe how we collect, use, protect and share information about you that we collect when you use any of our products and services, our websites, or apps or otherwise interact with us (Services).

HOW WE COLLECT INFORMATION FROM YOU

Information that you give to us

In the course of providing you access to the Network, as well as Products and Services, LowerSubs collects and receives personal information in a few ways, for example, when you set up a LowerSubs account or register for a product, newsletter or service., e.g. a demo or make comments on our site. Often, you can choose what information to provide, but sometimes we require personal information from you to carry out certain activities such as account verification or registration. This section details the ways in which we collect information from you and how that information is received.

Information we generate or collect automatically through your use of our services

We use cookies, which are small text files that collect and track certain technical information, and similar technologies to help us operate and provide our Services to you. This information includes:

• Information about the systems and device(s) you use to access our Services, including, IP address, browser type and version, time zone setting, operating system and platform, device type, and device identifiers;
• Information about your visits to the Websites, including the full URL clickstream to, through and from the Websites (including date and time);
• Information about your use of our mobile apps, including the information you view in our mobile apps and the date and time you view it;
• Information to facilitate your use of our Services (including to provide access to third-party websites and services), such as URL requests, destination IP addresses, or device configuration details; and
• Pages you view or search for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page.

More information on cookies can be found here.

Information we collect about you from third parties

Our Products and Services may also, from time to time, contain links to and from social media platforms. If you choose to connect with us through a social media platform, we may, through the social media platform connection, collect additional information from you, such as your user names, profile picture, contact information, contact list, and the profile pictures of your contacts. Similarly, the social media platforms may collect information about your interaction with our Products and Services. We do not have any control of the collection, use and sharing of your information when using any social media platforms. You should read any associated privacy policies before using them.

Information we collect from other sources, e.g.: information from third party providers, information that helps us to combat fraud or that relates to your social interactions (including your communications via social media, between individuals, organisations, prospects and other stakeholders acquired from companies that collect combined information);

We may combine the information we collect about you from the various sources described above.

WHY WE COLLECT YOUR INFORMATION (PURPOSES)

This section explains why we collect your information and what we need it for (purposes). This is set out below, by reference to what the information is required for.

We collect and process your personal information in order to offer the Network, and to offer you our Products and Services.

If you decline to provide us with personal information when we ask you, you may not be able to access all or some of our services and you may not be able to use the Network or certain Products and Services. For example, if you do not provide us with your email address or other information required for account registration, we will not be able to register you for certain account services.

Account registration information

We need to collect your personal information for account registration purposes. Although the Network provides for anonymous and pseudonymous participation, in some instances in order to use certain Products or Services, we require account registration. This requires a name associated with your account, an email address at which we can contact you, and in some cases, additional information including, a contact address, a billing address, and a password to help secure your personal information.

Profile information

When completing a public “profile”, whether it is for use with the Network or our Products and Services, we may require you to share certain personally identifying information in required and optional profile fields. The name associated with your account, which you may review and change in your account settings, as well as reputation points are publicly displayed and connected to your activity on the LowerSubs Network and via certain Products and Services such as our Talent and Teams platforms.

Other profile information may also be publicly displayed if you choose to complete certain elective components of the Account Registration options including, e.g., your Developer Story, display picture, affiliated role and company, your location and your preferred technologies (javascript, swift, sql-server, etc.), and some information is publicly displayed and required, such as how long you have been a member.

Similarly, you may elect to share additional information that is not required but this will be displayed publicly at your election.

Information we use to identify and authenticate you. We need this information to be able to recognize you, for example, when you access your accounts. It also helps us to protect your details and keep them secure.

Marketing and sales information, e.g. details of the services you receive and your preferences; information about your device or the software you use, e.g. its IP address, technical specification and uniquely identifying data; cookies and similar technologies we use to recognize you, remember your preferences and tailor the content we provide to you – our cookie policy contains more details about how we use cookies.

Device and browser information received automatically

When you visit the Network or use our Apps, LowerSubs automatically receives and records information from your browser or mobile device, such as your Internet Protocol (IP) address or unique device identifier. Cookies and data about which pages you visit on our Network allow us to operate and optimize the Products and Services we provide to you. This information is stored in secure logs and is collected automatically.

We may combine this browser information with other information we collect about you. This information is used to keep the Products and Services secure, to analyze and understand how our Products and Services are used, optimize such usage, provide advertising across the Network as well as certain Products and Services to personalize your experience, and to help connect you with potential job opportunities in the case of our recruiting Products and Services.

Location information

When you use the LowerSubs Network, and certain of our Products and Services, we collect location information about you including your IP address, your location, browser information, and how you came to the LowerSubs Network. This is the case for individuals who have registered for an account, and non-members who engage with the LowerSubs Network by visiting our website(s) but who have not completed an account registration.

This information is collected for various purposes, including advertising, analytics and to serve content as it relates to certain Products or Services (e.g., Talent), as well as to provide you with localized content, recommendations, and marketing. You may revoke our permission to collect some of this data, including your location and browser information through your Account Settings, but this may limit functionality in some cases. Certain location information we collect is required for security and site functionality. We share this information with certain third-parties (e.g., talent recruiters, payment processors, and advertising providers) in order to provide you with our Products and Services.

WHO WE SHARE YOUR INFORMATION WITH

We may share personal information with third parties who provide services to LowerSubs, such as payment processors, email delivery services, software providers, advertising providers and when we enter into product integrations with Software providers. Additionally, to improve user experience, we offer single sign-on solutions for account login and these third parties (including Facebook and Google) may receive information from these services when you elect to use them. When LowerSubs shares your personal information and other collected information with third party service providers, we require that they use your information only for the purpose of providing services to us and consistent with this privacy policy.

Advertising and marketing partners

When you register for an account, and when you interact with LowerSubs, e.g., when you use the Public Network, we and authorized third parties place cookies on you and your account activity as described in more detail within our cookie policy. We use this information to serve you certain advertising content. Similarly, we market our Products and Services to you and communicate important information, product and other opportunities to you. If you do not wish to receive direct marketing communications from us, you can tell us and remove yourself from our marketing communications via the unsubscribe and opt out options in our email communications and your Account Settings. For more information on how to control your account settings or to opt out of direct marketing campaigns, please visit your Profile Settings.

Analytics information

LowerSubs uses data analytics to ensure site functionality and to optimize our Product and Service offerings to you. We use web browser and mobile analytics to allow us to understand Network and Apps functionality. In doing so, we record information including, for example how often you visit the Network, how often you contribute content, Network and Apps performance data, errors and debugging information, and the type of activity you engage in while on the Network or in your use of our Products and Services. We may on occasion share this information with third parties for research or product and services optimization.

Billing information

For Products and Services requiring payment, we collect a billing name, phone number, and email address. We also collect a billing and shipping address for invoicing purposes. If you elect to pay by credit card, LowerSubs may engage a third party to securely process your payment. All payment processing is done through a PCI DSS compliant third party. If customers are paying by a credit card, their card details are vaulted through a third-party payment gateway. LowerSubs will store an encrypted token along with the last four digits of the credit card and the expiration month and year of the card and will not store or retain any other billing information about you.

Developer Survey

As the world’s largest developer community, LowerSubs publishes an annual Developer Survey to provide key insights into the developer community, as well as other surveys from time to time, all of which include demographic (e.g. gender, race, age etc) and certain personal information. Your participation in the Developer Survey as well as any other LowerSubs survey is entirely voluntary. In order to provide meaningful insights into the developer community, LowerSubs may collect sensitive data about you, including, but not limited to your gender, race, sexual orientation, immigration status, and your location. We consider this data to be among our most sensitive, and have taken elevated measures to protect such data as well as to de-identify your name and other personal information from such data. We restrict such data within LowerSubs on a privileged basis to only those that need to see it and while we may share your personal information with certain third parties such as researchers, we do so only after imposing contractual obligations of confidentiality on such third parties and only where absolutely necessary for limited research purposes.

When we publish our surveys, they are published as a compilation of anonymized data, which means that we take every effort to ensure that your information is understood in a statistical narrative decoupled from your personal identity.

If you have any questions concerning the Developer Survey or other survey and our security measures to protect your sensitive personal data, please contact us at: privacy@LowerSubs.com.

Legal basis for processing your information

We will only use your information where we have a legal basis for using it, for example, where we have your consent, or where we need to carry out processing to provide you with a service you have requested. This section describes the legal bases we rely on for processing your information, including when we share it with third parties.

When you access the LowerSubs Network and use the Products and Services we offer, we collect, display, store, share, transmit, and process your information in the manner described in this policy.

In order to carry out these activities, LowerSubs may rely on the following legal bases in order to process your personal data:

• Where you have given us consent to process the information, which you can withdraw at any time.
• Where the processing is necessary:
• to carry out the contractual obligations in the Terms of Service or to provide the Products and Services you have requested
• to comply with a legal obligation or to defend legal claims
• to protect the public interest or vital interest of others
• Where it is in our legitimate interests, or that of a third party to carry out the processing.

Whenever we rely on legitimate interests for processing, we ensure that we consider and balance our interests against the individual’s interests before processing. We do not use your personal data on the basis of legitimate interest for activities where individuals’ interests override our interests.

Where we process your information on the basis of legitimate interests, we do so in order to:

Secure your personal data and information

LowerSubs is committed to the safety and security of your personal data and the information that you share with us and with the public. We treat your personal data and safety from harassment as top organizational priorities. At LowerSubs we consider it necessary to pursue these legitimate interests in order to keep our community, you and your information safe from spam, harassment, intellectual property infringement, identity theft, and the scraping and unlawful collection of your information.

Provide and optimize products and services

We use your information to provide and improve our Products and Services, for identification, verification, to provide support, for online and offline marketing including through third party tools such as Google Analytics, and for general research and analytics reporting. In doing so, we may learn which of our Products and Services you are using most, what you’re interested in, and to better enable you to use and access our Products and Services. As a core part of our business, LowerSubs has a legitimate interest in enabling and customizing your experience of our Product and Services offerings.

Engage in commercial transactions

As part of providing our core Products and Services, LowerSubs may charge you for the use of some Products and Services, or certain features within these Products and Services. In order to process your payment, and to secure your financial information, we may facilitate the sharing of your information with third parties. We share your information only with third parties who have met strict security standards and consider the secure processing of your financial information to be a strict and legitimate business necessity.

Comply with regulatory and legal obligations

LowerSubs has a legitimate interest in complying with certain legal obligations and interests which, from time to time, may require the disclosure of your personal information. LowerSubs will not disclose your personal information to legal authorities except where such disclosure is by lawful request, including to meet legitimate national security or law enforcement demands (including a subpoena, court order, or other lawful legal demand by a legal authority with lawful jurisdiction). In some cases, we may also release your personal information to defend our legitimate legal interests. We consider our obligation to protect the LowerSubs community from imminent physical harm to be both a legitimate business interest as well as to be within the public interest and may disclose your personal information if we believe you or another individual may be in imminent danger of harm to yourself or to another.

Marketing and product communications

From time to time, LowerSubs may communicate with you about commercial and other Product and Services offerings. In doing so, we provide you with an opportunity to opt-out of such messages at any time you choose via your account settings. LowerSubs will not sell your personal information to enhance our marketing opportunities or profitability (except as may relate to a corporate event such as a sale or merger), and as we are committed to preventing spam, our direct marketing efforts are limited in scope and frequency. We engage in such activities as a legitimate business interest in order to promote key Products and Service offerings and provide you with every opportunity to unsubscribe from such communications or to further limit their scope and frequency. In short, while we want to communicate some key commercial communications with you and have determined it to be a legitimate interest for us to be able to do so, you have the final say in whether or not you would like to receive such commercial communications from us. You can review or change your permissions in your Profile Settings.

Core business operations

LowerSubs may engage with third parties in business transactions including the buying and selling of assets, the auditing of our business practices and financials, and to engage in business development opportunities. These core activities may involve the processing and/or disclosure of some limited personal information which may be necessary and within our legitimate interests to develop the LowerSubs brand and business. If we transfer any personal information in pursuing such a business transaction, we will always ensure that strict confidentiality measures are in place to protect your privacy interests.

YOUR CHOICE AND CONTROL OF THE INFORMATION WE COLLECT ON YOU

Privacy is a guiding principle of all LowerSubs Products and Services and we value your privacy. To this end, we provide you with the ability to control how your information is stored, and what information is collected. You may change or correct your account settings and choose not to share certain information by creating a pseudonymous account. Additionally, much of the data we collect is voluntary and your choice entirely to provide us or not. You may also remove certain optional information that you no longer wish to be publicly displayed, such as your photo, or job history. In the event LowerSubs decides to provide additional opt-out or opt-in mechanisms under the Privacy Shield Framework, the mechanisms will be clear, conspicuous, and readily available for you to exercise your choice. And of course, should you wish, you may also request the permanent deletion of your account, in which case all personal information collected on you will be removed from our servers and encrypted (except, in some cases your IP address required for security purposes, site maintenance, and spam protection).

We also provide you additional data control options created by the GDPR, but provided to the LowerSubs community regardless of geographic location with respect to your information, including data access and portability (including the right to obtain and download a copy of the personal data you provided to LowerSubs), data correction (the ability to update the personal data we collect and display on you, in many cases via your account settings), data deletion (where LowerSubs will delete personal information stored on you, which we are not required by necessity to maintain), and the ability to have us stop processing your personal data (with certain exceptions as may be necessary). You may submit data requests to privacy@LowerSubs.com.

Please also be aware that in order to respond to data requests and provide data choices to you, we may need to first verify your identity.

You may additionally control the receipt of certain marketing and advertising communications from LowerSubs. Some messages that we send are required, and related to our legal obligations, or service related and mandatory. Other messages, like marketing and advertising communications are provided by us to let you know how you can continue to share, learn, and build your knowledge within the LowerSubs community, and are voluntary. We provide you with the opportunity to control which voluntary (non-mandatory/required) messages you would like to receive in your Profile Settings.

Children

LowerSubs Network is not intended for children and we do not knowingly collect personal data pertaining to children.

Cookies

In order to provide the LowerSubs Network along with the Products and Services described in this policy, we may place cookies on you as well as partner with third parties including advertising partners, who may use cookies or other similar technologies to provide you with advertising based on your browsing activities and interests. Please see our cookie policy for additional information on how we use cookies and what third party cookies we permit.

Online and other digital advertising

When you access our websites, we may use your information to provide you with advertising content.

We will only process your data for any online or digital advertising on the basis of your informed consent, which can be withdrawn at any time, or if we have a legitimate interest.

OUR ONGOING COMMITMENT TO DATA SECURITY

Security is important to us and we know it is important to you. LowerSubs follows generally accepted standards to protect your personal information when processing, transferring, and storing your personal information including Transport Layer Security (“TLS”), by restricting your personal data when we do not need to access it and by keeping your personal data only as necessary to perform our legitimate business interests.

As the data subject, you too have an important role to play in helping us protect your personal information. We encourage you to protect yourself against unauthorized access to your personal information by choosing a password carefully and in accordance with industry best standards. Do not share your password with anyone you do not trust, and make sure your computer accesses LowerSubs via a secure network and that you do not leave your personal information vulnerable to hackers and other bad actors by leaving your computer unattended or by failing to logout of your account when you have ended your session activity.

DIRECT MARKETING OPT OUT

You may opt-out of receiving LowerSubs email marketing materials by using the unsubscribe link in these communications or by changing your Email Settings.

PRIVACY POLICY AMENDMENTS

We may amend or update this policy from time to time and will notify you of any material changes to this policy. Previous versions of this privacy policy are available upon request.

CONTACT US

Email: contact@lowersubs.com