This policy explains how Colab91 Inc. (Colab91, we, us) handles personal information when you visit www.colab91.com, including our blog at www.colab91.com/feeds (the site), when you contact us, when you apply for a job, and when you deal with us as a business contact. It also explains the cookies the site uses and the rights and choices you have.
In short: we use what you send us to reply to you and to recruit. We use cookies to understand how the site is used and to find out which businesses visit (and, in the United States, if you agree, who visits) so that we can follow up; you can turn those cookies off at any time with Your Privacy Choices at the bottom of every page. A script from Gushwork, our marketing agency, also records how you reached the site and sends that record, with a copy of any enquiry you send us, to Gushwork, so that we can see which marketing brings enquiries. We do not sell your information for money. You can ask to see, correct or delete your information by writing to contact@colab91.com.
1. Who we are
The site is run by Colab91 Inc., a Delaware corporation, 1325 Main Street, Suite 1404, Katy, Texas 77494, USA. Colab91 Inc. decides how and why the personal information described here is used: it is the controller. Our team in India is employed by our Indian company, Amavco Growth Partners Private Limited, WeWork Forum, DLF Cyber City, Gurugram, Haryana 122002, which handles this information with us and is responsible for applications to roles in India. Under Indian law, each of the two companies is a data fiduciary for the information it handles.
For any privacy question, request or complaint, email contact@colab91.com with "Privacy" in the subject line, or write to us at the address above.
2. What this policy covers
This policy covers the site and the blog, the enquiries you send us through the contact form or by email, job applications, and our dealings with business contacts, including business-to-business marketing.
It does not cover:
- SPIN, our product at spin.colab91.com, which has its own privacy policy as part of the SPIN Terms of Service;
- personal information we handle for our clients while providing services to them, which our agreements with those clients govern;
- other websites we link to, which have their own policies.
3. Information we collect
| Information | Examples | Where it comes from |
|---|---|---|
| Enquiry details | Your name, work email address, the topic you choose (services, products or careers), your message and the page you sent it from | You, through the contact form or by email |
| Application details | Your CV and what it contains (for example contact details, work history, education and skills), links you send us, notes from interviews and assessments, and references | You, the people you name as references, and recruiters you work with |
| Business contact details | Your name, job title, employer, business email address and phone number, and your professional profile (for example on LinkedIn) | You, your organization, RB2B (see Cookies and similar technologies) and public professional sources |
| Website activity | The pages you view and when, how you reached the site, the links you click, your approximate location (city or country), your browser and device type, and cookie identifiers | Your device, through cookies and similar technologies |
| Technical and security data | IP address, browser and device details, the pages requested and time stamps | Your device, recorded by our hosting and security providers |
Please do not send us sensitive information (for example about your health, racial or ethnic origin, religious beliefs or financial accounts) through the site or with an application, unless we ask for it for a specific legal reason.
You do not have to give us any information to browse the site. If you contact us or apply for a role, we need your name, email address and message (or CV) to reply to you or consider you.
4. How we use information, and our legal bases
The last column gives the legal basis we rely on under the GDPR in the European Economic Area (EEA), the UK and Switzerland.
| Why we use it | Information used | Legal basis (EEA, UK, Switzerland) |
|---|---|---|
| To reply to your enquiry and tell you about our services and SPIN | Enquiry details, business contact details | Our legitimate interest in responding to business enquiries, or steps you ask us to take before entering into a contract |
| To recruit: to assess applications, interview, and keep in touch about suitable roles | Application details | Steps before entering into an employment contract; our legitimate interest in hiring; legal obligations such as right-to-work checks |
| To understand how the site is used and improve it (Google Analytics) | Website activity | Your consent |
| To find out which businesses visit the site and follow up with them about our services (RB2B) | Website activity, business contact details | Your consent |
| To see which of our marketing brings enquiries (Gushwork) | Website activity, enquiry details | Our legitimate interest in measuring our marketing |
| To send business-to-business marketing emails | Business contact details | Our legitimate interest in promoting our services to businesses, or your consent where the law requires it. Every email lets you opt out. |
| To keep the site secure and stop spam and abuse | Technical and security data, and the spam checks on the contact form (a hidden field and the time taken to send) | Our legitimate interest in protecting the site and our team |
| To comply with the law, protect our rights and resolve disputes | Any of the above, as needed | Legal obligations, or our legitimate interest in protecting our rights |
Outside the United States, we use Google Analytics and RB2B only with your consent. In the United States, we use RB2B only with your consent, and Google Analytics on the basis of our legitimate interest in improving the site; you can opt out of Google Analytics at any time (see Your rights and choices).
Where we rely on legitimate interests, we have weighed them against your rights and interests. You can ask us for details, and you can object at any time. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
5. Cookies and similar technologies
Cookies are small files stored on your device; browsers can also keep information in local storage. The site's own code sets one cookie, to remember your choice, and loads two tools, Google Analytics and RB2B, each only as your choice allows:
- Outside the United States, they stay off unless you click Accept in the notice, or turn them on in Your Privacy Choices at the bottom of every page.
- In the United States, Google Analytics is on unless you turn it off in Your Privacy Choices, and RB2B stays off unless you click Accept in the notice or turn it on there.
- If your browser sends a Global Privacy Control signal, we treat it as a request to opt out for that browser and keep both off, even if you said yes before, and the choices panel shows that your opt-out was honored. If you then turn them on again yourself in Your Privacy Choices, we follow that choice.
Two more tools run through Cloudflare, which delivers the site, on every visit and whatever your choice in Your Privacy Choices: Gushwork's enquiry attribution and Cloudflare Web Analytics (both described below).
| Cookie | Set by | What it does | How long it lasts |
|---|---|---|---|
| c91_consent | Colab91 | Remembers your choice about the tools below (strictly necessary) | 6 months |
| _ga, _ga_* | Google Analytics (Google LLC) | Counts visits and measures how the site is used, in aggregate | Up to 2 years |
| _reb2buid, _reb2butk, _reb2bgeo, _reb2bli and related _reb2b cookies | RB2B (GetEmails LLC) | Recognizes returning visitors and links visits to business identities (see below) | From 20 days to 1 year |
| cf_clearance | Cloudflare | Set only if Cloudflare has to check that a visit is not from a bot: shows that the check was passed (strictly necessary, to protect the site) | As set in our Cloudflare security settings |
| cf_zaraz_client | Cloudflare (Zaraz) | Set by Cloudflare's tag manager, which loads Gushwork's script (in our tests it held no value) | 1 year |
| leads_attribution_data (local storage) | Gushwork | Records how you reached the site (for example the search engine, social network or campaign) and the pages you view | 30 days |
| leads_attribution_session (session storage) | Gushwork | A random identifier for your visit | Until you close the tab |
Google Analytics
Google Analytics shows us how many people visit, which pages they view and how they found us. It keeps the detailed data about visits for up to 14 months; after that, only totals remain in our reports. Google does not store the IP addresses of visitors in the EEA, the UK or Switzerland. You can read how Google uses this data in How Google uses information from sites or apps that use its services, and you can install the Google Analytics opt-out browser add-on.
RB2B (visitor identification)
RB2B, a service of GetEmails LLC of Austin, Texas, uses cookies, your IP address and details of your device to recognize your visit and match it against its own database of business profiles. For visitors in the United States it can tell us who you are in a professional capacity (for example your name, job title, employer and professional profile); for visitors elsewhere it tells us only which company you are likely to work for. We use this to follow up with businesses about our services.
RB2B runs its database independently of us, so under California law and some other US state laws, letting it collect information on our site counts as sharing your information. It runs only if you accept, and you can turn it off again at any time with Your Privacy Choices. You can also ask RB2B to remove you from its database at app.retention.com/optout, or to show you what it holds at app.retention.com/request_my_data.
Gushwork (enquiry attribution)
Gushwork, the agency that runs our blog and search marketing, has a script on every page of the site, loaded through Cloudflare's tag manager (Zaraz). It records how you reached the site (for example the search engine, social network or campaign) and the pages you view, in your browser's storage. When you send the contact form, it sends a copy of what you entered (your name, email address and message), with that record, to Gushwork, so that we can see which marketing brings enquiries. It runs on every visit, whatever your choice in Your Privacy Choices. You can remove what it stores by clearing this site's data in your browser.
Cloudflare Web Analytics
Cloudflare also counts visits and measures how quickly pages load (Cloudflare Web Analytics). Cloudflare says this does not use cookies or local storage and does not fingerprint visitors; in our tests it stored nothing on the device.
Our blog
The blog at www.colab91.com/feeds runs on a separate content platform (Gushwork). It currently loads RB2B and CallRail, a call-tracking service that records how visitors reach us so that calls can be traced to the page that led to them, and fonts from Google, without the choices described above. You can block these cookies in your browser settings, and you can opt out of RB2B's database at the link above.
Browser settings, Do Not Track and tracking across sites
You can block or delete cookies in your browser settings; the site works without them. Some browsers send a "Do Not Track" signal. There is no agreed standard for it, so the site does not respond to it; it does honor Global Privacy Control, as described above. Google and RB2B may collect information about your online activities over time and across different websites when you use our site.
6. Who we share information with
We share personal information only with the people and organizations below, and only as this policy describes.
| Who | Why | Where |
|---|---|---|
| Our team | Colab91 people (in India, employed by Amavco Growth Partners Private Limited) who handle enquiries, business development and recruiting | United States and India |
| Vercel Inc. | Hosts the website | United States |
| Cloudflare, Inc. | Delivers the site and protects it from attacks; counts visits and page speed (Cloudflare Web Analytics); runs the tag manager that loads Gushwork's script | Global network |
| Microsoft Corporation (Microsoft 365) | Our email: enquiries, applications and other messages arrive in our Microsoft 365 mailboxes | United States and other countries |
| HubSpot, Inc. | Our customer relationship management (CRM) system: keeps business contact details and enquiries, and our record of dealings with them | United States |
| Google LLC (Google's email service) | Sends the messages from the site's contact form to our mailboxes | United States and other countries |
| Google LLC (Google Analytics) | Site analytics | United States and other countries |
| GetEmails LLC (RB2B) | Visitor identification, as an independent third party (see Cookies and similar technologies) | United States |
| Gushwork | Runs our blog and search marketing; receives a copy of each contact-form enquiry with how the sender reached the site | United States and India |
| CallRail, Inc. | Call tracking on the blog | United States |
We also share information with our professional advisers under a duty of confidentiality; with courts, regulators and authorities when the law requires it or to protect rights and safety; with a buyer or successor if Colab91 is involved in a merger, acquisition or sale of assets, who must respect this policy; and with others when you ask us to or agree.
We do not sell personal information for money. Letting RB2B collect information on our site may count as "selling" or "sharing" under California law and some other US state laws, and you can opt out at any time (see Your rights and choices).
7. International transfers
We are based in the United States and our team also works from India, and our providers process information in the United States and other countries. When we transfer personal information from the EEA, the UK or Switzerland to a country without an adequacy decision, we rely on the EU-US Data Privacy Framework (and its UK and Swiss extensions) where the recipient is certified, and otherwise on the European Commission's standard contractual clauses, with the UK addendum or Swiss amendments where needed. You can ask us for a copy of these safeguards.
8. How long we keep information
| Information | How long we keep it |
|---|---|
| Enquiries | While we are in touch about your enquiry and then up to 24 months after our last contact, unless a business relationship follows (then for that relationship and as the law requires) |
| Job applications | Up to 12 months after the role is filled, so that we can consider you for other roles, unless you ask us to delete it sooner. If you join us, it becomes part of your employment record. |
| Business contact details and visitor identification | Up to 24 months after our last interaction with you, or until you opt out |
| Google Analytics data | Up to 14 months for the detailed data about visits; reports keep only totals |
| Enquiry attribution (Gushwork) | 30 days in your browser; Gushwork's copies of enquiries as for enquiries above |
| Technical and security logs | For the period our hosting and security providers keep them, and longer if we need them to investigate an incident or the law requires it |
| Your cookie choice | 6 months |
We may keep information for longer where the law requires it, or to establish, exercise or defend legal claims. When we no longer need information, we delete it or make it anonymous.
9. How we protect information
We use encryption in transit (HTTPS), access controls, and providers that maintain recognized security certifications such as SOC 2 and ISO 27001. Contact form messages go to our mailboxes (and a copy to Gushwork, see Cookies and similar technologies); the site itself does not store them in a database. No system is completely secure, so we cannot guarantee security, but we will tell you and the authorities about a breach where the law requires it.
10. Your rights and choices
Depending on where you live, you may have the right to:
- know what personal information we hold about you and get a copy;
- have it corrected or completed;
- have it deleted;
- restrict how we use it, or object to our use of it, including at any time to direct marketing;
- receive it in a portable format;
- withdraw your consent at any time (this does not affect what we did before);
- opt out of the "sale" or "sharing" of your information and of targeted advertising;
- not be treated differently for using these rights, including as a job applicant.
To use these rights, email contact@colab91.com with "Privacy request" in the subject. We will confirm we have your request within 10 business days and reply within one month (45 days where US state law applies), and tell you if we need more time. We may ask for information to confirm your identity first. You can ask someone to act for you; we may ask them for proof that you authorized them. If we turn down a request, we will tell you why and how you can appeal.
To turn off analytics and visitor identification, use Your Privacy Choices at the bottom of any page, or turn on Global Privacy Control in your browser. To stop marketing emails, use the unsubscribe link in any email, or write to us.
11. If you are in the EEA, the UK or Switzerland
The legal bases we rely on are in How we use information. You can complain to us directly at contact@colab91.com; we will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay. You also have the right to complain to a data protection authority, in particular where you live or work: in the UK, the Information Commissioner's Office; in the EU, your national authority; in Switzerland, the Federal Data Protection and Information Commissioner.
12. If you are in the United States
This section adds the information required by California law, including the California Consumer Privacy Act (where it applies to us) and the California Online Privacy Protection Act, and by other US state privacy laws. It applies to website visitors, business contacts and job applicants.
In the last 12 months we have collected these categories of personal information:
| Category | Examples | Sources | Disclosed for business purposes to | Sold or shared with |
|---|---|---|---|---|
| Identifiers | Name, email address, IP address, cookie identifiers | You, your device, RB2B | Vercel, Cloudflare, Google, Microsoft, Gushwork, HubSpot | RB2B |
| Professional or employment information | Job title, employer, CV contents | You, RB2B, public professional sources | Google and Microsoft (email), HubSpot (CRM) | RB2B (job title and employer it matches to your visit) |
| Education information | Education listed in a CV | You | Google and Microsoft (email) | Not sold or shared |
| Internet or network activity | Pages viewed, how you reached the site, clicks | Your device | Google, Vercel, Cloudflare, Gushwork | RB2B |
| Approximate location | City or country, worked out from your IP address | Your device | Google, Cloudflare | RB2B |
| Inferences | The company you are likely to work for, inferred from your visit | RB2B | None | RB2B |
We use these categories for the purposes in How we use information, and keep them for the periods in How long we keep information. If you accept RB2B, we share identifiers, professional information, network activity and approximate location with RB2B, a third party, to identify the businesses and people who visit and follow up with them. We do not use or disclose sensitive personal information to infer characteristics about you, we do not knowingly sell or share the personal information of anyone under 16, and we do not use automated decision-making technology to make significant decisions about you.
Your Privacy Choices, at the bottom of every page, is where you turn RB2B on or off, and so opt out of selling and sharing. We treat a Global Privacy Control signal as a valid request to opt out for the browser or device that sends it, and show that it was honored. You can also exercise the rights in Your rights and choices, and appeal a decision by replying to our response; if we turn down your appeal, you may contact your state attorney general.
13. If you are in India
Colab91 Inc. and our Indian company, Amavco Growth Partners Private Limited, are the data fiduciaries for the personal information described in this policy, each for the information it handles. You can ask us for a summary of your personal information and how we use it, and to correct, complete, update or erase it. You can nominate another person to exercise your rights if you die or become unable to. Where we rely on your consent, you can withdraw it as easily as you gave it.
Grievances: write to our Grievance Officer, Madhur Kabra, at contact@colab91.com or at Amavco Growth Partners Private Limited, WeWork Forum, DLF Cyber City, Gurugram, Haryana 122002. We will resolve your grievance within one month. If you are not satisfied, you may complain to the Data Protection Board of India once it is hearing complaints.
14. Children
The site is for businesses and job seekers, not children. We do not knowingly collect personal information from anyone under 18. If you believe a child has sent us information, contact us and we will delete it.
15. Changes to this policy
We update this policy when our practices or the law change. We will post the new version here with a new "last updated" date, and if a change is significant we will tell you more prominently, for example with a notice on the site.
16. Contact us
Colab91 Inc., 1325 Main Street, Suite 1404, Katy, Texas 77494, USA. In India: Amavco Growth Partners Private Limited, WeWork Forum, DLF Cyber City, Gurugram, Haryana 122002. Email: contact@colab91.com, with "Privacy" in the subject line.