pepelwerk, LLC ("Company", "We" or “US”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the privacy practices of the company. Including the types of information, we may collect that you provide voluntarily and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:
All of the above are referred to as “Touchpoints”
It does not apply to information collected by:
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.
This policy may change from time to time. Your continued use of the Company’s service (online or offline), or viewing any digital or printed works of the Company, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Policy on Users who are considered Minors/Children
Our services are not intended for children who are not of legal working age according to the governing laws of the country of citizenship and the country of employment.
Under no circumstances should a user who is under the age of 16 years enroll as user or engage with the Company in any way.
If you are between the ages of 16 and 18, or considered a minor dependent on parental or guardian consent to engage in work activities, then you must get the consent prior to accepting working opportunities. Some personal information, because of the sensitive nature, will require consent for legal guardians before the minor can proceed with Company services. Any data that a minor voluntarily provides as the user is used to benefit the user in getting connected with work.
You must attest that you have received such permission when you complete registration for service, stating that “I am a minor between the ages of 16 and 18 years and have permission from my legal guardian to participate in services from the Company.”
If we learn we have collected or received personal information from a child under legal working age without verification of parental consent, we will delete all of the users information. If we have reason to believe that any user is under the of 16, the account will immediately be deleted along with any user information.
If you believe we might have any information from or about a minor, please contact us immediately at email@example.com
Information We Collect About You and How We Collect It
We collect several types of information from and about potential users and registered users through our Touchpoints including information:
We collect this information:
Information You Provide to Us. The information we collect on or through our Touchpoints may include:
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
The company does not sell advertising or the access to our users information. However, while we apply every reasonable preventive measure to secure our environment, there will always be assholes and we cannot control all cyber activities that can cause untended exposure to our user’s data.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you.
We will use the information you voluntarily provide and that we have collected from you to enable us to display better user experience.
Retention of Your Information
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or send in writing to the address provided on the contact page of the website.
Data Across Boarders
Pepelwerk LLC is global organization and provides a global service. Sharing data cross-border is essential to our Services so that can provide the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By using our services you understand that we transfer your Personal Data globally.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.
Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here.
The content made available through our website, does not have any age limitations, however, there may be age limitations for the use of our services and software and sometimes additional terms or requirements will apply. By using this Website, you represent and warrant that you are of legal age to form a binding contract with the Company, or have obtained consent from a legal guardian, and meet all of the foregoing eligibility requirements. If you do not meet all of these requirements, you must not access or use the Website or any of the Company’s products or services.
Guest or User Intent
Guests, are people, companies, organizations or software systems who view the Company’s website, data, content, services or products (digital or non-digital) without registering for use. Users, are people, companies or organizations, who register to gain access to the services and products of the Company and view website, data and content. Both Guests and Users agree to use the products, information and services provided by the company for good intention. This means, if you are here to hack, harm, steel, manipulate our data or our user’s data, you should not continue on this website. Meaning we do not give anyone with that type of intent to infringe about our rights or out users right to digital safety. Your continued use of the website means that you understand and will comply with good intent policy.
Accessing the Website and Account Security
We reserve the right to withdraw or amend this Website, and any service or material we provide on the Website, in our sole discretion without notice. We will not be liable if for any reason all or any part of the Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts of the Website, or the entire Website, to users, including registered users.
You are responsible for:
If you choose, or are provided with, a user name, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any other person or entity. You also acknowledge that your account is personal to you and agree not to provide any other person with access to this Website or portions of it using your user name, password or other security information. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information.
Intellectual Property Rights
The Website and its entire contents, features and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection and arrangement thereof), are owned by the Company, its licensors or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws.
You must not:
You must not access or use for any commercial purposes any part of the Website or any services or materials available through the Website.
If you wish to make any use of material on the Website other than that set out in this section, please address your request to: email@example.com
The Company name, the terms and slogans, the Company logo and all related names, logos, product and service names, designs and slogans are trademarks of the Company or its affiliates or licensors. You must not use such marks without the prior written permission of the Company. All other names, logos, product and service names, designs and slogans on this Website are the trademarks of their respective owners.
Additionally, you agree not to:
The Website may contain message boards, chat rooms, personal web pages or profiles, forums, bulletin boards, and other interactive features (collectively, "Interactive Services") that allow users to post, submit, publish, display or transmit to other users or other persons (hereinafter, "post") content or materials (collectively, "User Contributions") on or through the Website.
Any User Contribution you post to the site will be considered non-confidential and non-proprietary. By providing any User Contribution on the Website, you grant us and our affiliates and service providers, and each of their and our respective licensees, successors and assigns the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties any such material for any purpose/according to your account settings.
You represent and warrant that:
You understand and acknowledge that you are responsible for any User Contributions you submit or contribute, and you, not the Company, have fully responsibility for such content, including its legality, reliability, accuracy and appropriateness.
We are not responsible, or liable to any third party, for the content or accuracy of any User Contributions posted by you or any other user of the Website.
Monitoring and Enforcement; Termination
We have the right to:
Without limiting the foregoing, we have the right to fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or other information of anyone posting any materials on or through the Website.
YOU WAIVE AND HOLD HARMLESS THE COMPANY AND ITS AFFILIATES, LICENSEES AND SERVICE PROVIDERS FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN BY THE COMPANY/ANY OF THE FOREGOING PARTIES DURING OR AS A RESULT OF ITS INVESTIGATIONS AND FROM ANY ACTIONS TAKEN AS A CONSEQUENCE OF INVESTIGATIONS BY EITHER THE COMPANY/SUCH PARTIES OR LAW ENFORCEMENT AUTHORITIES.
However, we cannot review all material before it is posted on the Website, and cannot ensure prompt removal of objectionable material after it has been posted. Accordingly, we assume no liability for any action or inaction regarding transmissions, communications or content provided by any user or third party. We have no liability or responsibility to anyone for performance or nonperformance of the activities described in this section.
These content standards apply to any and all User Contributions and use of Interactive Services. User Contributions must in their entirety comply with all applicable federal, state, local and international laws and regulations. Without limiting the foregoing, User Contributions must not:
If you believe that any User Contributions violate your copyright, please see our Copyright Policy or instructions on sending us a notice of copyright infringement. It is the policy of the Company to terminate the user accounts of repeat infringers.
Reliance on Information Posted
The information presented on or through the Website is made available solely for general information purposes. We do not warrant the accuracy, completeness or usefulness of this information. Any reliance you place on such information is strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to the Website, or by anyone who may be informed of any of its contents.
This Website may include content provided by third parties, including materials provided by other users, bloggers and third-party licensors, syndicators, aggregators and/or reporting services. All statements and/or opinions expressed in these materials, and all articles and responses to questions and other content, other than the content provided by the Company, are solely the opinions and the responsibility of the person or entity providing those materials. These materials do not necessarily reflect the opinion of the Company. We are not responsible, or liable to you or any third party, for the content or accuracy of any materials provided by any third parties.
Changes to the Website
We may update the content on this Website from time to time, but its content is not necessarily complete or up-to-date. Any of the material on the Website may be out of date at any given time, and we are under no obligation to update such material.
Information About You and Your Visits to the Website
Online Purchases and Other Terms and Conditions
Linking to the Website and Social Media Features
You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part without our express written consent.
This Website may provide certain social media features that enable you to:
Links from the Website
If the Website contains links to other sites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party websites linked to this Website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.
The owner of the Website is based in the state of Texas in the United States. We provide this Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.
Disclaimer of Warranties
You understand that we cannot and do not guarantee or warrant that files available for downloading from the internet or the Website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our site for any reconstruction of any lost data.
WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.
YOUR USE OF THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.
THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE.
THE FOREGOING DOES NOT AFFECT ANY WARRANTIES WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.
Limitation on Liability
IN NO EVENT WILL THE COMPANY, ITS AFFILIATES OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE.
THE FOREGOING DOES NOT AFFECT ANY LIABILITY WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.
Governing Law and Jurisdiction and Arbitration
(a) YOU AND PEPELWERK, INC. ARE AGREEING TO GIVE UP ANY RIGHTS TO LITIGATE CLAIMS IN A COURT OR BEFORE A JURY, OR TO PARTICIPATE IN A CLASS ACTION OR REPRESENTATIVE ACTION WITH RESPECT TO A CLAIM. OTHER RIGHTS THAT YOU WOULD HAVE IF YOU WENT TO COURT MAY ALSO BE UNAVAILABLE OR MAY BE LIMITED IN ARBITRATION.
(b) The arbitration will be administered by the American Arbitration Association ("AAA") in accordance with the Consumer Arbitration Rules (the "AAA Rules") then in effect, except as modified by this Section 12. (The AAA Rules are available at www.adr.org/arb_med or by calling the AAA at 1-800-778-7879.) The Federal Arbitration Act will govern the interpretation and enforcement of this section.
The arbitrator will have exclusive authority to resolve any dispute relating to arbitrability and/or enforceability of this arbitration provision, including any unconscionability challenge or any other challenge that the arbitration provision or the agreement is void, voidable or otherwise invalid. The arbitrator will be empowered to grant whatever relief would be available in court under law or in equity. Any award of the arbitrator(s) will be final and binding on each of the parties, and may be entered as a judgment in any court of competent jurisdiction.
If any provision of this arbitration agreement is found unenforceable, the unenforceable provision will be severed and the remaining arbitration terms will be enforced.
Limitation on Time to File Claims
Waiver and Severability
Your Comments and Concerns
This website is operated by Pepelwerk, LLC all feedback, comments, requests for technical support, copyright infringement claims and other communications relating to the Website should be directed to firstname.lastname@example.org.
The pepelwerk Code of Conduct is one of the ways that we put pepelwerk’s values and hopeful ideals about humanity and business into practice. We believe that everything we do in connection with our work at pepelwerk should be on the up-and-up when it comes to our ethics and how we conduct business. Yes, we are over achievers and set high standards, but we think the results are well worth it- for the people who work for, with and benefit from the things we get to do through pepelwerk.
After reading our Code you might just be so inspired by our emphatic accountability to create the world we want to live in, that you realize your own individual awesomeness and turn away from the dark side. We all have a responsibility for creating the world we want to live in. If you have a question or ever think that the company is slacking on its commitments- speak up. We can’t fix what you don’t know about it,
Who Must Follow Our Code?
We expect all our hires, investors, members, users, service and business partners to know and follow the Code. Failure to do so can result in termination of working relationship.
What If I Have a Code-Related Question or Concern?
If you have a question or concern, don’t just keep it to yourself. Don’t wait until a curiosity, suspicion or guess turns into a problem. Inform us at email@example.com. If you believe a violation of law has occurred, contact your local law enforcement.
Pepelwerk prohibits retaliation internally against any person who reasonably, proactively and with good intentions reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact firstname.lastname@example.org.
Our users’ value pepelwerk not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:
Our reputation as a company that our users can trust is our most asset, and it is up to all of us to make sure that we continually earn that trust. All our communications and other interactions with our users should increase their trust in us.
Our products, features, and services should make pepelwerk more useful for all our users. We have many different types of users, from individuals to large businesses, but one guiding principle: “Is what we are doing improving work lives?
Privacy, Security, and Freedom of Expression
Always remember that we are asking users to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of users’ personal information and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Privacy Policies, and applicable data protection laws.
Pepelwerk is committed to advancing privacy and freedom of expression for our users around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content. Contact email@example.com if you have questions on implementing these standards in connection with what you do at pepelwerk.
Part of being useful and honest is being responsive: We recognize relevant user feedback when we see it, and we do something about it. We take pride in responding to communications from our users, whether questions, problems, or compliments. If something is broken, fix it.
Any time you feel our users aren’t being well-served, speak up- let someone in the company know about it. Delivering on a better user experience and staying relevant for our users is everyone’s responsibility.
We are committed to creating an authentic and respectful working world. Where we all have an opportunity to reach our fullest potential for good. While we want you to be you, and all the wonderful and complicated things that come with you, we recognize that we are not much by ourselves but as a collection of people we have the potential to accomplish great things. To accomplish those great things through pepelwerk we won’t tolerate fakers, jerk-wads or being hateful just to be hateful.
Equal Opportunity Employment
Working here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment based on race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.
Harassment, Discrimination, and Bullying
pepelwerk prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you or someone else been bullied or harassed by anyone at pepelwerk, or by a pepelwerk partner or vendor, we strongly encourage you to immediately report the incident to firstname.lastname@example.org.
Drugs and Alcohol
Pepelwerk takes the position that the use of any substance that causes your behavior to inflict harm to others, yourself or pepelwerk is prohibited while conducting business with, for or on behalf of pepelwerk. If there is a reasonable suspicion of such behavior, pepelwerk has the right to terminate any working or business relationship immediately at our own discretion. If you see someone who is impaired or has the potential to cause themselves or others harm, please take reasonable action to prevent such harm while maintaining your own safety.
We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. If you become aware of a violation of this policy, you should report it to email@example.com immediately. In case of potential violence, contact law enforcement.
III. Avoid Conflicts of Interest
When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of pepelwerk or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.
When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of pepelwerk. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.
Below, we provide guidance in seven areas where conflicts of interest often arise:
Outside employment, side-gigs/jobs, advisory roles, board seats, and starting your own business
Business opportunities found through work
Friends and relatives; co-worker relationships
Accepting gifts, entertainment, and other business courtesies
Use of pepelwerk products and services
In each of these situations, the rule is the same – if you are considering entering a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, schedule time to review the situation with someone at pepelwerk by sending a request to firstname.lastname@example.org. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.
Avoid making personal investments in companies that are pepelwerk competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm pepelwerk.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, pepelwerk’ s business, and what you do at pepelwerk, including whether the company has a business relationship with pepelwerk that you can influence, and the extent to which the company competes with pepelwerk. You should also consider 1) any overlap between your specific role at pepelwerk and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.
Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include pepelwerk competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund’s investment activity.
Outside Employment, Side-gigs/Jobs, Advisory Roles, Board Seats, and Starting Your Own Business
Avoid accepting employment, work, advisory positions, or board seats with pepelwerk competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm pepelwerk. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify pepelwerk before accepting a board seat with any outside company. Do not start your own business if it will compete with pepelwerk. Do not accept or conduct side-gigs, consulting work or jobs that compete with your obligations to pepelwerk or with companies that compete with pepelwerk.
Business Opportunities Found Through Work
Business opportunities discovered through your work here belong first to pepelwerk, except as otherwise agreed to by pepelwerk.
Developing or helping to develop outside inventions that a) relate to pepelwerk’ s existing or reasonably anticipated products and services, b) relate to your position at pepelwerk, or c) are developed using pepelwerk corporate resources, service partners or training provided by pepelwerk may create conflicts of interest and be subject to the provisions of pepelwerk’ s Confidential Information and Invention Assignment Agreement and other employment or work agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, contact email@example.com.
Friends and Relatives; Co-Worker Relationships
Avoid participating in management of or decision-making regarding potential or existing pepelwerk business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.
To be clear, just because a relative, spouse/significant other, or close friend works at pepelwerk or becomes a pepelwerk competitor or business partner doesn’t mean there is a conflict of interest. However, if you are also involved in that pepelwerk business relationship, it can be very sensitive. The right thing to do in that situation is to remove yourself.
Finally, romantic relationships between people who work together, depending on the work roles and respective positions of the workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements. If you are feeling the warm and fuzzies towards another person, and its welcomed and reciprocated, both parties need to be proactive and act in the best interest of pepelwerk to make the romance work and not cause conflict of interest.
pepelwerk is not the matchmaker of the dating world, just the working world and we don’t want to have any perception that we cross that line.
Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, bribes, entertainment, and other business courtesies from a pepelwerk competitor, business partner, government official or office or any other person’s, entity or group that was given with the intention to influence your decision making that would benefit the providing party and impact pepelwerk adversely in anyway is prohibit. We take pride in providing our users with solutions and services that enhance their working experiences. Any behavior that creates the perception that we were playing politics, got bought or just enjoyed a 3-day vacation as a gift to influence our decision making is simply not acceptable.
Use of pepelwerk Products and Services
Avoiding potential conflicts of interest also means that you should not use pepelwerk products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of pepelwerk. For example, you should never approve pepelwerk accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as someone who works with or for pepelwerk to participate in or to generate a financial benefit for yourself or others. Do not use any service provider accounts, platforms or tools for your own personal gain.
All queries reported to firstname.lastname@example.org are reviewed by the executive leadership of pepelwerk and responses are determined on a case-by-case basis.
Unless specifically given permission to speak on the company’s behalf by the CEO, we expect all details, exchanges, information and communication with pepelwerk to be kept confidential. Information that is leaked to external sources that do not have a working relationship with pepelwerk can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Essentially we want you to treat your working relationship like your code name is 007 and keep things that are pepelwerk’ s – pepelwerks
This also includes:
properly secure, label, and (when appropriate) dispose of Confidential pepelwerk material;
safeguard Confidential information that pepelwerk receives from others under non-disclosure agreements;
take steps to keep our trade secrets and other confidential intellectual property secret.
Make sure that information that is classified and labeled as “Need to Know” or “Confidential” is handled as such. Do not share, forward, copy, or distribute under any circumstances. This includes be aware of your environment, the people that you are with and the pictures that you are in and ensuring that you are not disclosing confidential information. This includes keeping things confidential when winding down or having conversation with a friend, significant other or acquaintance that work for competitors. Use common sense- don’t share information that would cause harm to pepelwerk and don’t solicit information that could potentially gain pepelwerk
Just as you are careful not to disclose confidential pepelwerk information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.
Be sure to protect confidential information of pepelwerk or of any subsidiary or affiliate (“pepelwerk companies”). You may have access to confidential information through collaborations, rotations, 20% projects with another pepelwerk company, access to pepelwerk buildings or networks, or simply through casual interactions. Don’t access or use confidential information of other pepelwerk companies except when authorized and reasonably necessary for valid business purposes within the scope of your work at or with pepelwerk. Take all reasonable steps to maintain the confidentiality of any such information just as you would for pepelwerk confidential information.
Don’t disclose any confidential information about any pepelwerk company, including financial, partner, business, technical, or IP information, before obtaining appropriate sign-off from Legal, which may include getting consent from affected pepelwerk companies.
We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any pepelwerk’s former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it. Should you happen to come into possession of a competitor’s confidential information, contact Legal immediately.
You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of pepelwerk unless you’re authorized to do so by the company. The same applies to communications with the press.
pepelwerk’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use pepelwerk’s (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the CEO. We strongly encourage you to report any suspected misuse of trademarks, logos, or other intellectual property to email@example.com.
Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose pepelwerk and you to criminal and civil fines and penalties. Please seek advice from Legal before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to pepelwerk proprietary information. You should also check with Legal if developing a product that uses content not belonging to pepelwerk.
Consistent with our policy of respecting the valid intellectual property rights of others, we strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against pepelwerk, as well as significant damage to the company’s reputation.
pepelwerk gives us the tools and equipment we need to do our jobs effectively but counts on us to be responsible and not wasteful with the pepelwerk stuff we are given. Don’t be wasteful, excessive or access use or play with company resources and tools in a way that is abusive in nature. The big things like messing with company funds, equipment, and other physical assets are not to be requisitioned for purely personal use.
pepelwerk’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security processes. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smart phone or think that your network password may have been compromised – please promptly report the incident to firstname.lastname@example.org.
If you’re not careful, people may steal your stuff. Keep your head on a swivel. Always secure your laptop, important equipment, and your personal belongings, even while at a pepelwerk location. Don’t tamper with or disable security and safety devices.
Use of pepelwerk’s Equipment and Facilities
Anything you do using pepelwerk’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, pepelwerk may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting pepelwerk and its users, maintaining the security of resources and property, or investigating suspected misconduct.
Spending pepelwerk’s Money
A core business principle of pepelwerk is to spend money wisely and to earn money responsibly. When you spend money on pepelwerk’s behalf, make sure that the cost is reasonable, directly related to company business, and provides value to the business, the quality of the work we do or enhances our user experience.
Working with Suppliers and Business Partners
As pepelwerk grows, we enter more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for pepelwerk and our users. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision.
VII. Obey the Law
pepelwerk takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. You are responsible for being a subject matter expert in the work you do and that includes knowing when you are doing things outside the law.
U.S. and international trade laws control where pepelwerk can send or receive its products and/or services. These laws are complex, and apply to:
imports and exports from or into the U.S.
imports and exports of products from or into other countries, with additional concerns when those products contain components or technology of U.S. origin
exports of services or providing services to non-U.S. persons
exports of technical data, especially when the technical data is of U.S. origin
What constitutes an “import” or “export” under the law is broad. For example:
exposing or allowing access by non-U.S. persons to U.S. technical data can be an “export”, regardless of what country the exposure occurred in
sending a server from one country (“country X”) into another country (“country Y”) is an export from country X and an import into country Y
permitting the download of software from one country (“country X”) into another country (“country Y”) is an export from country X
transporting technical data or software on your laptop, or tools or equipment in your luggage, may be an export and import
The bottom line: If you are in any way involved in sending or making available pepelwerk products, services, software, equipment, or any form of technical data from one country to another, work with your manager to be sure that the transaction stays well within the bounds of applicable laws. If you are not sure, research it with the governing agency. If you are unsure how or if the law applies to your work with, for or on behalf of pepelwerk, send your question to email@example.com
Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition. These laws prohibit 1) arrangements with competitors that restrain trade in some way, 2) abuse of intellectual property rights, and 3) use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for pepelwerk.
Examples of prohibited conduct include:
agreeing with competitors about prices
agreeing with competitors to rig bids or to allocate customers or markets
agreeing with competitors to boycott a supplier or customer
Other activities can also be illegal, unfair, or create the appearance of impropriety.
Such activities include:
sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
using pepelwerk’s size or strength to gain an unfair competitive advantage
Although the spirit of these laws is straightforward, their application to situations can be quite complex.
pepelwerk is committed to competing fair and square. Any persons working with, for or on behalf of pepelwerk found to have violated these policies will, subject to local laws, be disciplined, up to and including terminating the working relationship. If you suspect that anyone at the company is violating the competition laws, send suspicions to firstname.lastname@example.org
Insider Trading Laws
Internally we share information, including non-public information, about pepelwerk’s business operations openly. In addition, you may overhear a conversation or come across a memo at a copy machine, either of which might involve confidential information. To use this non-public information to buy or sell stock, or to pass it along to others so that they may do so, could constitute insider trading. Insider trading not only violates this Code, it violates the law. Don’t do it.
Don’t bribe anybody, anytime, for any reason.
You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of pepelwerk. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.
Dealing with government officials
Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you’re dealing with a government official. “Government officials” include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything of value to government officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for government officials’ relatives. Never give gifts to thank government officials for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of pepelwerk products). Payment of such expenses can be acceptable, assuming they are permitted under local law.
The U.S. also has strict rules that severely limit the ability of a company or its employees to give gifts and business courtesies to a U.S. government official and limit the official’s ability to accept such gifts. The Honest Leadership and Open Government Act prohibits giving any gifts, including travel and other courtesies, to Members, Officers, and employees of the U.S. Senate and House of Representatives unless they fit within one of several specific exceptions. Gifts to employees of the U.S. executive branch are also regulated and subject to limits. Finally, state and local government officials in the U.S. are also subject to additional legal restrictions. If you don’t know, look it up on your local governing bodies web page.
pepelwerk aspires to be a company that walks the talk and tries every effort to create the changes that we believe enhance our working world. This document isn’t meant to spell out every scenario, that would be unnecessary and a little ridiculous. Instead, we expect that you use good judgement and consider our Code when representing yourself in the work you do, with for or in connection to pepelwerk.
Last updated April 9, 2019.
REPORTING CLAIMS OF COPYRIGHT INFRINGEMENT
We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from this site (the "Website") infringe your copyright, you may request removal of those materials (or access to them) from the Website by submitting written notification to our Copyright Agent (designated below). In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) ("DMCA"), the written notice (the "DMCA Notice") must include substantially the following:
Our designated Copyright Agent to receive DMCA Notices is:
Pw Legal Team email@example.com
If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.
Please be aware that if you knowingly materially misrepresent that material or activity on the Website is infringing your copyright, you may be held liable for damages (including costs and attorneys' fees) under Section 512(f) of the DMCA.
If you believe that material you posted on the Website was removed or access to it was disabled by mistake or misidentification, you may file a counter-notification with us (a "Counter-Notice") by submitting written notification to our copyright agent (identified below). Pursuant to the DMCA, the Counter-Notice must include substantially the following:
Completed Counter-Notices should be sent to: Pw Legal Team firstname.lastname@example.org
The DMCA allows us to restore the removed content if the party filing the original DMCA Notice does not file a court action against you within ten business days of receiving the copy of your Counter-Notice.
Please be aware that if you knowingly materially misrepresent that material or activity on the Website was removed or disabled by mistake or misidentification, you may be held liable for damages (including costs and attorneys' fees) under Section 512(f) of the DMCA.
It is our policy in appropriate circumstances to disable and/or terminate the accounts of users who are repeat infringers.