Last Updated: September 6, 2024

By providing your Personally Identifiable Information (“PII”) details and clicking through the initial registration, you consent to us using and managing your PII (which may more generally be described as “Personal Data”) and other information in accordance with this policy. You have certain rights with respect to this data including rights to withdraw consent, as described herein. This Policy describes our use of your data and related rights, and it should be read together with our Terms of Service.

The Service is intended for a professional audience operating in their professional capacity only, and the customary use case is to facilitate the efficient sharing of financial information with authorized recipients. If you are not operating in a professional capacity, you should not use the Service. Users under the age of 18 are prohibited, and by continuing to use the Service you warrant that you are above that age.

Cookie Policy

We may use functional “cookies” to deliver the Service. The operation of cookies generally is described at http://www.allaboutcookies.org/. Cookies are stored locally on your computer, either in the browser you are using or the hard drive. We may use persistent, session, or flash cookies. You may block them or remove them at any time. However, if you do so you will lose substantial functionality when attempting to access the Service and, in many cases, may not be able to access features at all.  In other cases, your workflow would be impacted; for instance, by needing to log in more frequently. We do not use cookies for marketing and in general strive to configure our systems to track the minimum amount of data necessary to deliver our Services, which is our legitimate business interest. We do not request any additional preference consents on your part with respect to cookies, and by continuing to use the Service you consent to the placement of cookies on your device for these minimal functional purposes. You may always withdraw your consent at any time by contacting us as described in the Terms of Service.

Types of Data

The Personal Identifiable Information (“PII”) that we collect is generally the minimum required to deliver the Service and includes First Name, Last Name, Company Name, Phone, Email, and Professional Role. To deliver some aspects of the Service we also collect and maintain certain Categorical Information (“CI”) with respect to User Accounts such as Asset Class and Deal Affiliations, Deal Document Validation Status, or other information. PII is Personal Data and, in some cases, CI may be Personal Data.

The platform is designed to mediate interests and information among Users interacting in a professional capacity, and by contrast we do not collect personal financial information. Nor do we collect protected classes of information about individuals (such as age, gender or sexual information, health or biometric data, race or ethnicity, marital status; or political, religious or philosophical views or affiliations) although such data may incidentally become disclosed to us. Also, we do not discriminate based on such protected information. We do not collect or retain audio or visual recordings pursuant to the Service. Any inferences we draw with respect to the profile of Users is exclusively related to their preferences in a professional capacity, and not personal information.

”User-Supplied Content” (“USC”) is not PII or CI and is substantive content input by a User for the purpose of delivering information to and/or interacting with other Users on the site. USC may include but is not limited to documents, price information, marking information, analytics, explanatory text, or other similar information, whether delivered via direct upload or via ingestion addresses. A User’s USC 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 USC is shared with other Users on the site, Users should exercise appropriate judgment when delivering USC. Users are responsible for obeying all regulatory and professional standards that apply to their access of the Service and delivery of USC. Certain USC is permission-based and requires disclosure of the requester’s PII for the limited purpose of enabling access to such content.  When you request access to such permissioned USC you consent to the sharing of PII for that purpose.

Personal Data Usage

Our use of Personal Data is designed to support our Business Purpose of delivering the Service. We may collect, hold, use, or disclose your Personal Data to: communicate with you, support internal administrative purposes and client management, comply with legal needs, enable your access to the Service, enable your User preferences, manage and report the access to permissioned USC, update you with respect to the Service functionality or DealVector Content, and maintain Account integrity and combat fraud. We will manage any Personal Data we receive from third parties under the same standards as Personal Data received directly from the subject User. We collect Personal Data from Users and may use third party databases or platforms to investigate and confirm such submitted data.

Personal Data Rights

You have a right to object to this processing as well as the right to access and/or correct your Personal Data, to understand how it is used, as well as to receive a copy of or request deletion of this information. You can opt-out or discontinue using the Service at any time. You can opt-out of receiving emails from us at any time. You can notify us with respect to exercising these rights and/or request to communicate with our Data Protection Officer by sending us an email at our Contact as provided in the Terms of Service. You also have the right to file a complaint with appropriate regulatory authorities.

In the event you choose to limit or terminate the processing of your information, most or all aspects of the Service may become unavailable to you due to the inherent nature of the Service. Most of our clients are in the financial industry and have a strong desire or requirement that data be retained for their compliance purposes. Our policy based on the legitimate business purpose of meeting this need is to retain data for at least seven (7) years. We may disclose and/or retain Personal Data as required by law or regulation and we may disclose to a successor firm or subsidiary firm if it assumes all our obligations in writing with respect to this Privacy Policy and the Terms of Service.

Sharing of Personal Data

We limit disclosure of Personal Data to only those parties having a specific legitimate business purpose for collecting, maintaining or processing such Personal Data. This is generally restricted to our employees and agents, who are subject to strict confidentiality requirements, as well as to Users as described herein pursuant to delivering the Service. To deliver the Service we also rely on certain vendors for fundamental infrastructure and operational support, principally Amazon Web Services, Google Workspace, and Salesforce, who are all based in the United States. We share your PII with them for the limited business purpose of delivering the Service, and they are not entitled by us to use such personal data in any other way. We do not sell Personal Data.

Derivative Works

DealVector reserves the right to disclose certain aggregated and anonymized data that may include 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. We may also create derivative works with respect to USC that is sufficiently aggregated and anonymized such that it does not disclose any User’s PII or any User’s listings of securities or transactions with respect to the disclosures and works described in this paragraph.

Third Party Links

Third Party Links found within the Service are beyond our control. They connect to destinations that have different Privacy Policies than we do and those Policies may change. They are not operated by us and we cannot accept responsibility or liability for their respective privacy practices. You should exercise caution when accessing such links.

Modification

We are continually improving our Service functionality. Because of these ongoing changes, changes in the law and the changing nature of technology, our data privacy practices may change.

DealVector reserves the right, in its sole discretion, to change, modify or otherwise alter this Privacy Policy by updating this posting. Your continued use of the Service following these changes indicates your acceptance of the terms, so you should periodically review this page.