Privacy policy

1. What is this Privacy Policy about

  • This LEVO privacy policy (hereinafter “Privacy Policy”) aims at informing you how the École Polytechnique Fédérale de Lausanne (hereinafter “EPFL” or “We” or “Us”) may process your personal data under the operation of Levo and the rights to which you are entitled. This Privacy Policy provide general information applicable in most situations and may be supplemented with more specific notices or regulations whenever applicable.
  • Personal data (hereinafter “Personal Data”) means any information relating to an identified or identifiable person, according to the Swiss Federal Act on Data Protection (hereinafter “FADP”).
  • This Privacy Policy was last updated on 17 June 2022 We may update this Privacy Policy at any time. Any changes to this Privacy Policy will be posted to this page.

2. Who is responsible for the processing of your Personal Data (“data controller”)

  • Levo is managed by the College of Management and Technology together with the Enterprise for Society Center both at the Ecole Polytechnique Fédérale de Lausanne (« EPFL »), Bâtiment CE, 3.316, Station 1, 1015 Lausanne, Switzerland;
  • You can directly contact the data controller at the following email address: hello@levoframework.com

3. Personal Data we collect about you and for which purposes

We may process the following different categories of Personal Data:

  1. Identity Data includes first name, last name, username or similar identifier, startup name
  2. Contact Data includes billing address, email address, and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you and other details of products or services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Levo.
  6. Profile Data includes your username and password, your Levo login information, items posted on Levo, information you provide to us in completing the Levo Operational Assessment and Impact Charting, purchases or orders made by you, your feedback and survey responses.
  7. Usage Data includes information about how you use Levo.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a user of our services

  1. Identity
  2. Contact
  1. Provide access to our services
  2. Performance of a contract with yo

To process and certify you as a customer including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Profile
  6. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences

  1. Technical
  2. Usage

Necessary for our legitimate interests (to improve the user experience, determine types of companies wanting to use our services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).


4. Key principles that guide us

EPFL is bound to respect the principles related to data protection. In application of these principles, we will only process data:

  1. lawfully, fairly and in a transparent manner;
  2. for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the Personal Data are processed; Personal Data may be stored for longer periods insofar as the Personal Data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures;
  6. processed in a manner that ensures appropriate security of the Personal Data

5. Your rights

You have the right to receive a copy of your Personal Data and you may request the correction of any Personal Data which is inaccurate or incomplete. You also have the right to object to the processing of your Personal Data for legitimate reasons as well as a right to object to the use of those data for commercial prospecting in accordance with applicable laws. When the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. EPFL reserves the right to refuse any abusive request or one which is contrary to applicable laws. Finally, you have the right to lodge a complaint with the relevant supervisory authority.

If you wish to forward a request to Us, please email Us at: hello@levoframework.com or t4i@e4s.center


6. Personal Data security

Security

  • EPFL ensures the safety and the security of Personal Data by implementing enhanced data security through the use of data and logical security resources.
  • We deploy appropriate measures at both the technological and organizational level to protect the stored Personal Data of our users from unauthorized access, improper use, alteration, unlawful or accidental destruction and accidental loss. Please note however that we cannot guarantee an absolute security for your Personal Data, to the extent that the Personal Data retention and electronical transmission involves certain risks.
  • These are consistent with good practice and the latest regulations, considering the risks involved, to protect your Personal Data.
  • You are an actor in the protection of your Personal Data. There are simple but effective measures to ensure the confidentiality, the security in general of your data. The EPFL’s IT security provides you some advice here.

Data retention

EPFL keeps your Personal Data for no longer than is necessary for the purposes for which the Personal Data are processed, in accordance with the applicable legislation.


7. International transfers

Your Personal Data is processed in Switzerland. In compliance with the applicable laws, Personal Data may be transferred outside of Switzerland if the recipient State has an adequate level of personal data protection or if such level is provided with appropriate safeguards. Usually, if your Personal Data is to be transmitted, it will always be coded and therefore does not allow you to be identified as a person.


8. With whom we share your Personal Data

  • We may share your Personal Data with the following recipients for the purposes indicated above:
    • Authorized employees of the data controller
    • Authorities responsible for monitoring research projects (such as Swiss or foreign ethics commissions or Swiss or foreign authorities responsible for protecting your personal data).
    • For users who are employed by a start-up: to your respective start-up investors or accelerators, only in the cases in which you were referred to Levo by them as a portfolio startup
    • For users who are start-up investors or start-up accelerators: to the start-ups of your respective portfolio (only contact details).

9. Contact information

For any information concerning the management of your Personal Data, please contact the data controller(s) Data controller

Enterprise for Society Center

email address: t4i@e4s.center or hello@levoframework.com

Terms of use

1. Definitions

“Intellectual Property Rights” means patents, utility models, trade or service marks, trade names, copyrights (including rights in computer software, source codes, and databases) and moral rights, design rights, inventions, discoveries, rights in know-how and all or any other industrial or intellectual property rights whether or not registered or capable of registration including, where the context allows, applications for any of the foregoing, and all rights or forms of protection having an equivalent or similar effect to any of the foregoing which may subsist in any part of the world, including any results developed in Levo;

"LEVO" refers to the application programming interface/platform and the website located on www.levo-framework.com as well as all content and services provided herein;

“Purpose” means the assessment and monitoring of a start-up’s impact and sustainability

"Terms of Use" or "Terms" refer to the present document and any documents referred herein.

“Uploaded Data” refers to the datasets that you import in Levo, which may include personal data and non-personal data, and that are in relation to the Purpose for both startups (for instance, implemented employees’ policies, governance structure, strategic goals, sustainability policies etc.) and investors/accelerators (for instance, contact details, portfolio startups).

“we” or “us” or “our” refer to the College of Management and Technology and the Enterprise for Society Center at the Ecole polytechnique fédérale de Lausanne, Bâtiment CE - 3.316 Station 1, CH - 1015 Lausanne, Switzerland.

"you" or "your" or “User” refer to any user of Levo;


2. Purpose of LEVO

Levo is a platform that allows startups to assess, monitor and continuously improve their sustainability and impact. At the same time, the platform offers investors and accelerators, who invite their portfolio startups to complete the assessment and as a service, access to a dedicated dashboard to review the status of their startups.

The description of the services is more detailed online, and any description of the services available online are part of these Terms of Use. (Hereinafter referred to as the “Services”)

The Services run on the cloud (hosted by hostpoint.ch) and you can access it via web browsers.


3. Duration and termination

You are granted access for an unlimited duration of time. You can close or delete your account whenever you want.

In the event of account’s deletion, the licenses granted under these Terms of Use will also be terminated at the termination’s date.

4. Services conditions

We will give access to Levo with all the functionalities. You accept the following conditions in relation with the Services:

  • Levo is hosted in datacenters in Switzerland, operated by Switch.
  • EPFL does not warrant any service availability.
  • To guarantee optimal performance of the Services, we will perform routine and standard maintenance on hostpoint servers. Such maintenance often requires taking servers off-line. The outage may take place at any time, but these outages will normally occur outside of normal office hours (Monday - Friday, 8:30am - 5.30pm CET).
  • We will not offer any specific support services. For any question however, you can write an email to the following email address: hello@levoframework.com
  • You may decide to delete your account and your Uploaded Data. For such deletion, please contact: hello@levoframework.com. In case of deletion, you must know that your Uploaded Data will be gone forever, because we are not ensuring a backup system.

We reserve the right to withdraw or amend Levo, and any service or material we provide on Levo, in our sole discretion without notice. We will not be liable if for any reason all or any part of Levo is unavailable at any time or for any period. From time to time, we may restrict access to some parts of Levo, or in its entirety, to the users.


5. Your Obligations

You undertake to comply with the following obligations:

  • Upon acceptance of the Terms of Use, you are responsible to take any necessary measure to configure the access rights if applicable, and to read all proper instructions
  • You may use Levo only for the Purpose stated above.
  • You may use Levo only for lawful purposes and in accordance with these Terms of Use. In particular:
    • You are personally responsible for ensuring that your use of Levo does not violate these Terms of Use or any applicable laws and regulations (e.g. criminal laws, data protection laws), does no consist in fake or wrong identity, does not impersonate or attempts to impersonate any person, EPFL or any other entity you do not have authorization to use Levo for, and does not infringe on third parties’ rights (including copyrights, database rights, trademark rights, design rights, patent rights, license rights and personal rights)
    • You undertake not to publish on Levo any unlawful content, in particular content of a racist or pornographic character or which infringes the rights of a natural person. In particular, the following content is not permitted:
      • any illegal, offensive or inappropriate content, including but not limited to any content representing violence, nudity, product placement, advertisement or simply not related to the Levo services;
      • fake projects or accounts.
    • You shall use Levo with all due care. In particular, you shall not
      • use Levo servers for any form of excessive automated bulk activity (e.g., spamming), or relay any other form of unsolicited advertising or solicitation through our servers
      • attempt to disrupt or tamper with our servers in ways that could disable, harm, damage, or impair Levo or interfere with any other party's use of Levo, including their ability to engage in real time activities through Levo
      • use any robot, spider or other automatic device, process or means to access Levo for any purpose, including monitoring or copying any of the material on Levo
      • use any manual process to monitor or copy any of the material on Levo or for any other unauthorized purpose without our prior written consent
      • use any device, software or routine that interferes with the proper working of Levo
      • introduce any viruses, trojan horses, worms, logic bombs or other material which is malicious or technologically harmful
      • attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of Levo, the server on which Levo is stored, or any server, computer or database connected to Levo
      • attack Levo via a denial-of-service attack or a distributed denial-of-service attack
      • otherwise attempt to interfere with the proper working of Levo.
    • You agree not to use Levo
      • For the purpose of exploiting, harming or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information or otherwise.
      • To engage in any other conduct that restricts or inhibits anyone's use or enjoyment of Levo, or which, as determined by us, may harm EPFL or users of Levo or expose them to liability.
    • You are responsible to ensure the backup of your Uploaded Data, if required.

Although we maintain necessary safeguards to protect your data, we may prosecute any parties who illegally attempt to mine member data from this site.

We reserve the right to suspend or terminate your use of Levo at any time without notice if we determine any abuse in your use of Levo.


6. Eligibility and User Responsibility for Account Security

You must be 18 years or older to use Levo. If you are younger than 18 years old, please do not use Levo.

You must be employed by a start-up, a start-up investor or a start-up accelerator.

Throughout Levo, you may be asked for registration details, contact details and other information. It is required that the information provided is current, truthful and current. The information you provide on Levo will be treated according to our Privacy policy, to which you fully agree when providing your information. In case you are referred to Levo by your investor or accelerator with whom you are involved with, you accept that the information you provide to Levo will be shared with them to a certain degree.

You are responsible for keeping your account secure. Usernames and passwords are for personal use only. In particular you shall not disclose to others your account identification and password and shall protect that information from access by others. You also agree to log out of your account at the end of each session.

If a third party obtains access to your account, if you notice any unusual activity on your user account, or a breach of your password or username, you must inform us immediately.


7. LEVO management

We reserve the right, but not the obligation, to:

  1. monitor Levo for violations of these Terms of Use;
  2. take appropriate legal action against anyone who, in our sole discretion, violates the law or these Terms of Use, including without limitation, reporting such user to law enforcement authorities;
  3. in our sole discretion and without limitation, refuse, restrict or terminate access to, any user of Levo who does not comply with these Terms of Use;
  4. in our sole discretion and without limitation, notice, or liability, to remove from Levo or otherwise disable all files and content that are excessive in size or are in any way burdensome to our systems;
  5. otherwise manage Levo in a manner designed to protect our rights and property and to facilitate the proper functioning of Levo.

8. Finance

The access to LEVO Operational Assessment and Impact charting is delivered on a free basis. Further services such as personalized consulting for setting goals and further functionalities that might be developed in the future may be subject to payment.


9. Data protection

We will use your personal data in accordance with the Privacy policy available at https://startup.levoframework.com/ and in compliance with applicable laws and regulations. This privacy policy forms part of these Terms of Use.

By uploading your documentation or content you represent and warrant that you duly informed the data subjects and have a duly legal ground to provide the personal data to Levo.


10. Intellectual Property

Except for Uploaded Data by a user, all the content present on Levo, including text, features, and functionalities and related Intellectual Property Rights are owned by us or other service providers. We reserve all rights including without limitation all copyrights contained in Levo, including the “Levo” name and logos and all rights on all our trademarks. You may not duplicate, copy, or reuse any portion of Levo without our express written permission.

You must not access or use for any activity outside of the Purpose or for any commercial purposes any part of Levo or any services or materials available through Levo.

If you print, copy, modify, download, or otherwise use or provide any other person with access to any part of Levo in breach of the Terms of Use, your right to use the Levo will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. Any use of Levo not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark, and other laws.

By uploading your documentation or content you represent and warrant that you own all rights to such content, and/or it does not infringe any third-party rights. We do not check Uploaded Data for appropriateness, violations of copyright, trademarks, other rights or violations. We invite everyone to report violations together with proof of ownership as appropriate. Reported violating content may be removed or disabled.

You hereby grant us a worldwide, royalty-free, non-exclusive, irrevocable license to use, reproduce and share the Uploaded Data (with the exception of personal data) for the Purpose and also for non-commercial research activities outside the Purpose.

Any analysis performed by us based on your Uploaded Data, whether in relation to the Purpose or for non-commercial research activities outside of the Purpose, shall belong to us.

Analysis performed by us based on your Uploaded Data and in relation to the Purpose (hereafter “Levo Analysis”) shall be communicated to you by us in PDF, CSV, or other similar file that you can download. Such Levo Analysis may be shared with the user’s respective start-up’s investors or accelerators, provided that you acknowledge Levo and EPFL’s work on such Levo Analysis. We may also share such Levo Analysis with your start-up’s respective investors or accelerators in case you have been referred and connected to them before the assessment.

As a start-up investor or accelerator, you acknowledge that we may share your Uploaded Data to the start-ups in your respective portfolio.


11. Limited Liability

We cannot be liable for any breach of our obligations in case of force majeure.

Levo is provided "as is", without warranty of any kind, express or implied, including but not limited to the warranties of merchantability, fitness for a particular purpose, accuracy, correctness and non-infringement.

We do not warrant that Levo will meet your requirements; that Levo will be uninterrupted, timely, secure, or error-free; that the information provided through Levo is accurate, reliable or correct; that any defects or errors will be corrected; that LEVO will be available at any particular time or location; or that Levo is free of viruses or other harmful components. You assume full responsibility and risk of loss resulting from your downloading and/or use of files, information, content or other material obtained from the Levo. Furthermore, we cannot be responsible for the content provided by any user.

In the case of any cyber-attack, we disclaim all liabilities for any losses or damages caused by such an intrusion, except in the case of serious misconduct on our part.

special, consequential or exemplary damages, including but not limited to damages for loss of profits, goodwill, use, data or other intangible losses, resulting (even if we have been advised of the possibility of such damages), from your use of Levo. You agree to hold us harmless and indemnify us in case of any claims related to your use of Levo.


12. Links to Other Web Sites

Levo may contain links to third-party web sites or services that are not owned or controlled by us. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party web sites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services. We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.


13. Social media

You may mention Levo in your start-up’s social media, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, or suggest any form of false association, approval, or endorsement by us.


14. Changes

We reserve the right, at our sole discretion, to modify or replace these Terms at any time without notice. By continuing to access or use our Levo after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using Levo.

There may be information on Levo that contains typographical errors, inaccuracies, or omissions that may relate to Levo, including descriptions, pricing, availability, and various other information. We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information on Levo at any time, without prior notice.


15. Termination

We may terminate or suspend access to our Services immediately, without prior notice or liability, for any reason whatsoever.


16. Governing Law - Place of Jurisdiction

These Terms and any claims raised in connection with Levo are governed by Swiss law, excluding its conflict of rules provisions. You agree to submit to the exclusive jurisdiction of the cantonal court of the Canton of Vaud located in Lausanne, Switzerland.


17. Contact Us

If you have any questions about these Terms, please contact us at hello@levoframework.com (please include “Terms of Use” in the subject).

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