Privacy Policy

1 Purpose of Privacy Policy

In this Privacy Policy, 'us,' 'we,' or 'our' refers to Deeligence Pty Ltd ACN 665 609 307 (UK Company Number FC043030) and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store, and disclose your personal information.By providing personal information to us, you understand that we will collect, use, and disclose your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy. This Privacy Policy also applies to personal information that we collect or receive from third parties, including our clients and service providers. In circumstances where we have collected or received personal information from a third party, we rely on the third party from which we have collected or received the information to inform the individual of our collection and, where applicable, to obtain individual consents from the individual to whom that personal information relates.

For the purposes of UK data protection law the data controller is Deeligence Pty Ltd.

2 What is Personal Information?

Personal information includes information or an opinion about an individual that is reasonably identifiable, whether in a material form or not. For example, this may include a user's name, age, gender, postcode, and contact details.

3 Why does Deeligence Collect, Receive, and Use Personal Information?

We may collect, hold, use, and disclose user personal information for the following purposes:

• To enable users to access and use our website and platform.
• To provide customers with our services.
• To enable us to undertake essential administrative and operational tasks, including recruitment, website analytics, and optimisation.
• To operate, protect, improve, and optimise our website and services, business, and our users' experience, such as performing analytics, conducting research, and for advertising and marketing.
• To send users service, support, and administrative messages, reminders, technical notices, updates, security alerts, and information requested by users.
• To send users marketing and promotional messages and other information that may be of interest to users, including information sent by, or on behalf of, our business partners that we think users may find interesting.
• To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

4 Lawful Basis for Processing (UK GDPR)

Under UK data protection law the lawful bases we rely on for processing your data are:

• Contract: Where processing is necessary to perform our contract with you or to take steps at your request before entering into a contract. This applies to providing our services, managing your account, and responding to your enquiries.‍
• Legitimate interests: Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This applies to improving our services, website analytics, and business administration.‍
• Legal obligation: Where processing is necessary to comply with a legal obligation. This applies to regulatory requirements and responding to lawful requests from authorities.‍
• Consent: Where you have given clear consent for us to process your personal information for a specific purpose.This applies to marketing communications. You may withdraw consent at any time by contacting us or using the unsubscribe link in our communications.

5 What User Information Does Deeligence Collect and Receive?

When a user sets up an account with us, we collect:

• Full name.
• Email address.
• Occupational information for enterprise users (i.e., job title).
• Details of the user's use of our services, including any communication with us (i.e., any support requests).
• Any information provided through feedback surveys or reviews.
• Any other personal information requested by us and/or provided by the user or a third party.

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When an individual fills in information on the Deeligence platform and hosted through our services, we collect the information provided solely for the purpose of providing our services to that individual, including support services as required.

When an individual uses our website or otherwise interacts with us online, we may collect:

• The individual's hashed email, browser session and geo-location data, device and network information (i.e., device ID, device type, geo-location information)statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour.
• Information about the individual's access and use of our Services, including through the use of cookies, communications with our online Services, the typeof browser an individual is using, the type of operating system an individual is using, and the domain name of an individual's Internet service provider and standard web log information.
• Any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or platform accounts from which you permit us to collect information.

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We may collect these types of personal information either directly from you or from third parties. We may collect this information when you:

• Signup for our services.
• Use our forms.
• Communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services, or websites.
• Interact with our sites, platform, content, and advertising.
• Invest in our business or inquire about a potential purchase in our business.
• When you apply for a job or position with us, we may collect certain information from you, from any recruitment consultant, your previous employers, and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.

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In addition, we may receive personal information (including sensitive information), of a kind not listed above, from our clients and users in the course of providing services to them (especially via the filling of our forms).

6 Who does Deeligence Disclose the Personal Information of Users to?

We may disclose personal information for the purposes described in this privacy policy to:

• Our employees and related bodies corporate to perform the services and for our internal business purposes.
• Our clients, as part of the services and in circumstances where that personal information was originally provided to us by that client.
• Third-party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing services to our clients).
• Professional advisers, dealers, business partners, and agents.
• Anyone to whom our assets or businesses (or any part of them) are transferred.
• Specific third parties authorised by users to receive information held by Deeligence.
• Other persons, including government agencies, regulatory bodies, and law enforcement agencies, or as required, authorised, or permitted by law.

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The countries to which we send data for the purposes listed above may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries:

• We will perform those transfers in accordance with the requirements of applicable law.
• We will protect the transferred personal information in accordance with this Privacy Policy.

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7 International Data Transfers (UK GDPR)

When we transfer personal data outside the UnitedKingdom, we ensure appropriate safeguards are in place to protect your information. These safeguards include where applicable:

• Transfers to countries that have been deemed to provide an adequate level of protection by the UK Government
• Use of Standard Contractual Clauses (SCCs) approved by the UK Government.
• Other appropriate safeguards as permitted under UK data protection law.

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You may request a copy of the safeguards we use for international transfers by contacting us at team@deeligence.com.

8 Our Website and Cookies

Our website uses cookies, and we may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone, or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

You do not have to consent to using cookies when you visit. You can also disable them by changing the appropriate settings in your internet browser.

9 Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your data, whether we can achieve those purposes through other means, and applicable legal requirements.

In general:

• Account information is retained while your account is active and for a reasonable period thereafter to allow for reactivation or to comply with legal obligations.
• Due diligence materials uploaded by clients are retained in accordance with our contractual arrangements and applicable regulatory requirements.
• Marketing preferences are retained until you withdraw consent or unsubscribe.

10 Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. However, we cannot guarantee the security of your personal information.

11 Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

12 Accessing or Correcting Personal Information for Users

You can access the personal information we hold about you by contacting us using the details below. Sometimes, we may not be able to provide you with access to all of your personal information, and where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us, and we will take reasonable steps to ensure that it is corrected.

13 Your Rights Under UK Data Protection Law

Under UK data protection law, you have additional rights regarding your personal information. Subject to certain exceptions, you have the right to:

• Request erasure: You can ask us to delete or remove your personal information in certain circumstances, such as where there is no good reason for us to continue processing it.‍
• Request restriction of processing: You can ask us to suspend the processing of your personal information in certain scenarios, for example if you want us to establish its accuracy.‍
• Request data portability: You can request the transfer of your personal information to you or a third party in a structured, commonly used, machine-readable format.‍
• Object to processing: You can object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object. You also have the right to object to direct marketing at any time.‍
• Withdraw consent: Where we rely on consent to process your personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

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To exercise any of these rights, please contact us using the details below. We will respond to your request within one month. There is no fee for making a request, although we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

14 User Privacy Complaints

If you think we have breached an applicable privacy law, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address, and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

UK residents also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. You can contact the ICO at ico.org.uk orby calling their helpline. We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Privacy Contact
Deeligence Pty Ltd
Email: team@deeligence.com