DealVector Inc. Privacy Policy

Last Updated: October 30, 2018

DealVector Inc. (”DealVector”) provides this notice explaining DealVector’s online information practices and the way that the personal information of a user of DealVector’s services (Each, including you, a “User”) is collected and used. If you do not agree with the practices explained in this policy, you should not use the service, and if necessary, should request that your registration or subscription be cancelled. This policy applies to all User- Supplied Content, including, without limitation, all information placed onto the DealVector system by you or that DealVector collects from Users in connection with their use of the Service. By using the Service, and by checking the box indicating agreement with the Terms of Service during registration, you agree to accept the practices and terms set forth in this Privacy Policy. Capitalized terms not defined in this policy shall have the meaning set forth in the DealVector Terms of Service 

1. General Usage and Disclosure of Information

DealVector is a communication platform that facilitates information sharing among its Users by matching Users according to criteria that they specify. There are three categories of User-Supplied Content utilized by the platform, which are generally described below,”Personally Identifiable Information” (“PII”) is information that describes a User’s actual contact data and identity such as Name, Address, Email, Telephone, Fax, Employer, or other proprietary personal information. DealVector shall procure that neither it, nor any of its directors, officers, employees, agents, representatives, partners, suppliers, affiliates, attorneys or advisers shall reveal a User’s PII to another User on the system or to anyone outside of the system unless specifically consented to or requested by the User (as with a Contact Escrow feature request), or to comply with applicable law, subpoena, order, or other legal requirements as specified in, and in accordance with, our Terms of Service.

”Categorical Information” (“CI”) is descriptive information related to the status or type of a User within the system. CI may include but is not limited to Primary Role, Deal-Specific Role, Affiliation Status, Validation Status, Reputation Rating, Document Verification status, and Connection Score. User CI is used to match Users to one another based on User-designated preferences, and is therefore disclosed on a limited basis to other Users in the general course of operating the service. By way of example, a User who has designated himself or herself as an “Institutional Investor” will be identified as such in postings to the network, to the subset of Users to whom the posting is directed. DealVector shall procure that neither it, nor any of its directors, officers, employees, agents, representatives, partners, suppliers, affiliates, attorneys or advisers will display or disclose User PII in conjunction with User CI, and only the subset of CI relevant to a particular match shall be revealed to the subset of Users with whom the match is made. An individual User’s CI shall not be searchable or made visible or disclosed to anyone, either on the system or outside of the system. By way of example, it is not possible for one User to see a list of all of the deals with which another User has affiliated himself or herself, only the particular deal which is relevant to the specific matching event.

”User-Interactive Content” (“UIC”) is information (other than PII or CI) input by a User in the course of interacting with other Users on the site. UIC may include but is not limited to message text, documents, price information, marking information, or other similar information. A User’s UIC is shared with other Users on the site as specified by the criteria selected by the communicating User, or by the rules of a particular DealVector feature set. Because UIC is shared with other Users on the site, Users should exercise appropriate judgment in their communications with other Users. Users are responsible for obeying all regulatory and professional standards that apply to their forms of communication. For the avoidance of doubt, all information submitted with respect to messaging and/or message mining functionality (including but not limited to Bondtalk) constitutes UIC. “User Delivered Content” (“UDC”) is a subset of UIC that describes any uploaded documents and that also describes forwarded email content shared into the system via bondtalk@dealvector.com, privatebwics@dealvector.com, bwics@dealvector.com, or bwic@dealvector.com. UDC content that is not PII may be shared with other Users.

The “Public Teaser” is a specific type of UIC where a User may optionally provide DealVector with information that DealVector can use outside of the DealVector site for the purposes of generating an out-of-network match to the User’s query. DealVector reserves the right to disclose certain systemic activity and information with respect to site usage, including (for illustrative example) the number and types of users on the platform, the number of posts on the platform, specific deals being queried on the platform, descriptions of aggregate CI on the platform, and similar types of information and derivative works, but shall not, as part of any such systemic activity or information disclosure, disclose any User’s PII, any User’s listings of securities or transactions, or the content of any User’s communications on the system.

2. Termination

Upon the termination of a User’s registration or subscription, such termination initiated by either of the User or DealVector, DealVector will render all PII related to your account inaccessible to other members.

3. Anonymous Alpha-Numeric Identifiers

User CI and UIC are associated with and used with anonymous alpha-numeric identifiers. Such anonymous alpha-numeric identifiers may be reset by the User at any time. Existing User PII, CI and UIC then becomes  associated with the new anonymous alpha-numeric identifier. DealVector provides the anonymous alpha- numeric identifier functions as a courtesy to Users to facilitate communication on potentially sensitive topics, but does not represent that such anonymized designations will always be available or will always be effective, and assumes no liability for any disclosure of User identities in the absence of willful misconduct or gross negligence.

4. Other Party Access to Information

Users that designate a Compliance Manager within their firm grant to DealVector the ability to share all PII, CI, and UIC related to such User’s account with the designated Compliance Manager. In such case the Compliance Manager will also have the ability to manipulate certain aspects of the User’s account, including blocking communications, as well as searching the PII, CI and UIC of the User with a variety of tools. Pursuant to providing and maintaining the technical capabilities of the Service and otherwise performing the tasks set forth in this Privacy Policy, DealVector, its staff, partners and contractors may review User PII, CI, and UIC, but they shall remain bound by the disclosure policies as set forth in this Privacy Policy. DealVector may also use User PII to deliver the Service; to send notices related to the Service, User Accounts, or DealVector business matters; to send newsletters (from which Users may unsubscribe at any time); to determine the technical capabilities of the device User’s employ to access the Service; and to communicate generally with Users respecting the Service. DealVector may disclose PII to its partners in order to provide the Service, resolve service problems and correct errors in the Service (including customer inquiries, billing and credit corrections), to communicate with Users about the Service, to provide Users with advertising and promotional information in connection with the Service, and to enhance User experience on the Service. However, these partners do not have an independent right to share this information and shall be subject to the disclosure restrictions set out in this Privacy Policy and in the Terms of Service. Due to DealVector’s potential contractual obligations with these third parties and the need to share personally identifiable information to deliver and support the Service, DealVector cannot provide Users with the opportunity to opt-out of sharing PII with these third parties, however, the duty of confidentiality established above will extend from DealVector to such third parties with regard to any PII shared or otherwise provided to DealVector’s partners. To the extent DealVector may accept credit card payments all credit card orders and information shall be transmitted securely for processing. User-Supplied Content including PII, CI, and UIC may be provided to a third party if DealVector files for bankruptcy, or there is a transfer of the assets or ownership of DealVector. Any and all obligations of confidentiality regarding such information shall carry over to any third party in the event of such bankruptcy or transfer of the assets or ownership of DealVector, subject to applicable law and any order of a duly authorized bankruptcy court. Subject to Section 5 of the DealVector Terms of ServiceDealVector may also disclose such information in order to respond to a law enforcement agency request, subpoena, court order or other such request by a legal authority, including any regulatory body or agency, or defend against legal claims directly related to User use of the Service, to investigate, prevent and take action regarding fraud or misuse of the Service, to comply with laws or regulations, to enforce DealVector’s Privacy Policy and Terms of Service, and to protect the rights, property or safety of DealVector, the Service, Users and others.

Any information that a User may reveal in communication with matched Users is visible to such matched Users. Consequently, you should exercise appropriate care in your communications on the site. DealVector Services are a platform for communication, and DealVector makes no representation or warranty as to the accuracy, completeness or veracity of any UIC made available through the Services at any time. ALTHOUGH DEALVECTOR WILL USE ITS COMMERCIALLY REASONABLE EFFORTS TO ENFORCE COMPLIANCE, DEALVECTOR HEREBY DISCLAIMS ANY AND ALL RESPONSIBILITY AND LIABILITY FOR ANY VIOLATIONS OF THE TERMS OF SERVICE BY USERS OF THE DEALVECTOR SERVICES.

5. Non-Personally identifiable and Aggregate Information

Additional non-personally identifiable information that DealVector gathers may include User gender, age, zip code, country or territory of residence, IP address (but see the discussion at the end of this section), the type of browser that Users use, the type and nature of the content that Users upload to the Service and access from the Service, the links and transactions with DealVector and with third-parties that Users enter into via the Service, certain aspects of UIC, and other aspects of User use of the Service. DealVector uses this information to improve the Service, conduct research, to analyze Users’ interest in the areas of the Service, to tailor advertising and content displayed to Users, to inform DealVector partners about the use of the Service, and to inform DealVector advertisers about the number of Users that have viewed their advertising. To do this DealVector may combine information that it has about Users with information that it obtains from business partners or other companies. DealVector may also release aggregate demographic information about User trends and/or combined UIC information to partners and other third parties, including third-party advertisers on the Service. An example of this information would be patterns of use of the Service based on types of User or anonymized market-related data. DealVector also retains aggregated log files of requested content in order to report overall product usage to content partners and to evaluate User trends. Generally, an IP address changes each time Users connect to the Internet (it is a “dynamic” address). Note, however, that if Users have a broadband connection, depending on individual circumstance, it is possible that User IP addresses that DealVector collects, and cookies, may contain information that could be deemed identifiable. This is because with some broadband connections User IP addresses don’t change (it is “static”) and could be associated with a User’s personal computer.

6. Data Security

DealVector uses commercially reasonable precautions to keep user information secure. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, DealVector has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information that is collected. However, due to the open nature of communication through the Internet, and the information practices of various intermediary service providers such as email or other communications services, DealVector cannot guarantee that communications among Users, the Service, and other Users will be free from unauthorized access by third parties. DealVector cannot absolutely guarantee the security of any information that is disclosed or transmitted online.

7. Third Party Websites

The Service may contain links to other web sites or form part of the offering of those web sites. DealVector is not responsible for the privacy policies of these sites. If Users provide any information to such third parties different rules regarding the collection and use of PII, CI, and UIC may apply. Users should review such third party’s privacy policies before providing any data to them.

8. Cookies and Web Beacons

The Service may use a technology known as web beacons – sometimes called single-pixel gifs – that allow DealVector to collect web log information (such as the date and time User’s visited the Service, the pages visited, the website Users came from, the types of browser and operating system used, and the domain name and address of the User’s Internet service provider). A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. DealVector may also include web beacons in e-mail messages to Users in order to determine whether messages have been opened. DealVector uses cookies to automate log-in, permit guest access, and record user preferences. A cookie is a piece of information that a webserver may send to a user’s computer when a user accesses such website. Subsequently when users return the website can detect the presence of the cookie. Nothing contained in this Section 8 shall permit DealVector or any of its directors, officers, employees, agents, representatives, partners, suppliers, affiliates, attorneys or advisers to disclose, use or reveal any information other than as permitted under the other Sections of this Privacy Policy.

9. Legal Basis for Processing Personal Information (EEA visitors only)

If you are a visitor/customer located in the European Economic Area (“EEA”), Dealvector is the data controller of your information, including User-Supplied Content. DealVector’s Data Protection Officer can be contacted at info@dealvector.com.

Our legal basis for collecting and using the PII, CI, and UIC described above will depend on the information concerned and the specific context in which we collect it. However, we will normally collect information from you only where we have your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect information from you.

If we ask you to provide information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your information is mandatory or not (as well as of the possible consequences if you do not provide your information). Similarly, if we collect and use your information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

10. Data Retention Retention of Personal Information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your information, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request and if, in our sole discretion, we do not believe we have a regulatory obligation to maintain such information.

If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription

Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your information, from the Subscription Service. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your DealVector account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

11. Contact, Corrections and Updates

Questions, comments, or complaints with respect to this policy and DealVector privacy practices may be sent to info@dealvector.com.

Users may adjust PII at any time by logging onto the Service and using the Account management feature. All information must continue to be current, accurate, truthful and complete.

12. Reasonable Efforts

DealVector will use reasonable efforts to comply with this Privacy Policy and will take prompt corrective action upon notice of any failure by DealVector, any User or any third party to comply with our Privacy Policy. DealVector sometimes releases beta versions of products and services, which are further refined before the release of the final version. Any beta versions released for use in the Service shall be identified as such to the Users. Because these products and services are still in a test phase, DealVector may not always catch an unintended privacy issue, despite efforts to do so. As such, DealVector welcomes User feedback on any privacy concerns. In light of the above and because of the complex and constantly changing nature of DealVector’s technology and business, and the security risks associated with using the Internet, DealVector does not guarantee error-free performance under this Privacy Policy. DEALVECTOR SHALL NOT BE LIABLE FOR ANY INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES RELATING TO THIS PRIVACY POLICY.

13. Modifications of the Privacy Policy

DealVector will inform Users of any substantive modifications to this Privacy Policy that affect User obligations to DealVector or any other User or DealVector’s or any other User’s obligations to other Users by: (a) sending Users an email at the email address provided as part of the registration process or including a notice in regular email correspondence to Users, or (b) by a message to the User at the time the User logs into the Service. If Users do not agree with any such modifications, the sole remedy is the termination of such User’s Account, which User may effect by sending an email to info@dealvector.com. User’s continued use of the Service after receiving notice of any modifications indicates User acceptance of the modified Privacy Policy. Users also agree to review this Privacy Policy periodically so that User remains aware of any modifications.