Legal

Dealpath Privacy Policy

LEGAL

Dealpath Privacy Policy

Effective Date: July 01, 2022

Dealpath, Inc. (“Dealpath”, “we”, “us”, or “our”) provides a cloud-based collaboration and workflow technology platform that allows our customers to manage their real estate investment transactions (“Service Platform”).  Our Privacy Policy is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you.

  1. SCOPE
  2. PERSONAL INFORMATION WE COLLECT
  3. HOW WE USE YOUR PERSONAL INFORMATION
  4. DISCLOSING YOUR PERSONAL INFORMATION TO THIRD PARTIES
  5. INTERNATIONAL TRANSFERS
  6. YOUR CHOICES
  7. YOUR PRIVACY RIGHTS
  8. RETENTION OF PERSONAL INFORMATION
  9. OUR LAWFUL BASIS FOR PROCESSING
  10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
  11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
  12. SECURITY OF YOUR PERSONAL INFORMATION
  13. THIRD PARTY WEBSITES/APPLICATIONS
  14. CHILDREN’S INFORMATION
  15. SUPERVISORY AUTHORITY
  16. CHANGES TO OUR PRIVACY POLICY
  17. CONTACT US

    1. SCOPE

This Privacy Policy applies to personal information processed by Dealpath in our business, including on our Service Platform, websites and related online or offline offerings.  To make this Privacy Policy easier to read, our Service Platform, websites and related offerings are collectively called the “Services.”

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of our customers through their use of our Services pursuant to a data processing agreement or other similar document (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

  1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with our Services.

Information You Provide to Us.

Account Creation. When you create a user account, we may collect your name, email address, employer, position/title, phone number, address, username, profile photo and password.

Payment Information. In order to facilitate your use of the Services, we may collect payment card and/or other financial information. Please note that we use a third-party service provider to collect and process payment card information on the Services. Dealpath does not directly collect or store any payment card information provided to the Services, but it may receive information associated with your payment card information (e.g., your billing details).

Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request a demo, register for our newsletter, request customer or technical support or otherwise communicate with us.

Surveys.  We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.

Interactive Features. Dealpath may offer interactive features such as collaboration tools, blogs, forums, and social media pages. Dealpath and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public”, and unless otherwise required by applicable law, will not be subject to the privacy protections referenced herein.

Customer Service and Support. If you call or otherwise interact with Dealpath’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows and other events where we collect personal information from individuals who interact with or express an interest in Dealpath and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Information Collected Automatically or From Others.

Automatic Data Collection.  We may collect certain information automatically when you use the Services.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of  your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

Cookies, Pixel Tags/Web Beacons and Analytics Information.  We, as well as third parties that provide content, advertising or other functionality on the Services, may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in device browsers to store their preferences.  Most browsers allow you to block and delete cookies.  However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services.  The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:
    • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
    • LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
    • Hotjar (Session Replay Analytics). We may use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
    • FullStory (Session Replay Analytics). We use FullStory’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how FullStory uses your personal information, please visit FullStory’s Privacy Policy. To learn more about how to opt out of FullStory’s use of your information, please click here.

 

Information from Other Sources.

Our Customers. If you use our Services on behalf of an organization (e.g., your employer), that organization may provide us with information about you so that we can provision your account.

Third Party Services and Organizations. We may obtain information about you from other sources, including through third-party services and other organizations. For example, if you access or use our Services through a third-party application, such as a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.

  1. HOW WE USE YOUR PERSONAL INFORMATION

We use your information for a variety of business purposes, including to:

To Provide the Services or Information Requested, such as:

  • Fulfilling our contract with you or the organization on whose behalf you use the Services;
  • Process payment card and/or other financial information to facilitate your use of the Services;
  • Responding to questions, comments and other requests;
  • Providing access to certain areas, functionalities and features of our Services; and
  • Answering requests for customer or technical support.

Administrative Purposes, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security and fraud prevention;
  • Measuring interest and engagement in our Services;
  • Improving the Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on our Services and Privacy Policy changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

How We Use Automatic Collection Technologies.  Our uses of the Technologies (as defined above) fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.  This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites. Some of the advertising Technologies we use include:
    • Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
  1. DISCLOSING YOUR PERSONAL INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Our Customers (Authorized Users Only). In cases where you use our Services as an authorized user on behalf of an organization (e.g., your employer), that organization may access information associated with your use of the Services including usage and other data.

Please note that your information may also be subject to that organization’s privacy policy. We are not responsible for the privacy or security practices of our customers.

Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.

Affiliates. We may share personal information with our affiliated entities.

Advertising Partners. Through our Services, we may allow third party advertising partners, including Google, Facebook, and LinkedIn, to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

  1. INTERNATIONAL TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

  1. YOUR CHOICES

General. You may have the right to opt-out of certain uses of your personal information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our agreement with you or this Privacy Policy).

Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these and learn more about targeted advertising and consumer choice and privacy, by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

  1. YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

Please note that if you use our Services as an authorized user on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the individual rights requests referenced above.

  1. RETENTION OF PERSONAL INFORMATION

We store the personal information we receive as described in this Privacy Policy for as long  as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

  1. OUR LAWFUL BASIS FOR PROCESSING

If your personal information is subject to the applicable data protection laws of the European Economic Area and/or the United Kingdom, Dealpath’s processing of your personal information may be supported by the following lawful bases:

  • Performance of a Contract. Dealpath needs to process your personal information to carry out your employment contract.
  • Legitimate Interest. Dealpath processes your personal information to further its legitimate interests but only where our interests are not overridden by your interests or fundamental rights and freedoms.
  • Compliance with our Legal Obligations. Dealpath may process your personal information to comply with our legal obligations.
  • in some cases, dealpath may also rely on your consent to process your personal information.
  1. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) in our capacity as a “business.” The CCPA provides California residents with the right to know what categories of personal information Dealpath has collected about them, and whether Dealpath disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by DealpathCategory of Third Parties Personal Information is Disclosed to for a Business Purpose
Identifiers

·         Service Providers

·         Our Customers (Authorized Users Only)

·         Advertising Partners

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·         Service Providers

·         Our Customers (Authorized Users Only)

Commercial information

·         Service Providers

·         Our Customers (Authorized Users Only)

Internet or other electronic network activity

·         Service Providers

·         Our Customers (Authorized Users Only)

·         Advertising Partners

Professional or employment-related information

·         Service Providers

·         Our Customers (Authorized Users Only)

Inferences drawn from other personal information to create a profile about a consumer

·         Service Providers

·         Our Customers (Authorized Users Only)

·         Advertising Partners

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Dealpath does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

 Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

  1. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.

  1. SECURITY OF YOUR PERSONAL INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.  To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

  1. THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

  1. CHILDREN’S INFORMATION

The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

  1. SUPERVISORY AUTHORITY

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

  1. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion.  If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

  1. CONTACT US

Dealpath is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Dealpath, Inc.
300 California Street, Suite 300
San Francisco, CA 94104
support@dealpath.com
(415) 625-3545

Revision History
Privacy Policy – Revision – February 2020
Privacy Policy – Revision – Sept 2016

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