Legal

Privacy Policy

Last updated: February 19, 2024

I. Introduction and application

The Dealboard platform is a technology solution developed by Dealboard (the “Platform”). It consists of a suite of cloud-based software to disseminate information about the private markets sector, expand access to investments in this sector and facilitate the communication and integration among regulated and unregulated vendors engaged with offerings of securities of the private markets sector, registered before regulatory bodies, and final clients, generating better understanding and education about the private market industry as a whole.

Due to the services provided by Dealboard, it is necessary to collect Personal Data from all those who access and register on the Platform and the privacy of information is very important to Dealboard components, which has as one of its principle’s respects for the confidentiality of information and Personal Data.

The purpose of this Privacy Policy (“Policy”) is to inform you how Dealboard treats the Personal Data it has access to in the context of the registration made through the Platform, whether being the Investment Manager and/or the end user, in accordance with current legislation, namely the ADPPA (American Data Privacy and Protection Act), as well as other applicable legislation according to the place of data collection and the user’s residence.

This Policy applies to the processing of Personal Data of all those who register, subject to Dealboard’s Terms of Use, by registering on the Platform.

The terms hereby written but not defined in this Policy will be interpreted in accordance with Dealboard’s Terms of Use and Agreement.

For the purposes of this Policy, below are some important definitions:

  • Personal Data — Any information provided and/or collected, even if public, by the Platform, by any means, that: (I) identifies, or, when used in combination with other information processed on the Platform, makes the user identifiable.
  • Processing of Personal Data — Any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
  • Purpose — is the objective that Dealboard wishes to achieve from each act of processing Personal Data.
  • Necessity — is the limitation of the processing of Personal Data to the minimum necessary for the fulfillment of its purposes, avoiding the excessive collection of information.
  • Legal grounds — is the basis in the ADPPA (American Data Privacy and Protection Act), among other legislation that may apply, authorizing the processing of Personal Data for a specific purpose by Dealboard.
  • Consent — is the free, unequivocal and informed authorization given by the holder of the Personal Data for Dealboard to process their Personal Data for a specific purpose.

For more information about the processing of your Personal Data, please contact us at dpo@dealboard.co.

II. How your personal data is collected

The Platform may collect your Personal Data in various ways, such as:

1. When provided by filling in forms, questionnaires, e-mails, applications, contracts, by submitting personal documents, printed or scanned, in situations where you:

  • register and qualify for the services provided by Dealboard;
  • request the sending of Dealboard materials;
  • create an account on the Platform;
  • provide or intend to provide services to Dealboard;
  • is or intends to become a Dealboard Partner;
  • participates in a survey promoted by Dealboard; and
  • gets in touch, through the channels made available on the Platform, to provide feedback or request information.

2. Through public sources (e.g. public websites, public databases) or through sharing by a third party, carried out without violating any legal obligation to which you are subject.

III. The kind of data we may collect

To register on the Platform, the following data may be requested:

  • Identification, registration and contact data (if an individual): full name, nationality and place of birth, date of birth, gender, marital status, mother’s and father’s name (optional), full address, telephone number and e-mail address.
  • Identification, registration and contact details (if a legal entity): company name, fantasy name, nationality, date of incorporation, names of partners/shareholders, full address, telephone number and e-mail address.
  • Identification documents: copies and/or numbers of identification documents such as ID, CPF, Passport, CNPJ, EIN number and professional licenses, issuing body and date of issue, copy of the legal entity’s articles of incorporation up to date.
  • Professional information: academic background and profession. If employed: company name and full address.
  • Procedural Data: information related to administrative and judicial actions, protests, among others.
  • Identification as a Politically Exposed Person: information related to a politically exposed person, when applicable.
  • Financial Information: source of income, assets and shareholdings.
  • Banking Information: bank, type of account, branch number and current account.
  • Other Information: whether you are a US Person and whether you are tax resident in other countries.

IV. Why do we collect and process your personal data?

The Platform collects and process data to promote integration between the service providers and the end users, thereby streamlining processes and enriching the overall quality of interaction between the parties.

Accordingly, the Personal Data collected may be processed for the following purposes:

  • authenticating identity in order to fulfill “KYC” obligations;
  • preventing and detecting fraud, financial crime and market abuse;
  • to measure and manage the risks to which it is subject when contracting with the client, partner or service provider;
  • complies with judicial or administrative orders;
  • dealing with customer complaints and requests;
  • sends communications and satisfaction surveys;
  • for the purposes of security and operation of Dealboard’s IT systems;
  • for analyzing behavior on the Platform (in this case the information used does not identify the user, as it is anonymized. Therefore, such information is not considered Personal Data under current legislation); and
  • for sending marketing communications, by e-mail, telephone or other previously agreed forms.

Consent

Consent to the processing of Personal Data, as well as the use of the services available on the Platform, is given through acceptance of the Terms of Use.

Consent to the sending of communications and marketing emails can be revoked by using the unsubscribe option in the footer of the emails.

V. Sharing platform information

Dealboard will not disclose the Personal Data of its users, service providers and partners, except when:

  • with third-party service providers who assist in the operation of the Platform;
  • for risk control;
  • for financial or regulatory reporting; and
  • it is necessary due to obligations arising from the law, rules and regulations, judicial or administrative order.

In these cases, your Personal Data may be shared with:

  • public administration bodies and entities;
  • administrative and self-regulatory entities; and
  • professional advisors, such as law firms, accountants, auditors, tax consultants.

VI. International data transfer

In addition to its operations in the United States, Dealboard also provides services in North America, Central America, South America, Europe and Asia. Therefore, Dealboard’s platform may transfer Personal Data to other countries, when required by law.

For countries that do not have an adequate level of regulation for the protection of Personal Data compared to the ADDPA, we will implement operational and contractual measures for the transfer of Personal Data.

VII. How long your data will be stored on the platform

The Platform will keep your Personal Data collected during the relationship with you and in accordance with the purposes for which they were collected, and will store your Personal Data for the period necessary to:

  • fulfill the purpose of processing the data;
  • defense of Dealboard’s interests in administrative, judicial or arbitration proceedings; and
  • compliance with legal or regulatory obligations.

After the period mentioned above, or when the user so requests and a Dealboard component evaluates their request for deletion, the Personal Data will be deleted, except in cases where the maintenance of the data is due to a legal or regulatory obligation.

VIII. How does Dealboard protect your personal information and data?

Dealboard employs technical security and organizational measures to protect your information and Personal Data. Data will be stored in a secure operating environment that is not accessible to the public.

Dealboard strives to protect the privacy of Personal Data and other information that is stored, however total security cannot be guaranteed. Unauthorized use of accounts, hardware or software failure, as well as other factors can compromise the security of your Personal Data at any time. In this sense, no transmission over the Internet can be guaranteed to be completely secure.

Consequently, Dealboard does not represent, authorize or guarantee that personal information will be protected against invasion by hackers or any other unauthorized form or device in the Internet environment.

Therefore, if the user identifies or becomes aware of anything that compromises the security of Personal Data, Dealboard asks that you contact us via e-mail at compliance@dealboard.com or any other form of contact you choose from those made available by Dealboard for this purpose.

IX. What are my rights in relation to personal data?

In compliance with current and applicable regulations regarding the protection of Personal Data, Dealboard respects and guarantees the user the possibility of submitting requests based on the following rights:

  • request access to your Personal Data;
  • request confirmation of the existence of the processing of your Personal Data;
  • requests the correction of incomplete, inaccurate or outdated data;
  • requests the anonymization, blocking or deletion of Personal Data, in specific situations;
  • revoke consent to the processing of your Personal Data, in specific situations;
  • request the deletion of data processed with the user’s consent;
  • request information on the possibility of not giving consent, as well as being informed of the consequences in the event of refusal;
  • review automated decisions made solely on the basis of the automated processing of Personal Data; and
  • to object to Processing carried out in one of the cases where consent is waived, in the event of non-compliance with the provisions of the ADDPA and other applicable legislation.

Requests can be made via e-mail to compliance@dealboard.com.

X. Legal warning

Dealboard is not responsible for the misuse or loss of Personal Data to which it has no access or control.

All the technical materials and other content available on the Platform are for information purposes only and do not constitute financial, legal, tax, accounting, or any other type of recommendation.

The Platform may contain links to other external websites, the content and privacy policies of which are not the responsibility of Dealboard.

XI. Changes to the privacy policy

The Platform may update this Privacy Policy from time to time. We recommend that users review this Policy regularly to stay informed about our privacy practices.

XII. Contact us

If you have any questions or concerns about this Privacy Policy, please contact us at our channels available on the Platform.

By using the Platform, users agree to the terms of this Privacy Policy.