dealWIP Privacy Policy

 

Last Updated and Effective as of: March 14, 2019

 

Welcome to dealWIP Inc.’s (“dealWIP,” “we,” “our” or “us”) privacy policy (the “Privacy Policy”)!

 

dealWIP respects your privacy and is committed to protecting your information. The Privacy Policy below discloses our practices regarding our website (https://www.dealwip.co/) (the “Website”) and the provision of certain dealWIP software, products and services commonly known as the dealWIP Products as may be detailed in a separate agreement between you and dealWIP (collectively, the “Service”). This Privacy Policy does not apply to any other websites, applications or services provided by us, our affiliates or clients, unless it appears on the same.

 

This Privacy Policy aims to give you information on how we collect and process your information through your use of the Service, including any data you may provide through the same.  It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on the occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data.

 

This Privacy Policy is provided in a layered format so you can click through to the specific topics below.

 

 

INFORMATION COLLECTION

 

Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you.  We do not collect personal information unless (1) you submit that information to us or (2) you have been invited to use the Service by a dealWIP client. If you have been invited to use the Service by a dealWIP client, and you accept such invitation, by your acceptance you are agreeing to the use of your contact details in accordance with this Privacy Policy. Categories of personal information we may collect include:

 

  • Identity Data, which includes name, job title, employer and other similar identifiers; and
  • Contact Data, which includes address, email address and telephone numbers.

 

We may also collect certain other types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:

 

  • Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
  • Transaction Data, which includes anonymized information from documents stored on, or other information submitted or uploaded to, the dealWIP platform in order to facilitate transactions and to gain insight into the private transaction market.
  • Profile Data, which includes your username and password and your work history and preferences.
  • Usage Data, which includes information about how you use our Service.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us. 

 

IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

 

We use different methods to collect data from and about you including through:

 

Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:

 

  • create an account on our Service;
  • use our Service;
  • subscribe to our Service or publications;
  • sign up for a demo or otherwise contact us;
  • request marketing to be sent to you; or
  • give us feedback.

 

Automated technologies and cookies: As you interact with our Service, we may automatically collect Technical Data and Usage Data through the use of cookies, which are a type of technology that installs a small amount of information on a Service user’s computer or other device to permit a Service to, for example, recognize future visits using that computer or device. The Service may use other similar technologies (including, without limitation, tracking pixels, as described further below, and other anonymous identifiers) to gather information about you, such as IP addresses and location data, to customize your visit, to enable us to enhance our service, or for other purposes. Some of the specific cookies the Website and/or the Service may use include, but are not limited to:

 

  • Hotjar and Google Analytics. We use Hotjar and Google Analytics (together, the “UX Services”) in order to better understand our users’ needs and to optimize users’ experience with the Service. The UX Services are technology services that help us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.), which in turn enables us to build and maintain the Service using the best user feedback possible. Each of the UX Services uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular, a user’s device IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location, preferred language used to display our website). The UX Services store this information in a pseudonymized user profile. For further details, please see Hotjar’s privacy policy by clicking on this link, and Google Analytics’ privacy policy by clicking on this link. You can opt out of the creation of a Hotjar user profile, Hotjar’s storing of data about your usage of the Service and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
  • HubSpot.  We use HubSpot to enable us to better understand how visitors to the Website and users of the Service engage with the contents of each. HubSpot provides (1) a marketing technology service that allows us to automate the collection of data submitted to us via the Website and anonymously track the number and location of visitors to the Website and (2) a service technology service that allows us to be as responsive as possible to questions from users.  HubSpot uses cookies and other technologies to collect data on users of the Service and visitors to the Website. For further details, please click on this link. For HubSpot’s privacy policy, click on this link. For HubSpot’s cookie policy, click on this link.

 

INFORMATION USE AND SHARING

 

Subject to the section titled “Additional EU Disclosures,” we use information held about you to perform our services and for the other purposes outlined below. Specifically, we use your information for a variety of purposes:

 

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • To provide information that you have requested.
  • To respond to your direct inquiries.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • To send you marketing materials (see below).
  • Where we need to comply with a legal or regulatory obligation.

 

Subject to the section titled “Additional EU Disclosures,” we may share the information we collect about you with certain third parties in the following ways:

 

  • We will share your information with Amazon Web Services and other third-party providers of back-end and database infrastructure to operate our Service. We will provide such third parties with certain categories of your information including Identity Data and Contact Data. These third parties may only use this information in connection with their services for dealWIP, and not for their own purposes or benefit.
  • We will share your information with HubSpot and other third-party providers of marketing software to operate our Service and the Website. We will provide such third parties with certain categories of your information including Identity Data and Contact Data. These third parties may only use this information in connection with their services for dealWIP, and not for their own purposes or benefit.
  • We may, from time to time, share your information with our business partners, operational service providers and subcontractors and other third parties.
  • We may, from time to time, share your information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control.
  • We may, from time to time, share your information with third parties with whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Service.

 

THIRD-PARTY SERVICES

 

This Service may include links to third-party websites, services, plug-ins, applications and content. You do not need to click on those links, enable those connections, or otherwise engage such third-party websites, services, plug-ins, applications or content to use this Service, but to the extent you do, we may share your information with such third party, and/or such action may allow third parties to collect or share data about you. We do not control these third-party properties and are not responsible for their privacy statements. When you leave our Service or engage third-party services, plug-ins, applications or content on our Service, we encourage you to read the privacy policy of each third-party provider whose website, service, plug-in, application or content you visit or engage, as applicable.

 

DATA SECURITY

 

We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.  However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION

 

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances you can ask us to delete your data; see below for further information.  In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.

 

ADDITIONAL EU DISCLOSURES

 

Our role as data controller and data processor

 

dealWIP Inc. generally acts as the data controller of your information submitted through our Service. 

 

If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority, so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us.” If you are situated in the EU and have a complaint, please contact our privacy manager, James Clarkin-Breslin, at info@dealwip.co.  

 

Provision of personal data and failure to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.

 

Legal basis for our processing of your personal data

 

Below are the types of lawful basis that we will rely on to process your personal data:

 

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@dealwip.co. 

 

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.

 

  • Consent means if you consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent.

 

Change of purpose

 

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 info@dealwip.co.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Collection of personal data from third party sources

 

As discussed above, we may obtain information about you through automated technologies (see section entitled “Information Collection”).

 

Categories of third parties receiving personal data

 

The only third parties receiving personal data are those referenced in the section “Information Use and Sharing.”

 

Withdrawing your consent

 

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at info@dealwip.co.

 

Use of your personal data for marketing purposes

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

 

  • Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.

  • Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.

 

To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.

 

Rights of EU Data Subjects

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

 

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

To exercise your rights, please contact us at info@dealwip.co.

 

OPT OUT

 

Opting out of messages from us

 

To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at info@dealwip.com.  We will process your request within a reasonable time after receipt.  Please note that if you opt out in this manner, certain aspects of the Service may no longer be available to you.

 

Opting out of cookies

 

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Service or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.

 

DATA RELATING TO CHILDREN

 

Our Service is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

 

CROSS BORDER TRANSFERS

 

Our Service is maintained in the United States, the United Kingdom and the Republic of Ireland. If you are visiting or using the Service from any regions with laws governing data collection and use that may differ from those in the United States, United Kingdom and the Republic of Ireland, please note that you may be transferring your information to the United States, the United Kingdom, the Republic of Ireland and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States, the United Kingdom, the Republic of Ireland and in other countries as specified in this Privacy Policy.  You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

 

UPDATES TO THIS PRIVACY POLICY

 

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time.  However, if at any time in the future we plan to use your information in a way that materially differs from this Privacy Policy, we will post such changes here or email you. We encourage you to periodically review the Service for the latest information on our privacy practices.  You are bound by any changes to the privacy policy when you use the Service after such changes have been first posted.

 

CONTACT US

 

dealWIP Inc.

68 Jay Street, Brooklyn, New York 11201

info@dealwip.co