dv01, Inc. Privacy Policy

Introduction

Who We Are

dv01, Inc. (“we,” “our” or “us”) provides an all-in-one data management, reporting, and analytics platform that brings transparency and insight to lending markets—making them more efficient for institutional investors and safer for the world. 

While using  our products and services (including the dv01.co and dv01app.com sites, collectively, the “Services”), we collect personally identifiable information (“Personal Information”) from our users. Personal Information is any information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual.

Scope of Privacy Policy

This Privacy Policy describes the collection, use, maintenance and disclosure of your (“you”, “your”) personal information in connection with your use of the Services and the steps that we take to safeguard it. It does not apply to information collected by us offline or through any other means not described in this policy, or to information collected by any third party linked to via the Services. By using the Services you agree to the collection and use of information in accordance with the terms of this policy.

In the event of any conflict between this Privacy Policy and a definitive agreement entered into between us and you, then the terms of the definitive agreement shall govern.

Processing of Personal Data

The Services may include the transfer to dv01 of Personal Information. We use Personal Information to provide Services to our customers. When dv01 receives Personal Information, dv01 is acting as the "processor" and its customer or business partner is the "controller" of such data. Our customers or business partners retain responsibility for obtaining the appropriate consents or other lawful basis for processing such Personal Information under applicable law. With respect to data generated as part of the use of dv01 Services, dv01 acts as a "controller".

Information That We Collect

Information You Provide Voluntarily

We collect Personal Information that you voluntarily enter while using our Services to meet legitimate business interests. For instance, when you voluntarily enter your registration information to access the site or when you contact us with comments or inquiries, we collect the following Personal Information:

  • full name

  • email address

  • phone number

Information That We Collect Passively

Like most websites, in order to meet the legitimate business interest to give you the best possible user experience, improve the quality of our Services, or address technical issues, we automatically collect some technical information during your use of the Services.

Usage Data

For each page that you visit, we collect:

  • Internet Protocol (IP) addresses

  • Browser type

  • Internet Service Provider (ISP)

  • Referring/exit pages

  • Operating System

  • Date and time of access

Aggregate Information

Aggregate Information refers to aggregated and anonymized data collected or derived from the use of the Services, including data on the number and types of assets managed through the Services, how many users used or viewed a particular product or data set over a certain time span. 

Cookies/Web Beacons

Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We collect data using both session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them). We also use web beacons, page tags, pixels or similar tools and information to gather and store “clickstream information.” You can choose what cookies are used on dv01.co by selecting the cookie notice settings menu. 

How We Use Your Information

We use the Personal Information that you provide voluntarily to send business updates, event announcements, promotional materials or other information to you via newsletter. 

We use Personal Information that we collect passively to enhance, improve, operate, and maintain our Services, as well as to develop new products and services.

We use your information for legitimate business and marketing purposes, including:

  • To enable your access to and generally supply the Services

  • Support internal business operations, including assessing and managing risk

  • Analyze usage of the Services

  • Issue benchmarking and other similar reports

  • Send marketing emails

  • Respond to your requests

Disclosure & Sharing of Information

We also share information, including Personal Information, with third-party processors who provide hosting, maintenance, and other services that support our business. These third-party service providers may have access to or process your Personal Information for the purpose of providing these services for us. Where it is necessary to share your Personal Information to these third parties, such Personal Information will only be used for its intended business purposes. Unless we tell you differently, these companies do not have any rights to use your personal information that we share with them beyond what is necessary to assist us.

Legal & Compliance Disclosures

We may disclose, read, preserve any information including your Personal Information to comply with legal, regulatory or government obligations and requests, detect or prevent fraud, security or technical issues, audit reports, to defend our property rights or to prevent wrongdoing.

Business Transfers

If we are acquired, merge, reorganize, dissolve or undergo a change of control or other similar corporate event, user information, including Personal Information, may be one of the assets that is transferred or acquired by a third party as one of our business assets. We do not currently have a parent company or any affiliates. In the future we may share your information with these subsidiaries or affiliates. They will be subject to the same obligations set out in this policy.

Security of Information

Trust and transparency are at the core of our business. To that end, we protect your personal information against unauthorized access, alteration, disclosure or destruction using appropriate techniques. Your data is always encrypted when stored on our platform or systems and is removed when no longer needed (Please note that some information may remain in our records after deletion of your account to satisfy legal obligations or where we believe that we have a legitimate reason to do so.) However, we recognize that not all security breaches may always be preventable. We maintain multiple layers of security and privacy controls in place to detect and respond to identified security incidents, but we do not guarantee or warrant that the techniques we employ will prevent all breaches of information about you that we store.

Choice

If you receive commercial email from us, you may unsubscribe at any time by following the unsubscribe link or other instructions contained in the email message. You can choose what cookies are used on dv01.co selecting the cookie notice settings menu. Persistent cookies can be removed by following your browser’s instructions (for more information, see allaboutcookies.org). Please note: if you choose to disable cookies, some of our Services may not work properly.

Additionally, you may request deletion of your personal information using the contact information provided below. In all instances, you can choose whether to provide your Personal Information at your discretion. However, choosing not to provide Personal Information may prevent you from being able to fully use the Services.

In general, you have the right to object to processing by emailing us using the contact information below. Please note that doing so may prevent your ability to use our Services.

Do Not Track “DNT” option

Your browser may offer you a DNT option. DNT is a privacy option that you can set in your web browser which allows you to indicate that you do not want certain information about your online activity tracked over time and across different websites. We currently do not support DNT requests, which means that we continue to collect your information as described in this policy.

Access

You may update any Personal Information that you provide to us by logging into your account and accessing your account settings.

Non-U.S. Users

Please be advised that your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal data may be less stringent than the laws in your country. If you have concerns about our processing of your personal data, please do not use the Services.

EEA Residents

We collect your explicit consent before processing personal data collected using cookies. The legal basis on which we process other personal data is our legitimate interest to improve our services, address bugs, and enhance the user experience for our products. When legitimate interests serve as the basis for data processing, you have the right to object at any time.

You are also afforded the following rights over the use of your personal data under the European General Data Protection Regulation (“GDPR”):

  • Right to be informed – you must be informed of the types of personal data collected from you, the purposes for processing said data, and of the contact details of the individual responsible for data privacy

  • Right to access – you may request access to your personal data being processed, along with the purpose(s) for processing, and the estimated retention period

  • Right to rectification – you may request that your personal data be corrected where inaccuracies are identified

  • Right to erasure – you may request that your personal data be erased by dv01

  • Right to restrict processing – you may request that your personal data not be processed under certain circumstances, including where the accuracy of the data is contested or where the data is no longer needed

  • Right to data portability -  you may request that a copy of all personal data be provided to you

If you are an EEA resident and wish to make a request, please use the contact information found in the “Contacting us” section of this policy and we will contact you within one month.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the relevant supervisory authority for your location. The full list of European data protection authorities can be found here.

California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the address listed in Contact Us below.

Children’s Privacy

Our Site is not directed to children under the age of 18. We do not knowingly collect Personal Information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. We will take immediate steps to remove that information.

Contacting us

If you have any questions or concerns regarding your privacy when using the Services, please send us a message to support@dv01.co. We will make every effort to resolve your concerns.

You may also get in touch by writing to us at:

dv01, Inc. Attn: Legal Department 915 Broadway Suite 601 New York, NY 10010

Changes to This Policy

We may amend this Privacy Policy from time to time. We encourage you to review it regularly to stay informed about how we collect, use and disclose personal information.

Last Updated: March 2020

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915 Broadway, Suite 601
New York, NY 10010
Phone: 646-854-5258
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