Privacy Policy

LAST UPDATED: July 29, 2021

INTRODUCTION

PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE CONTINUING TO USE OUR SITES LOCATED AT HTTPS://WWW.IDEALSVDR.COMWWW.IDEALSCORP.COM, AND ANY SUBDOMAINS, AS APPLICABLE (“SITE”), WEB, MOBILE AND/OR DESKTOP APPLICATION (“APPLICATION”), VIRTUAL DATA ROOM AND/OR OTHER OUR SERVICES (“PRODUCT”). BY CONTINUING TO USE IDEALS’ SITE, APPLICATION OR PRODUCT YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.

iDeals group of companies includes iDeals Solutions Group Limited, iDeals Solutions Group, iDeals Solutions Operations Limited and their affiliates (“iDeals”, “we” or “us”) who are committed to respecting your data privacy and keeping your information secure and confidential.

This Privacy Policy (“Privacy Policy”) explains how iDeals collects, uses, shares, and secures the Personal Information you (“customer”, “you” or “your”) provide during your online and offline interactions with us in connection with the Site or Application in order to use the Product.

As used in this Privacy Policy, “Personal Information” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, phone number, title, and other personally identifiable information.

iDeals will be the controller of your Personal Information that is provided, collected and/or processed pursuant to this Privacy Policy by you directly. If you have any questions about whether any of the foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.

This Privacy Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our Site.

COLLECTED INFORMATION

This Privacy Policy applies to Personal Information we collect from you through our Site or Application. We obtain Personal Information in the following forms: (i) information provided by you, for example as part of the sign-up process, and (ii) information that we obtain or collect automatically from your use of the Site or Application, and Product.

Personal Information provided by you: Product offered to visitors of the Site and users of the Application require you to register for a personal account with iDeals (“Personal Account”). When registering for a Personal Account, iDeals will ask you to supply us with certain information about yourself by filling out and submitting an online form. iDeals may ask you to voluntarily supply us with certain information about yourself by filling out and submitting an online form for marketing purposes as well.

To become a registered user you will have to create a Personal Account. Its creation implies providing the following information:

Information that we obtain or collect automatically from your use of the Site or Application: We may automatically collect certain information from your use of the Site or Application, such as usage data, preferences, or any other information concerning how you use the Product.

In particular, our servers automatically record certain information and/or we may use cookies (small text files placed on a device’s hard disk by a web service) or similar tracking technologies to collect the following types of information:

Please note that you may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser. Additional information on how we use cookies and other tracking technologies and how to control them can be found in our Cookie Policy.

In addition, by using our Site or Application, network information such as Product usage information, may be transmitted back to us. It helps us to determine how users are interacting with our Product, improve our Product, and correct any problems that may occur.

We record calls for the purpose of quality control as our legitimate interest, on the basis of the Article 6 section 1 letter f of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Call recordings are stored for the period of 36 months as of the date of a record unless we receive a request for erasure/withdrawal of consent/access earlier as indicated in this Privacy Policy.

REFERRALS

If you choose to use our referral service to invite a third party to use our Product, you represent that you have such third party consent to provide us with his/her Personal Information such as:

We will automatically send such a person a one-time email inviting him or her to visit the Site and use Product. This person will be required to accept this Privacy Policy to continue using the Product.

If you choose to use our additional service such as USB flash drive delivery for a third party, you may be requested to share the following information about this third party:

In this case you represent that you have such third party consent to provide us with his/her Personal Information.

GEOLOCATION

We collect your location based information such as country, region, city for the purpose of optimizing your connection to our data center. We will only share this information with our data center provider for the sole purpose of providing our service and Product to you.

If you prefer to restrict sharing your information in this manner you may opt-out of location based services at any time by changing the settings in your Internet-connected device or by contacting us using the information in the “Contact Us” section of this Privacy Policy.

REGISTRATION OPTIONS

As described above, we will ask you to create a Personal Account to enable you to use the Product. Once the Personal Account is created, you will be able to access, review and update your personal account information online via the Site or the Application.

When you sign-up, you, therefore, consent to receive system emails, communications from our customer support team and newsletters about Product updates from us. If you would like to discontinue receiving these notifications, you can update your preferences by clicking the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this Privacy Policy.

Please note that you may choose not to create the Personal Account. If you choose so, you will still have access to many of the Site’s web pages, however, you may be unable to access certain options and services that we offer only to registered users.

USE OF PERSONAL INFORMATION

iDeals uses your Personal Information to:

PROCESSING AND SHARING YOUR PERSONAL INFORMATION

By accessing or using the Site, Application, or Product, or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have privacy laws different from your country of residence. Please note that some of the recipients of your Personal Information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations. If the recipient is not a member of the iDeals group of companies, the adequate safeguard might be provided by signing a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.

We may also share Personal Information with third parties including as follows:

In some cases, we may share your information with third-party vendors to understand which areas and features of the Product are most popular and/or to improve the overall effectiveness of the Product and its features.

COLLABORATION AND SHARING FEATURES

iDeals offers collaboration features or other integrated tools, which allow you to share your сontent through the Product. Because these features are of the collaborative nature of the Product and are based on the permissions and settings you choose, their use enables you to share сontent with people you want to collaborate with. You can choose to change your settings at any time for a file or folder through your account.

SECURITY OF INFORMATION

Personal Information you provide to us is protected by the password you create when registering to use the Site, Application, and Product. Please understand that you can help prevent the unauthorized disclosure of information by choosing and protecting your password appropriately. You can also help

prevent unauthorized disclosure by not sharing your password and preventing others from using your computer or mobile device.

We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:

We use commercially reasonable security procedures to protect all collected Personal Information. Please understand that no security system is perfect and, as such, we do not guarantee the security of the Site, or that your Personal Information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email. We will take reasonable steps to remedy the breach.

DATA SUBJECT RIGHTS

You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests. We may ask you to provide us with additional information in connection with your request. If we need to verify your identity or the nature of your request, we may ask you to provide more details regarding your Personal Information. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy.

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our affiliates and/or third parties for marketing purposes) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

When offering services to its customers, iDeals acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA using the information set forth in the “Contact Us” section below.

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of service. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

ACCESS BY MINORS

iDeals does not knowingly collect or store any Personal Information from or about children under the age of 18. If you believe a child under the age of 18 has under any circumstances provided us with their Personal Information and data, ask a parent or legal guardian of that child to contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy and request to delete their children’s information from our records.

CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect customer feedback and changes in our Site, Application, or Product. When we post changes to a statement, we will revise the “last updated” date at

the top of the statement. If there are material changes to the statement or any changes in the way how iDeals will use Personal Information, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification.

USER CONSENT

By using Site, Application, or Product you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes given above as well as those explained where iDeals collects Personal Information.

RECOURSE, ENFORCEMENT AND LIABILITY

Since iDeals is committed to protect your privacy as set forth in this Privacy Policy, if you think we are not in compliance with our Privacy Policy, or if you have any question or if you wish to take any other action concerning this Privacy Policy or your Personal Information, we encourage you to contact us using the contact details set forth in “Contact Us” section below. We will investigate your complaint, take appropriate action and report back to you within 30 days.

With respect to complaints concerning Personal Information that is transferred from the EU, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. iDeals will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning Personal Information that is transferred from the EU to the United States.

For complaints concerning Personal Information that is transferred from Switzerland, we commit to cooperate with Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the FDPIC. Complaints regarding handling of personal data pertaining to EU and Swiss citizens may be reported by the individual to the relevant Data Protection Authority.

The resource mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

CONTACT US

If you have any inquiries or complaints, you may contact us: