DatePerfect Investor Portal
Privacy & Cookies Policy
Effective date: August 13, 2018
Who We Are and How to Contact Us
Who we are. The Company is the “Controller” (for the purposes of the GDPR) of your Personal Data (as defined below). Our address is 248 3rd Street, Suite 440, Oakland, California, USA, 94607.
What Personal Data We Collect
Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally (“Personal Data“) while using the Portal. The Personal Data we may collect from you is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, picture, social security number and/or tax identification number, password, copies of ID cards or other forms of identification.|
|Contact Data||Your home address, work address, billing address, email address and telephone numbers.|
|Financial Data||Your bank account and payment card details, statements about your wealth and financial situation.|
|Transaction Data||Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history).|
|Content Data||Any content you provide to the Portal or otherwise provide us that is not already included in another category, including without limitation, your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Portal, and metadata about the foregoing (“Content“).|
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Portal, we may retain the content of such messages and our responses.|
|Behavioral Data||Inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into “segments.”|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available. Examples of these sources include credit reporting agencies, social media sites, our affiliates, analytics providers, data brokers, and identity verification and compliance service providers.
No Special Categories of Personal Data. We do not collect any “Special Categories of Personal Data” about you on the Portal (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
How We Use Your Personal Data and Why
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a legal basis for that use if you are within the EU. The legal bases depend on how you use the Portal. This means we collect and use your Personal Data only where:
We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to a use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We have set out below, in a table format, more detailed examples of relevant purposes for which we may use your Personal Data.
|Purpose||Why do we do this|
|Providing, updating, and maintaining the Portal and our business||To deliver the services under the Portal, including, for example, registering you as a user, managing your account and profile, and authenticating you when you log in, establishing your eligibility to invest in the Company under applicable laws, third-party contractual obligations and internal policies, and providing tax and other investment related reporting as required by applicable laws.|
|Processing investments and payments||To close investments and process payment for any purchases, subscriptions or sales made in the Company, to protect against or identify possible money-laundering or other fraudulent transactions, and otherwise as needed to manage our business.|
|Research and development||To enable us to improve the Portal and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use the Portal and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, areas for additional features and improvement of the Portal and other insights. We also test and analyze certain new features with some users before introducing the feature to all users.|
|Communicating with users about the Portal||To send communications via email and within the Portal, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. We may also provide tailored communications based on your activity and interactions with us. These communications are part of the Portal and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.|
|Providing customer support||To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Portal and provide other customer support.|
|Enhancing security||To keep our website, the Portal and associated systems operational and secure, including, for example, verifying accounts and activity, monitoring and investigating suspicious or fraudulent activity and to identify violations of our terms and policies.|
|To comply with applicable law, legal process and regulations and protect legitimate business interests||As we believe is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others.|
What happens when you do not provide necessary Personal Data? Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Portal). In this case, we may have to stop you using the Portal.
What are cookies? When you visit the Portal, we may send one or more “cookies” – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Portal. A cookie may convey anonymous information about how you browse the Portal to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Portal. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.
What cookies do we use? Our Portal uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through the Portal and to enable you to use some of its features. For example, they allow you to log in to secure areas of the Portal and help the content of the pages you request to load quickly. Without these cookies, the Portal cannot function properly, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow the Portal to remember choices you make when you use the Portal, such as remembering your login details and remembering the changes you make to other parts of the Portal which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Portal.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to the Portal and how users use the Portal. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Portal. The information collected is aggregated and anonymous. We use this information to help operate the Portal more efficiently, to gather broad demographic information, and to monitor the level of activity on the Portal. We use a number of different tools, including Google Analytics, for this purpose.|
How can I disable cookies? You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of the Portal and some features of the Portal may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit the Portal.
Log Files: Log file information is automatically reported by your browser each time you access a web page. When you use the Portal, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Clear GIFs Information (Web Beacons): When you use the Portal, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your DatePerfect account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make the Portal better for our users.
Third-Party Services: The Company may use third-party services such as Google Analytics to help understand use of the Portal. These services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You can also prevent the use of Google Analytics relating to your use of the Portal by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
Use of Google User Data: If you choose to connect a Google profile to your account, we will access certain information obtained from Google regarding your account. In particular we may store your name and email address as well as information on the particular profile you connect, including your contacts. This data will only be used by us to provide you with the service you expect and will not be shared with any third parties.
Who We Share Your Personal Data With
We may share your Personal Data with third parties in the ways that are described in the table below. We consider this information to be a vital part of our relationship with you.
|Recipients||Why we share it|
|Our Affiliates||Our affiliates may access your Personal Data to help us develop, maintain and provide the Portal and help manage our customer relationships (including providing customer support, customer liaison, fund advisory services, etc).|
|Service Providers||Our service providers provide us support for the Portal, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, banking services, and other services for us, which may require them to access or use Personal Data about you.|
|Professional Advisers||Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services.|
|Legal and Taxing Authorities, Regulators and Participants in Judicial Proceedings||We may disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others.|
|Advertisers||Certain users of the Portal may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Portal that are targeted towards your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on the Portal, and such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests.|
|Researchers||To enhance the public understanding of patterns and trends in the markets served by the Portal, we may provide Personal Data to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes.|
|API Users||A limited number of partners have API access to portions of the Portal.|
As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain services related to the Portal or conduct independent research based on such anonymous usage data.
If you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data, we will convey that request to any third party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
How Long We Store Your Personal Data
We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Where We Store Your Personal Data
How We Protect Your Personal Data
The Company uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your information on the Portal may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
Your Rights Relating to Your Personal Data
How to exercise your rights. If you want to exercise any of the rights described above, please contact us using the contact details in Who We Are and How to Contact Us.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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.
We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority.
Marketing Communications Preferences
You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to existing or pending hires, purchases or investments using the Portal or consent to direct marketing communications.
Our Policy on Children’s Privacy
Links to Other Websites