Privacy Policy

As of September 18, 2024

Creative Destruction Lab (“CDL”, “we”, or “us”) is a seed-stage program for massively scalable, science- and technology-based ventures that employs an objectives-focused mentoring process with the goal of maximizing equity-value creation (the “CDL Program”). CDL operates in collaboration with educational institutions worldwide (each a “CDL Site”) to deliver the CDL Program in specialized technology or industry-specific focus areas (each a “Stream“). A list of CDL Sites is available at https://creativedestructionlab.com/locations/. CDL was founded at the Rotman School of Management at the University of Toronto.

We value and respect your privacy and have prepared this Privacy Policy to describe how CDL collects, uses and discloses personal information when you apply to or participate in the CDL Program, use our CDL Community Portal (the “Portal”), visit our website at creativedestructionlab.com (the “Website”), or otherwise contact or interact with us, including as a mentor, partner, venture, guest, or student (collectively, “CDL Stakeholders”). 

Data sharing across CDL Sites is critical to the effectiveness of the CDL Program. If you apply to or otherwise participate in the CDL Program, CDL will collect and share your personal information with the CDL Site(s) for which you have applied or are participating, and will also collect personal information from these CDL Site(s) for the purposes set out in this Privacy Policy or as you otherwise consent. CDL may also share or make your personal information accessible to other CDL Sites to facilitate your participation in the CDL Program and to comply with funding commitments, and as otherwise described in this privacy policy. 

Please note that CDL Sites may collect, use and disclose additional personal information in the course of its interactions with CDL Stakeholders. For information about the treatment of your personal information by CDL Sites, please refer to the respective educational institution’s privacy policy.

Table of Contents

• How We Collect Personal Information
• Collection, Use and Sharing of
  Personal Information for CDL Program Participation
• Other Collection and Use of Personal Information
• Other Sharing of Personal Information
• Data Location
• Information About Our Website
• Interest-Based Advertising
• Safeguards and Retention
• Your Rights and Choices
• Individuals Inside the EEA
• Updates to the Privacy Policy
• Contact Us

How We Collect Personal Information

• CDL collects personal information directly from you, as well as indirectly from CDL Sites that you interact with. We may also collect personal information about you from other CDL Stakeholders such as mentors and partners, as well as from publicly available sources such as LinkedIn. We also collect information automatically when you visit our Website or Portal, as described under “Information About Our Website” below. 
• If you provide us with personal information about any other individual (such as your co-founder(s) or partner(s)), we rely on you to confirm that you have obtained the consent of such individual(s) prior to providing any personal information to us.

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Collection, Use and Sharing of Personal Information for CDL Program Participation

Given the global nature of the CDL Program, your personal information will be collected, used and disclosed by and across CDL and CDL Sites to administer your participation in the CDL Program, administer and improve the CDL Program, and communicate with you, as described in further detail below. 

Applying for the CDL Program (Ventures): 

• If you are a founder and apply to a CDL Site or Stream, CDL collects personal information about you and your employees through the CDL Application Portal, and other online sources, such as: first and last name, email address, country, postal code, education history, work experience, financial information about the venture, venture technology, additional information relating to your venture and why you are applying for the CDL Program (“Venture Data”). 
• We use this information for the purposes of processing and responding to your application, including assessing the suitability of your venture for acceptance into the CDL Program and connecting you with an appropriate CDL Site and Stream. 
• To help ensure an equitable opportunity for CDL Sites to recruit Site and Stream-specific ventures, Venture Data is entered into a centralized database that is accessible to all CDL Sites for evaluation, selection and program participation purposes and you may be contacted by any CDL Site for these purposes. 
• We also use this information to identify, evaluate and better understand factors that contribute to a successful venture and to administer and improve the CDL Program and your participation in the CDL Program.

Applying to the CDL Apprentice Program: 

• If you apply to participate in our Apprentice Program at a CDL Site, CDL will collect information such as your first and last name, email address, home country and city, school name, school grade, month and year of birth, confirmation that you meet program eligibility requirements (which may include programs only available to certain populations), parent/guardian’s information, and the responses you provide to questions about your interest in the Apprentice Program.
• CDL will use this information to process and respond to your application, assess your suitability and eligibility for acceptance into the Apprentice Program and ensure proper advancement in the program. If you sign-up to participate in an in-person event, CDL will share your contact information with the CDL Site hosting the virtual event to facilitate your participation in the event. 
• If you are accepted and enrolled into the Apprentice Program, CDL will collect and use information about your participation in the program in order to administer your participation, facilitate your attendance in future Apprentice Program events and communicate with you about your participation in the program.  This information is not shared with other CDL Sites.

Participating in a CDL Pedagogy Program at your University

• CDL Sites may offer their own CDL education programs for credit. You are required to sign-up for these programs through the associated university. CDL will collect limited personal information such as name, email address, and university to administer your participation in the pedagogy program and provide you with access to the Portal.  

Participating as a Mentor in the CDL Program:

• If you are invited to be amentor or mentor candidate in the CDL Program, we will collect information you provide to us or a CDL Site including information about you, your skills and background. We may also collect information through our onboarding call with you as well as other information that may be available on public websites such as LinkedIn. 
• We use this information to administer your participation as a mentor, administer and improve the CDL Program, and communicate with you about the CDL Program as well as to help us to tailor your experience in the CDL Program (e.g., match you with appropriate Ventures).
• Mentor information is stored in the CDL central database and accessible to CDL Sites to ensure that mentors or mentors candidates are not contacted or recruited by multiple CDL Sites.

Community Portal:

• We provide CDL Stakeholders with access to the Portal for the duration of each program year that can be used to obtain information about CDL Sessions (e.g., personalized schedules) and CDL Stakeholders (e.g., venture documents and stakeholder profiles), and to input comments (e.g., notes and endorsements) during and after CDL Sessions. We use information from the Portal to administer and improve the CDL Program.
• In order to access the Portal, CDL Stakeholders are required to create an account with a username and password. Each user is required to create a profile page through the Portal during their first log-in each program year. As part of the venture profile update, CDL may collect your venture’s address, website, description, industry and logo. As a part of the stakeholder profile update, CDL may collect your profile photo, interests and motivations. All CDL stakeholders have access to the venture and stakeholder profile pages basic information (e.g., venture name, overview and website, as well as stakeholder name, bio and LinkedIn profile) through the Portal. Access to additional Session-specific information within the Portal is limited by Session-specific invitations and Stakeholder-specific role (e.g., financing rounds for CDL mentors only).
• When you access the Portal, we may also collect certain information automatically including the IP (Internet protocol) addresses of all visitors and other related information such as login history, browser type and operating system. We use this information to provide user support, help us understand our portal activity and to monitor and improve our Portal, as described under “Information About Our Website”, below.

Participating in the CDL Program: 

• Once you are accepted into a CDL Site or Stream, we also collect information about your participation in the CDL Program and the progress of your venture from the CDL Site(s) with whom you interact, such as session transcripts, venture documents, objectives, successes, challenges, contact information, session registration, financing information, attendance and participation information.  This information is entered into the CDL central database and is used to administer participation in the CDL Program, communicate with CDL Stakeholders, analyze and improve the CDL Program, and prepare session-specific informational materials for stakeholder-specific access by CDL Stakeholders on the  Portal. We also collect information that other CDL Stakeholders provide about your venture. 
• We use this information to administer your participation in the CDL Program, communicate with you about the CDL Program and upcoming events and sessions, and to identify, evaluate and better understand factors that contribute to a successful venture and to administer and improve the CDL Program.
• We collect transcripts and notes from CDL Sessions from CDL Sites and share this data with Rotman School of Business at the University of Toronto as described under “Sharing with Funding Partners.”  

Participation in CDL Sessions and Events

• CDL Stakeholders may be invited to CDL Sessions as a part of the Program, or other events organized and hosted by us (e.g. CDL’s annual Super Session showcasing its graduating early-stage technology companies).
• If you register for a Session or other event hosted by CDL, CDL will collect your first and last name, email address, organization name, and title in order to facilitate your registration and communicate with you about the Session or event, along with attendance and other information you provide (e.g., meal preferences and survey feedback) in order to administer and improve Sessions or other events. 
• CDL Sessions may be recorded (audio and video) for record keeping purposes and to administer and improve the CDL Program. If you do not wish to be recorded, you can request to sit in an area out of viewing range of the cameras (for in-person sessions) or you can turn off your camera for virtual sessions.

Sharing with CDL Sites and Stakeholders:

• As described above, personal information and venture information is made available to CDL Sites including through the CDL central database. CDL also shares aggregated data and reports with CDL Sites.  
• If you are a current or graduate venture in the CDL Program, we may share your contact information and information about your venture with CDL Stakeholders such as mentors and partners. CDL Stakeholders will use this information to communicate with you, view open financing rounds as it relates to your venture, create ongoing engagements and endorsements, and develop relationships that may benefit you and/or your venture. 

Sharing with University of Toronto 

• We collect transcripts and notes from sessions from CDL Sites and share this data with our founding CDL Site, the Rotman School of Business at the University of Toronto in order to fulfill the conditions of funding that Rotman receives in connection with the CDL Program. This information is analyzed (along with other information such as Venture application data and session participation data) and used for research and analysis in order to identify, evaluate and better understand factors that contribute to a successful venture and develop models to predict the success of ventures and founders. This data is not shared with other CDL Sites.  

Sharing with Funding Partners

• We may share aggregated information about CDL applicants and Program participants with our funding partners for the purpose of fulfilling the conditions of funding CDL receives to run CDL Programs.  

Sharing with Academic Researchers 

• We may share de-identified data about CDL applicants and Program participants with academic researchers who have obtained research ethics board (or equivalent) approval for social science and entrepreneurship research purposes. This de-identified information may include data collected from founders such as education history, work experience, and financial information about the venture, and any other information provided to us in connection with the CDL Program. CDL does not share sensitive technical information or intellectual property relating to the venture with any researchers.

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Other Collection and Use of Personal Information 

Subscribe to our Email Updates 

• If you subscribe to receive the CDL Monthly Newsletter or other email updates, we collect your email address in order to send you monthly newsletters. You may also sign-up to be notified when applications for CDL Program open-up. When you create a profile on the Portal, we will send you the CDL Family Newsletter which includes news and updates from the larger CDL community. 
• If you no longer wish to receive any of these communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of the emails. Alternatively, you can opt out of receiving our email updates by contacting us at the contact information under “Contact Us” below. 
• Please note that you may continue to receive certain informational, transactional or account-related communications from us. You may also separately sign-up to receive email updates from CDL Sites. To opt-out of these communications, please contact the CDL Site directly.  
• If you subscribe for our email updates, we may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt out of the use of your information for such purposes, please contact us at privacy@creativedestructionlab.com.

Surveys  

• From time to time, we may offer you an opportunity to participate in one of our surveys about your participation in the CDL Program, Stream, Session, or other event. The information obtained is used to help us understand our participants and to enhance our Program and as otherwise described at the time of the survey.

Job Applicants

• In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information to process your application, assess your suitability for employment and to communicate with you about current and future career opportunities. With your consent, we may also obtain information from third parties such as employment or educational references and background screening companies.

Contact Us 

• When you contact us with a comment, question or complaint by email, phone, or the “Contact Us” form on our Website, you may be asked for information that identifies you, such as your name, address and a phone number, along with additional information we need to help us promptly answer your question or respond to your comment.  We may retain this information to assist you in the future and to improve our customer service and service offerings.

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Other Sharing of Personal Information

We do not sell, rent or disclose your personal information to third parties without your consent, except as described in this Privacy Policy or as required or permitted by applicable law.

• Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers (including related entities) to provide services such as administering our surveys, hosting the Website, providing marketing, advertising, data processing, and analytics services, developing and delivering software, providing cloud storage services, providing virtual meeting software, providing customer relations management (CRM) tools, providing tools to administer and improve the CDL Program, providing data management, software administration, consulting and user management services, and sending our marketing communications. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.
• Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
• Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Creative Global Projects or as part of a corporate reorganization or other change in corporate control.

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Data Location

• CDL and our service providers may transfer or store your personal information outside the country, province, or state you reside in (which may include transfers outside of Quebec for Quebec residents). In addition, given the global nature of CDL, your personal information may be shared with CDL Sites worldwide (see current list of locations here). For more information about our use of third-party service providers (including the use of service providers outside your country), please contact us as described under the “Contact Us” section, below. 

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Information About Our Website

• Visiting our Website:  In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website (including the Portal) and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
• Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. Other similar files such as clear GIFs, web beacons and pixel tags work in the same way and we use the word “cookie” in this Privacy Policy to refer to all files that collect information in this way. Cookies may provide us and our service providers with information that we will use to personalize our Website or Portal in accordance with a user’s preferences. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features. For more information, see our Cookies and Interest-Based Advertising Policy. 
• Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
• Third Party Links:  Our Website may contain links to other websites that CDL does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

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Interest-Based Advertising

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. For more information on Interest-Based Advertising, please see our Cookies and Interest-Based Advertising Policy.

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Safeguards and Retention

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements. Access to information contained within the CDL central database is limited to staff members at CDL Sites on a need-to-know basis for the purposes set out above. 

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Your Rights and Choices

• Subject to limited exceptions under applicable law, you have the right to access, update, and correct inaccuracies in your personal information in our custody and under our control, and to withdraw consent to our collection, use and disclosure of your personal information (subject to legal and contractual restrictions). 
• You may request access, updating and corrections of inaccuracies in your personal information in our custody or control, or request to withdraw your consent, by contacting us at the contact information under “Contact Us” below. 
• We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
• As indicated above, if you have signed up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below. 

To adjust your preferences or opt-out of our use of cookies, see our Cookies and Interest-Based Advertising policy.

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Individuals Inside the EEA

When we process your personal information, we do so with the following legal bases.

Data processing purpose	Data categories	Legal basis
Processing and responding to your application to join a CDL Program including assessing the suitability of your venture for acceptance into the Program and connecting you with an appropriate CDL Site and Stream, and administering and improving the CDL Program	First and last name, email address, country, postal code, education history, work experience, financial information about the venture, venture technology, additional      information relating to your venture and why you are applying for the CDL Program	CDL’s, and the CDL Sites’, legitimate interests in assessing applications to, and administering and improving, the CDL Program.
Administering your participation in the CDL Program, and sharing the results of the CDL Program with funding partners and academic researchers, and administering and improving the CDL Program	Session transcripts, venture documents, objectives, successes, challenges, contact information, session registration, financing information, attendance and participation information.	Your consent to our collection and use of this information, in relation to session registration and session transcripts or where we otherwise seek your consent. In respect of other data, our legitimate interests in offering, administering, and improving the CDL Program, and the legitimate interests of funding partners and academic researchers in analysing information about the CDL Program.
Processing and responding to your application for, and assessing your suitability and eligibility for acceptance into, the Apprentice Program and ensuring proper advancement in the program.Administering your participation, facilitate your attendance in future Apprentice Program events and communicate with you about your participation in the program.	First and last name, email address, home country and city, school name, school grade, month and year of birth, confirmation that you meet program eligibility requirements (which may include programs only available to certain populations), parent/guardian’s information, and the responses you provide to questions about your interest in the CDL Apprentice Program	CDL’s, and the CDL Sites’ legitimate interests in assessing applications to, and administering, the Apprentice Program.
Administering your participation in the CDL Program as a mentor and communicating with you about the CDL Program, and administering and improving the CDL Program	Information about you, your skills and background. We may also collect information through our onboarding call with you as well as other information that may be available on public websites such as LinkedIn.	Your consent. Our legitimate interests in identifying suitable mentors for the CDL Program and administering and improving the CDL Program.
Enabling CDL Stakeholders’ use of the Portal, and administering and improving the CDL Program	Username, password, profile photo, interests and motivations.IP (Internet protocol) addresses of all visitors and other related information such as login history, browser type and operating system.	Our legitimate interests in operating the Portal to CDL Stakeholders and administering and improving the CDL Program.
Running CDL Sessions and Events, and administering and improving the CDL Program	First and last name, email address, organization name, and title. Attendance and other information you provide (e.g., meal preferences and survey feedback)	Our legitimate interests in running the CDL Sessions and Events , and administering and improving the CDL Program.
Sending you our email newsletters	Information about your subscription to our email newsletters	Your consent.
Processing your job application	Name, resume, any other materials you provide to us	Our legitimate interests in assessing your suitability for employment by us.
Responding to your queries	Information you submit to us through the contact form on our Website or otherwise provide to us when you contact us, such as your name, email address, and your question	Our legitimate interests in responding to your question.

You may be entitled, in accordance with the applicable law, to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your personal information. You also have the right to lodge a complaint with your data protection authority. Where we use your personal information on the basis of your consent, you have the right to withdraw this consent at any time without affecting the lawfulness of the processing conducted on the basis of the consent prior to its withdrawal. Where we process your personal information in furtherance of entering into a contract with you, you are not obliged to provide such personal information, however, failure to do so may not allow us to consider your application for current and future career opportunities with us.

As described in this privacy policy, we may transfer your personal information to third parties. Some of these third parties may be located in countries such as the United States, other than your own, whose privacy and data protection laws may not be equivalent to those in your country of residence. When we transfer your personal information to other countries, including the United States, we apply appropriate safeguards, to protect your personal information and comply with applicable laws, such as standard data protection contractual clauses issued by the European Commission’s Implementing Decision (EU) 2021/914 for controller-to-processor transfers, copies of which can be obtained from us upon request.

Where you provide us with information about, or on behalf of, any other individual or third party, it is your responsibility to ensure that they are made aware of this privacy notice.

We retain your personal information for the period that we require that personal information to achieve the purposes described in the “Collection, Use and Sharing of Personal Information for CDL Program Participation”, or longer where we are required to do so under applicable law or to establish or defend a claim or otherwise protect our legal rights. 

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Updates to the Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes, but we will notify you in relation to material changes where feasible. We will indicate at the top of this Privacy Policy when it was most recently updated.

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Contact Us

The CDL Program is operated by Creative Global Projects, a not-for-profit organization. If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers treat your personal information, or if you wish to exercise any of your rights and choices over your personal information, please contact the Creative Global Projects Privacy Officer at privacy@creativedestructionlab.com. 

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