The Dealboard platform is a technological solution developed by Dealboard (the "Platform"). It consists of cloud-based software to disseminate information about the private markets sector, expand access to investments in this sector and facilitate communication and integration between regulated and unregulated providers involved in private markets sector securities offerings, registered with regulatory bodies, and end clients, generating better understanding and education about the private markets industry as a whole.
Due to the services provided by Dealboard, it is necessary to collect Personal Data from all those who access and register on the Platform, and the privacy of information is very important to the components of Dealboard, which have as one of their principles respect for the confidentiality of information and Personal Data.
The purpose of this Privacy Policy ("Policy") is to inform you how Dealboard treats the personal data it has access to in the context of the registration made through the Platform, whether the service provider and/or the end customer, in accordance with current legislation, namely the ADPPA (American Data Privacy and Protection Act), as well as other applicable legislation according to the place of data collection and the user's residence.
This Policy applies to the processing of Personal Data of all those who register, subject to Dealboard's Terms of Use, by registering on the Platform.
Capitalized terms written but not defined in this Policy shall be interpreted in accordance with Dealboard's Terms of Use and Terms of Service.
For the purposes of this Policy, below are some important definitions:
Personal Data: Any information provided and/or collected, even if public, by the Platform, by any means, that: (I) identifies, or, when used in combination with other information processed on the Platform, makes the user identifiable.
Processing of Personal Data - Any operation carried out with Personal Data, such as those relating to the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
Purpose - is the objective that Dealboard wishes to achieve from each act of processing Personal Data;
Necessity - is the limitation of the processing of Personal Data to the minimum necessary to accomplish its purposes, avoiding excessive information collection;
Legal bases - is the basis in the ADPPA (American Data Privacy and Protection Act), among other legislation that may be applied authorizing the processing of Personal Data for a particular purpose by Dealboard.
Consent - is the free, unambiguous, informed consent given by the data subject for DXA to process his or her Personal Data for a specific purpose.
For more information about the processing of your Personal Data, please contact us at dpo@dealboard.com.
The Platform may collect your Personal Data in various ways, such as:
1. When provided through the completion of forms, questionnaires, e-mails, applications, contracts, through submission of personal documents, either printed or scanned, in situations where you:
a) registers and qualifies for the services provided by Dealboard;
b) requests the shipment of Dealboard materials;
c) create an account on the Dealboard platform;
d) provides or intends to provide services to Dealboard;
e) is or intends to become a Dealboard Partner;
g) participates in a survey promoted by the Dealboard platform; and
h) gets in touch, through the channels made available on the Dealboard platform, to provide feedback or request information.
2. Through public sources (such as public websites, public databases) or through sharing by a third party, done without violating any legal obligation to which you are subject.
a. To register on the Platform, the following data may be requested:
Identification, registration and contact details (if an individual): full name, nationality and place of birth, date of birth, gender, marital status, mother's and father's name (optional), full address, telephone number and e-mail address;
Identification, registration, and contact data (if legal entity): company name, trade name, nationality, date of incorporation, name of partners/shareholders, complete address, telephone, and e-mail;
Identification documents: copies and/or numbers of identification documents such as ID, CPF, Passport, CNPJ and professional licenses, issuing body and date of issue, copy of the legal entity's articles of incorporation up to date;
Professional Information: academic background and profession. If employed: company name and full address;
Procedural Data: information related to administrative and judicial actions, protests, among others;
Politically Exposed Person Identification: information related to politically exposed person, when applicable;
Financial information: source of income, assets and shareholdings;
Bank information: bank, type of account, branch number and current account,
Other information: whether you are a US Person and whether you have a tax residence in other countries.
The Platform collects and processes data to promote integration between service providers and end users, thus optimizing processes and enriching the overall quality of interaction between the parties.
Thus, Personal Data collected may be processed for the following purposes:
a. authenticate identity in order to fulfill KYC obligations;
b. prevent and detect fraud, financial crimes and market abuses;
e. measure and manage the risks to which it is subject when contracting with a client, partner or service provider;
f. comply with judicial or administrative orders;
g. handle customer complaints and requests;
h. send communications and satisfaction surveys;
i. for the purposes of security and operation of Dealboard's IT systems;
j. for analysis of behavior on the Platform (in this case the information used does not identify the user, as it is anonymized. Therefore, such information is not considered Personal Data under current legislation);
l. for sending marketing communications, by e-mail, telephone, or other previously agreed upon means;
Consent
Consent to the processing of Personal Data, as well as the use of the services available on the Platform, is given through acceptance of Dealboard's Terms of Use.
Consent to the sending of marketing e-mails and communications may be revoked by means of the unsubscribe option present in the footer of the e-mails.
V. Information Sharing
Dealboard will not disclose the Personal Data of its users, service providers and partners, except when:
a. it is necessary to guarantee the rendering of the contracted services that depend on a third party;
b. for risk control;
c. for financial or regulatory reporting; and
d. it is necessary due to obligations arising from the law, rules and regulations, judicial or administrative order.
In such cases, your Personal Data may be shared with:
a. organs and entities of the public administration;
b. administrative and self-regulatory bodies;
c. professional advisors, such as law firms, accountants, auditors, tax consultants;
If Dealboard is involved in a merger, acquisition or takeover, Personal Data may be shared during the due diligence phase or, at a later date, transferred to the acquiring legal entity.
In addition to its operations in the United States, Dealboard also provides services in Central America, South America, North America, Europe and Asia. Therefore, Dealboard's platform may transfer Personal Data to other countries when required by law.
For countries that do not have an adequate level of regulation for the protection of Personal Data compared to the ADDPA, we will implement operational and contractual measures for the transfer of Personal Data.
The Platform will keep your Personal Data collected during the relationship with you and in accordance with the purposes for which it was collected, and will store your Personal Data for the period necessary to:
a. comply with the purpose of the data processing;
b. defense of Dealboard's interests in administrative, judicial or arbitration proceedings; and
c. compliance with legal or regulatory obligations.
After the period mentioned above, or when the user so requests and Dealboard evaluates their request for deletion, the Personal Data will be deleted, except in cases where the maintenance of the data results from a legal or regulatory obligation.
Dealboard employs technical security and organizational measures to protect your information and Personal Data. Data will be stored in a secure operating environment that is not accessible to the public.
Dealboard strives to protect the privacy of Personal Data and other information that is stored, however total security cannot be guaranteed. Unauthorized use of accounts, hardware or software failure, as well as other factors may compromise the security of your Personal Data at any time. In this sense, no transmission over the Internet can be guaranteed to be completely secure.
Accordingly, Dealboard does not represent, authorize or warrant that personal information will be protected from hacking or any other unauthorized form or device in the Internet environment.
Therefore, in the event that the user identifies or becomes aware of something that compromises the security of Personal Data, Dealboard asks that you contact us via e-mail at compliance@dealboard.com or another form of contact that you choose from those made available by Dealboard for this purpose.
IX. What are my rights in relation to Personal Data
In compliance with current and applicable regulations regarding the protection of Personal Data, Dealboard respects and guarantees the user the possibility of submitting requests based on the following rights:
a. request access to your Personal Data;
b. request confirmation of the existence of the processing of your Personal Data;
c. request the correction of incomplete, inaccurate or outdated data ;
d. request the anonymization, blocking or deletion* of Personal Data, in specific situations;
e. revoke* consent to the processing of your Personal Data, in specific situations.
f. Request the deletion of data processed with the user's consent;
g. request information on the possibility of not giving consent, as well as being informed of the consequences in case of refusal.
h. the review of automated decisions taken solely on the basis of the automated Processing of Personal Data e;
i. the opposition to the Processing carried out in one of the cases of waiver of consent, in the event of non-compliance with the provisions of the ADDPA and other applicable legislation.
Requests can be made via e-mail: compliance@dealboard.com.
Dealboard is not responsible for the misuse or loss of Personal Data to which it has no access or control.
All technical materials and other content available on the Platform are for information purposes only and do not constitute financial, legal, tax, accounting or any other type of recommendation.
The Platform may contain links to other external websites, the content and privacy policies of which are not the responsibility of Dealboard.
The Platform may update this Privacy Policy from time to time. We recommend that users review this Policy regularly to stay informed about our privacy practices.
If you have any questions or concerns about this Privacy Policy, please contact us through the channels available on the Platform.
By using the Platform, users agree to the terms of this Privacy Policy.
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