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		Entrepreneurship Sports Generation
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PRIVACY POLICY

Effective Date:

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October 1, 2020
Last Updated: October 1, 2020

INTRODUCTION

NestGSV Inc. and tGELF and (dba GSVlabs) and The Global Education & Leadership Foundation (TGELF) and their subsidiaries and affiliates (collectively, “GSVlabs and tGELF”TGELF”, “us”, “we” or “our”) created this privacy policy (“Privacy Policy”) to advise you about GSVlabs’ and tGELF’s TGELF’s information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights and how the law protects you. We urge you to read this Privacy Policy carefully. Please also review our Terms of Use [LINK], which govern your use of the Sites (as defined below).

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This Privacy Policy applies to https://esg.gsvlabsportal.com and esgx.global and all other websites, features, or online services that are owned or controlled by NestGSV Inc. and the tGELF TGELF Foundation and that post a link to this Privacy Policy (collectively, the “Sites”), whether accessed via computer, mobile device, or otherwise. For convenience, we refer to the Sites and our services collectively as the “Service”. Note, however, this Privacy Policy does not apply to your use of unaffiliated websites that link to our Sites. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites.

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The Service is not intended for children and we do not knowingly collect information relating to children. If NestGSV Inc. and/or the tGELF TGELF Foundation discovers that it has inadvertently collected Personal Information from anyone younger than the age of 16, it will delete that information.

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We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Sites. Any such change, update or modification will be effective immediately upon posting on the Sites. However, unless you consent, NestGSV Inc. and the tGELF TGELF Foundation will not use your Personal Information in a manner materially different than what was stated in our posted Privacy Policy at the time your Personal Information was collected. Please check this Privacy Policy regularly to ensure you are aware of any changes in our practices. If we make material changes to this Privacy Policy, we will notify you by email or through the Sites.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

E.

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 THIRD PARTY CONTENT, LINKS TO OTHER WEBSITES, AND NESTGSV INC. AND

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TGELF FOUNDATION CONTENT FOUND OUTSIDE THE SITES

The Sites may include links to third-party websites, embedded content, plug-ins and applications and certain content on the Sites may be hosted and served by third parties that NestGSV Inc. and the tGELF TGELF Foundation does not control. Clicking on those links, viewing or accessing embedded content (such as videos, gifs, or audio files), or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

In addition, NestGSV Inc. and the tGELF TGELF Foundation content may be included on web pages and websites that are not associated with NestGSV Inc. or the tGELF TGELF Foundation and over which we have no control. These third parties may collect data through the use of their own cookies, web beacons or other technology, independently collect information or solicit Personal Information, and may have the ability to track your use of their websites and services. NestGSV Inc. and the tGELF TGELF Foundation are not responsible for the privacy practices or the content of any third party.

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• Identity Information includes name, username or similar identifier, company name, title, date of birth, and gender.Demographic Information includes zip code, age and/or income.Contact Information includes billing address, mailing address, email address and telephone numbers. Financial Information includes bank account and payment card details.Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us. Technical Information 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 or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access the Sites. Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, and feedback. Usage Data includes information about how you use our Service, products and services, including all of the areas within our Sites that you visit or use, and the time of day you visited the Sites, among other information. Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences. Location Information includes information about your location using a variety of technologies, such as GPS, IP address, and connected or nearby Wi-Fi networks. User Content Information includes text (including questions, comments, and suggestions), pictures, audio, videos, or other content (collectively, "User Content") you share by participating and posting content publicly in reviews, interactive features, or other communication functionality (“Community Features”). Business Information includes text, images, or video pertaining to your company or project that you share by participating and completing the competition application.    

We also collect, use and share Aggregated Information such as statistical or demographic information for any purpose. Aggregated Information may be derived from your Personal Information but is not considered Personal Information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information that will be used in accordance with this Privacy Policy.

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• Community Features. The Service may provide you the opportunity to participate and post User Content publicly through reviews, surveys, interactive features, or other communication functionality (“Community Features”). We may provide functionality for you to submit or post User Content through Community Features, by linking the Sites to a third party service, or otherwise. Please note that certain information, such as your name, may be publicly displayed on the Sites along with your User Content. User Content consisting of uploaded files may contain metadata, which may contain Personal Information or other information about or relating to you. You may wish to remove metadata from your files before transmitting such files to NestGSV Inc. and the tGELFTGELF Foundation. Note that anything you post through Community Features is public – others will have access to your User Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information, that information will be considered public information and the protections of this Privacy Policy will not apply. If you submit User Content, it may be published online or offline at any time. In addition, we may use your User Content and any excerpt from your User Content in connection with our advertising, marketing, publicity and promotional activities.
• Third parties or publicly available sources. We may receive Personal Information about you from various third parties (including your employer, broker, host, parent or guardian) or public sources. For example, if you are on another website and you opt-in to receive information from us, the other website may forward your contact and other information to us so that we may contact you as requested. If your company has provided you with access to the Service, we may receive information about you from your company. We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Service. In those cases, we will apply this Privacy Policy to the combined information. Examples of third party sources include:Technical Information from the following parties:analytics providers; advertising networks; and search information.Contact, Financial and Transaction Information from providers of technical, payment and delivery services.Contact and Financial Information from companies that facilitate making reservations.Identity and Contact Information from publicly available sources.

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Certain functionality on the Sites may permit interactions that you initiate between the Sites and a third party website or service (“Third Party Interactions”). Examples of Third Party Interactions may include technology that enables you to “like” or “share” content from the Sites on or to other websites or services; to transmit content to the Service from your account on a third party website or service; and to otherwise connect the Service to a third party website or service, such as through an application programming interface (API) made available by NestGSV Inc., the tGELF TGELF Foundation or a third party.

If you choose to use Third Party Interactions, information you post or provide access to may be publicly displayed on the Sites or by the provider of the feature that you use. Similarly, if you post information on a third party platform that references the Service (e.g., by mentioning the Service or using a hashtag associated with the Service in a tweet or status update), your post may be published on our Sites in accordance with the terms of the third party website or service. In addition, both NestGSV Inc., the tGELF TGELF Foundation and the third party may have access to certain information about you and your use of the Service and the third party website or service. In addition, we may receive information about you in connection with other users’ use of Third Party Interactions (e.g., we may learn that you are a “friend” or “connection” of the third party or receive other information about you that the other user enables us to receive).

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V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING

NestGSV Inc. and the tGELF TGELF Foundation work with certain third parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Sites, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to one of the Sites, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising.

These third parties may also transfer Device Identifier and Usage Data to other third parties where required to do so by law, or where such third parties process analytics information on their behalf. Each of these third party’s ability to use and share Device Identifier and Usage Data is restricted by their respective Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by these third parties in the manner and for the purposes set out above. For a full list of third party analytics services, please contact us at esg@gsvlabs community@gsvlabs.com.

For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:

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We may use the information we collect about you, including Personal Information and Usage Data for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We use your personal information:

• to provide, operate and improve the Service; to identify you as a user in our system; to process a transaction you initiate, process payments and provide accurate billing and shipping; to process your registration with the Sites, including verifying your Contact Information is active and valid; to bill you for NestGSV Inc. and the tGELF TGELF Foundation products and services; to contact you with regard to your use of the Sites and, in our discretion, changes to the Sites policies or functionality; to communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages; to communicate with you about events or contests in which you participate; to understand your needs and interests, and personalize your experience with the Service; and to respond to your requests, questions and feedback related to the Service.

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To send you marketing and promotional communications. We may send you promotions, newsletters or other marketing communications, information about NestGSV Inc., the tGELF TGELF Foundation or our products or services, or promotional material from some of our advertisers or third-party business partners. We may also communicate with you to market our products or services, including recommending products or services that might be of interest to you, but you may opt out of receiving them as described in the Opting Out section below.

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You will receive marketing communications from us if you have requested information from, purchased goods or services from us, or if you provided us with your details when you registered out our Sites and, in each case, you have opted in to receive that marketing.

B. THIRDTHIRD-PARTY AND AFFILIATE MARKETING

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Google Tag Manager

AWS

Acuity

Slack

The GEN Accelerate ULead Platform

Functionality/performance

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A. INTERNAL THIRD PARTIES

NestGSV Inc. and the tGELF TGELF Foundation may disclose information including Personal Information with its parent, subsidiaries and affiliates for a variety of purposes, including for business, operational, and marketing purposes. NestGSV Inc. and the tGELF TGELF Foundation may, and reserves the right to, share your information with any other company that is not presently, but becomes, a NestGSV Inc. or tGELF TGELF Foundation parent, subsidiary, or affiliate.

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• to comply with a valid legal inquiry or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
• to obtain or maintain insurance coverage, manage risks, obtain professional advice, or establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure;
• to protect the safety, interests, rights, property or security of NestGSV Inc., the tGELFTGELF Foundation, you, or any third party;
• to respond to a breach or attempted breach of the security of our Sites;
• to defend or assert our legal rights pursuant to any of the Sites’ Terms of Use, any policies applicable to the Sites, or any other agreement you may have with NestGSV Inc or the tGELFTGELF Foundation.; or
• at the request of governmental authorities conducting an investigation.

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C. SHARING BETWEEN NESTGSV INC. AND tGELF COMPANIES; BUSINESS TRANSFERS

NestGSV Inc. and the tGELF TGELF Foundation may also disclose and transfer your Personal Information: (i) to a subsequent owner, co-owner or operator of the Sites or applicable database, or of our products or services; (ii) if NestGSV Inc. or the tGELF TGELF Foundation (or any of their affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of NestGSV Inc.’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.

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You can review, request access to, update, correct or delete your Personal Information by contacting us at esg@gsvlabs community@gsvlabs.com.

You may request deletion of your Personal information by contacting us and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain information for fraud prevention or similar purposes. Also, note that we may need to delete your user account in order to delete your Personal Information.

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IX. DATA SECURITY

NestGSV Inc. and the tGELF TGELF Foundation take commercially reasonable security measures to help protect your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be completely secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Sites and provide us with your information at your own risk.

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The Sites are operated in the United States, and NestGSV Inc., the tGELF TGELF Foundation and third party service providers and partners operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Sites, or providing us with any information, you consent to this transfer, processing and storage of your information in countries where the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

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Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding NestGSV Inc. and the tGELF’s TGELF Foundation’s disclosure within the immediately preceding calendar year of that California resident’s Personal Information to third parties (and in some cases, affiliates) for their direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request to the following email address: esg@gsvlabscommunity@gsvlabs.com or write or write to us at the following mailing address: GSVlabs, 2955 Campus Dr #110, San Mateo, CA 94403. You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.

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If you have any questions or concerns regarding this Privacy Policy or our practices, please feel free to contact us via email at esg@gsvlabs community@gsvlabs.com.  We We can also be contacted by mail at:

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Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.

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C. CONTROLLER

NestGSV Inc. and the tGELF TGELF Foundation are made up of different legal entities.This Privacy Policy is issued on behalf of NestGSV Inc.. the tGELF TGELF Foundation and their subsidiaries and affiliates so when we mention “GSVlabs”, “tGELF” “TGELF” “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company responsible for processing your data. The tGELF TGELF Foundation is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

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We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at esg@gsvlabs community@gsvlabs.com.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

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If you wish to exercise any of the rights set out above, please contact: esg@gsvlabs community@gsvlabs.com.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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