Privacy Policy

Effective Date: April 15th, 2021

Welcome to bitgrit Inc. (“bitgrit” or “Bitgrit”), and our website(s), products, services and applications (the “Services”). This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

When you clicked “accept” or “agree” in connection with registering your account, we made available to you this Privacy Policy and the information handling practices described here. This Privacy Policy only covers bitgrit's practices regarding personal information, and not information more generally. We may use aggregated, anonymized data that we derived from your personal information, but not in a manner that incorporates any of your personal information or would identify you personally.

We'll ask for your consent before using your information for a purpose that isn't covered in this Privacy Policy. You may decline to share certain personal information with bitgrit, in which case Bitgrit may not be able to provide to you some of the features and functionality found in the Services. If Bitgrit contracts a third party to perform services that includes the handling of personal information, Bitgrit will take precautions to ensure that the contracted service provider abides by appropriate information protection practices. Such precautions may include but are not limited to entering into a non-disclosure contract or other similar contract with such outsourced service providers.

Information bitgrit Collects

We collect information to provide better Services to all our users. When you're not signed into a bitgrit account, we store the information we collect with unique identifiers tied to the browser, application, or device you're using. When you're signed in, we collect information that we store with your bitgrit account.

Things You Create or Provide to Us

When you create a bitgrit account, submit competition entries or otherwise use the Services, you provide us with personal information that includes your username, country, email address, and a password. You may also optionally provide your city and/or other personal information.

You must provide this data to enter into the Terms of Use, a contract, with us, as well as for you to enter competitions and use other functions hosted on the Services. These entries and any other data submitted are also a contract between you and the competition host or other third party affiliated with the relevant Service in use, and we need your personal information to host the Services offered under that contract (see the Terms of Use for additional information). If you do not enter the minimum amount of personal data required to register an account, which includes your display name and email address, you cannot use the Services, as this information is necessary for contractual reasons.

Other data that collect includes the content you create, upload, or receive from others as part of using our Services. This includes things like messages you send and receive, datasets, and submissions to relevant competitions.

Profile

Our platform allows users to input their personal information on their profile. This information can be used for the Job Board, recruiting ventures, and job-searching functionality, as well as in evaluating users on competition leaderboards. Users may also input their personal data surrounding their educational experience, professional experience, background, skillset, and other information for personalized job recommendations, referrals, and other job placement services bitgrit provides.

Users may choose whether to provide this information. Should users choose to input this information on the platform, this information will be available for bitgrit's use in compiling competition participation analytics should a user participate in a certain competition, determining competition prize winners, discussing with competition hosts regarding competition participants and winners, referring candidates for job opportunities or other activities associated with functions of the platform, depending on which functions of the Service you make use of. This data will be provided to bitgrit for bitgrit's viewing purposes only, and will not be passed in written or spoken form to any third-party firm in a way that can be personally identifiable unless the user expressly consents in this Privacy Policy or separately that Bitgrit or third party affiliates use this information. Any information that should be made available to other parties or publicly will be anonymized, though some information made public on your User Profile will be visible to other users and competition hosts via the Leaderboard or via consequent exchange between Bitgrit and prize holders in competitions and the competition hosts. We will seek explicit consent and approval from the individual in the event that we wish to disclose their information to third parties.

For the sake of clarity, users who make applications to certain job board postings will be construed as having shared explicit consent to share their information in regard to those job contents or the company listed in the job description. The user can expressly inform Bitgrit of their desire to keep their information disclosed or anonymized, which Bitgrit will honor, though it will impede Bitgrit's ability to connect you with job opportunities and provide you with the Services. Applications on the Job Board will be construed as express consent to share information only with the company detailed within the relevant Job Posting. Bitgrit will only share profile information with companies in which Bitgrit has entered into a relevant recruiting contract or non-disclosure agreement.

Information We Collect as You Use Our Services

Your Apps, Browsers & Devices

Bitgrit gathers information regarding the applications, browsers, and/or devices you use to access our Services or to open our emails by using different types of technology, including “clear gifs” or “web beacons.” Information acquired using this technology is collected automatically, and may include your Internet Protocol address (“IP address”) or other device addresses or IDs, the type of web browser or device that you use, the web pages or sites that you visit just before or just after accessing the Services, the pages you view on the Services, and the dates and times that you visit the Services.

We make use of different technologies to collect and store information, including local storage, pixel tags, cookies, browser web storage, application data caches, databases, and server logs.

Your Activity

We collect information about your activity as you use our Services, which may include, but is not limited to:

• Views and interactions with certain content.
• Which datasets you view or download.

You are not required to post or upload personal data; please note that in not doing so, however, you may not be able to grow and engage with your network over our Services with the same freedom as someone who has provided their information.

Cookies and Web Beacons

When you use the Services, we send one or more cookies to your computer. We use cookies to ensure that you are able to switch between pages on the Services without any hindrance or delay to your connection speed. Bitgrit may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services.

Persistent cookies can be removed. Please review your web browser's “Help” file to learn the proper way to modify your cookie settings. If you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Linked Accounts

When you link an account you may have on a third party service (such as a third party social networking site or email provider) to your bitgrit account, bitgrit collects certain information stored in connection with that account that you have configured that service to make available, including your email address, provider ID, first and last name, and profile picture. By linking your accounts in this manner, you authorize bitgrit to access and use your account on the third party service in connection with your use of the Services.

Why bitgrit Collects Information

bitgrit uses the information we collect for the following purposes:

Providing Our Services

We use your information to deliver our Services, like administering competitions you enter or hosting datasets you upload or access. For example, we use the IP address assigned to your device to send you the data you requested, such as loading a dataset. Another example is that we use unique identifiers stored in cookies on your device to help us authenticate you as the person who should have access to your bitgrit account.

Maintaining & Improving Our Services

We also use your information to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us. For example, we continuously monitor our systems to look for problems. And if we find something wrong with a specific feature, reviewing activity information collected before the problem started allows us to fix things more quickly.

And we use your information to make improvements to our Services – for example, to understand and analyze the usage trends and preferences of our bitgrit account members and to improve the way the Services work and look.

For example, we use cookies to analyze how people interact with our Services, which can help us build better products. It may help us discover that it's taking people too long to complete a certain task or that they have trouble finishing steps at all. We can then redesign that feature and improve the product for everyone.

Developing New Services

We use the information we collect in existing Services to help us create new features and functionality.

Providing Personalized Services

We use the information we collect to customize our Services for you, including remembering your information so that you will not have to log-in again the next time you visit the Services if you haven't signed out. We also use data to provide customized third party content and information and to track your status in any Competitions or other activities. In addition, we may use the information we collect to provide personalized and relevant advertising, for example showing you positions from our jobs board in your location based on your IP address or providing personalized job offer information based on your competition history, results, or information in your profile.

Measuring Performance

We use data for analytics and measurement to understand how our Services are used. For example, we analyze data about your visits to our sites to do things like optimize product design, monitor and analyze the operation and effectiveness of the Services and related activities, and monitor aggregate site usage metrics such as total number of visitors and pages viewed. We use a variety of tools to do this, including Google Analytics. Google Analytics relies on first-party cookies, which means the cookies are set by bitgrit.

In addition, we may also collect information on your profile for use in measuring performance in our competitions, evaluating submitted solution files, and determining who may rank as prize winners in our Leaderboard.

Communicating with You

We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity on your account, or we may let you know about upcoming changes or improvements to our Services. We will also use your email address to contact you with respect to competition entries, prize awards and otherwise in connection with competitions; for administrative and customer service purposes; to address intellectual property infringement, rights of privacy, or defamation issues; or regarding things you post on the Services. And if you contact bitgrit, we'll keep a record of your request to help solve any issues you might be facing.

bitgrit also uses your email address or other personal information to send you messages about the Services. We may also send you messages related to the Services and the activities of third parties we work with. These messages may be targeted at you based on your activities on our Services, for example your interaction with a particular dataset or your entry into a specific competition. You will have the ability to opt-out of receiving marketing communications by updating your settings in your profile.

We may also reach out to you to confirm the details of your submissions in a certain competition to determine leaderboard ranking, determine eligibility of submitted files, as well as to confirm contact and banking information should you be eligible to receive prize money or other benefits. We may also be in touch with you regarding your profile information or the application process should you make an application to a certain Job Board application.

Protecting bitgrit, Our Users, and the Public

We use information to help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm bitgrit, our users, or the public. For example, we collect and analyze IP addresses and cookie data to protect against automated abuse. This abuse can take many forms, such as sending spam to bitgrit users or launching a Distributed Denial of Service (DDoS) attack.

When we detect spam, malware, illegal content, and other forms of abuse on our systems in violation of our policies, we may disable your account or take other appropriate action. In certain circumstances, we may also report the violation to appropriate authorities.

Bitgrit will seek your explicit consent to use information outside of the purposes mentioned above. Should Bitgrit make any changes to the extent in which it uses your information, Bitgrit will either make that fact publicly known or inform you directly of that fact.

Managing Your Information

Managing, Reviewing, and Updating Your Information

When you're signed into your bitgrit account, you can always review and update information by visiting your account profile.

Information Retained For Extended Time Periods for Limited Purposes

Business and legal requirements may, from time to time, require us to retain certain information for specific purposes for an extended period of time. For example, when you submit an entry in a competition, we may retain this information for a longer period of time to guard against cheating, for example, or for legal purposes. Reasons we might retain some data for longer periods of time include:

• Security, fraud & abuse prevention
• Financial record-keeping
• Complying with legal or regulatory requirements
• Ensuring the continuity of our services

Any personal information retained that is no longer in use by the User, Bitgrit, or Third Parties will be promptly deleted.

Enabling Safe and Complete Deletion

When you delete data in your bitgrit account, we immediately start the process of removing it from the product and our systems. First, we aim to immediately remove it from view. For example, if you delete a post you made, we will work to immediately remove that from the public-facing bitgrit website.

We then begin a process designed to safely and completely delete the data from our storage systems. Safe deletion is important to protect our users and customers from accidental data loss. Complete deletion of data from our servers is equally important for users' peace of mind.

Each of our storage systems from which data gets deleted has its own detailed process for safe and complete deletion. This might involve repeated passes through the system to confirm all data has been deleted, or brief delays to allow for recovery from mistakes. As a result, deletion could sometimes take longer when extra time is needed to safely and completely delete the data.

Our services also use encrypted backup storage as another layer of protection to help recover from potential disasters.

As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and timeframes defined in this article. We maintain systems designed to detect and remediate such issues.

To make a request for data deletion, please contact bitgrit at bitgrit.com. Please note that to maintain server integrity and for recordkeeping of competition participation data, it may not be possible for bitgrit to delete all data tied to a User's account in its entirety. Data that cannot be deleted in its entirety will be anonymized, encrypted, or processed in a way that protects the identity of the user to which it is associated with.

When bitgrit Shares or Processes Your Information

We are not in the business of selling your information. We do, however, disclose your personal information in connection with developing and maintaining the Services and operating Competitions.

We share and/or process your information for the purposes described in this policy, based on the following grounds:

With Your Consent

We'll share personal information outside of bitgrit when we have your consent. We may share your information, for example, if you give us permission to share your information with a third party who may be a prospective employer, for collaboration purposes in hosting marketing initiatives, connecting you with job opportunities. Applications via the Job Board are to be considered as consent from the applying user to bitgrit to share their information to the employer mentioned in the Job Board posting. Bitgrit may not share the information of Job Board applicants to any companies in which the user has not explicitly applied or given consent to provide information to.

To Operate Competitions

Bitgrit may disclose your personal information to the hosts of competitions to enable your participation in the competitions and our operation of the competitions. By choosing to participate in a competition (via pressing the “Participate” button, expressing explicit intent to participate, or agreeing to the Competition NDA), you give your consent to bitgrit to disclose your personal information to the host(s) of that competition. Information made public on your user profile may be shared with competition hosts for purposes of maintaining competitions, evaluating submission files, and determining winners. The terms of that disclosure are covered in the competition rules, which is a contract between you and the competition sponsor.

For Legal Reasons

We will share personal information outside of bitgrit if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

• Meet or comply with any applicable law, regulation, legal process, or enforceable governmental request.
• Enforce our Terms of Use, including investigation of potential violations, and take precautions against liability.
• Detect, prevent, or otherwise address fraud, abuse, security, or technical issues.
• Protect against harm to the rights, property or safety of bitgrit or our affiliates, our users, or the public as required or permitted by law.
• Protect the security or integrity of the Services and to protect or enforce third party rights.

We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our Services.

If bitgrit is involved in a merger, acquisition, or sale of assets, we'll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Data Transfers

Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

Bitgrit may provide your information to third parties in foreign countries should any of the circumstances be applicable to you.

• You have given prior consent to provide personal information to third parties in foreign countries. Third parties refer to subsidiaries and companies affiliated with Bitgrit located in foreign countries. Prior consent is including, but not limited to, participation in competitions in which data providers or hosts are located in foreign countries, applying for a job on the Job Board in which the hiring company is located outside of Japan, or downloading or uploading datasets in which the uploader or downloader is located in a foreign country, etc.
• Concerning the handling of personal information, where personal information is provided to third parties in foreign countries that have implemented measures in accordance with the provisions of Chapter 4, Section 1 of the Personal Information Protection Act in Japan by appropriate reasonable measures, and with whom Bitgrit has ensured implementation of such measures; in such case, the recipients of personal information are limited to Bitgrit's subcontractors in foreign countries (subcontractors include such parties as sub-subcontractors and their subcontractors, etc. in foreign countries);
• Your information is not personally identifiable or able to be connected to you personally.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Providing Services

We process your data to provide a service you've agreed to utilize, access, and/or participate in under our Terms and Conditions. For example, we process your information in connection with competitions you enter.

Complying with Legal Obligations

We'll process your data when we have a legal obligation to do so, for example, if we're responding to legal process or an enforceable governmental request.

In regard to any other uses of your data that are not mentioned here, Bitgrit will seek your explicit permission to use data for such purposes.

Pursuing Your Interests

We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

• Providing, maintaining, and improving our Services to meet the needs of our users
• Developing new products and features that are useful for our users
• Understanding how people use our Services to ensure and improve the performance of our Services both within bitgrit and with competition collaborators and co-hosts
• Customizing our Services to provide you with a better user experience
• Marketing to inform users about our Services
• Providing advertising to make many of our Services freely available for users
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
• Protecting against harm to the rights, property or safety of bitgrit, our users, or the public as required or permitted by law
• Performing research that improves our Services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of our Terms of Use

Our Commitment to Data Security

Bitgrit takes proper and adequate security measures and considers the security of user data to be of the utmost priority. We will take all measures available to us to prevent information from being lost, damaged, or leaked, while regularly reviewing our security measures to ensure continuous protection of data.

If bitgrit learns of a security breach, we will notify you in accordance with applicable law.

Third Party Websites

The Services contain links to websites and services provided by third parties. Any personal information you provide on third party sites or services is provided directly to that third party and is subject to that third party's policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on the Services. We encourage you to learn about third parties' privacy and security policies before providing them with personal information.

Our Commitment to Children's Privacy

Protecting the privacy of children is especially important. For that reason, bitgrit does not knowingly collect or maintain personal information from persons under 13 years old, and no part of the Services is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.

If bitgrit learns that personal information of children under 13 years old has been collected on the Services without verifiable parental consent, then bitgrit will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained a user account on the Services, then you may alert bitgrit by contacting bitgrit directly.

If you are between the ages of 13 and 16 years old, you must receive parental consent before using the services. If you are between the ages of 13 and 17 years old or under the age of contractual majority in your country, you also may not enter any competitions unless you have received parental consent from parents or guardian. If you utilize the services and/or participate in bitgrit competitions, it will be understood that you have received parental consent prior to doing so.

Compliance & Cooperation with Regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Changes and Updates to this Privacy Policy

We change this Privacy Policy from time to time. Note that our amended Privacy Policy will become effective on a going-forward basis as stated in the Terms, except that (i) unless you agree otherwise, we will use your personal information in the manner described in the Privacy Policy in effect when we received that information and (ii) if you do not agree with any changes to the Privacy Policy, you must terminate your bitgrit membership and cease use of the Services.

Bitgrit will inform users of updates to the Privacy Policy by publicly announcing said changes, informing users of said changes, or other means. Your continued use of the Services after a revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.

Governing Law and Jurisdiction

This Privacy Policy will be governed by and construed in accordance with the laws of Japan. Any dispute concerning this Agreement or the Service will be subject to the exclusive jurisdiction of the Tokyo District Court of first instance.

bitgrit Contact Information

Contact information may be found at info@bitgrit.com