Decile Hub Privacy Policy
Decile Group Inc. (“Decile Group” or “we”) are committed to protecting your privacy. We have prepared this Privacy Policy (this “Privacy Policy”) to describe to you our practices regarding the Personal Data we collect from users of our Sites and the Materials that are made available or enabled via the Sites. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data, and for registered members of Decile Hub may include additional data as outlined below. “Sites” means our websites and the services offered on those Sites which includes access and information available on our channels such as LinkedIn, Twitter and Slack. The word “Materials” refers to the information, reports, data, templates, agreements and other materials on the Sites. You automatically agree to this Privacy Policy simply by using or logging into the Sites or using the Materials.
We want to assure you that we do not sell your Personal Data and will use the Personal Data only for the purposes outlined in this Privacy Policy. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at the following address:
Decile Group Inc.
Attn: Legal
Email: legal@decilegroup.com
Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Information You Provide to Us. We may collect Personal Data from you. If you provide us feedback, post an event or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the form, in order to send you a reply. We may also collect Personal Data at other points in the Sites that state that Personal Data is being collected.
Information Collected via Technology. To make our Sites more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP“) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole. For example, some of the information may be collected so that when you visit the Sites, it will recognize you and the information could then be used to provide information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
Cookies. Like many online services, we use cookies to collect information. “Cookies” are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes those cookies. You can find out more information about cookies at http://www.allaboutcookies.org/. Cookies are widely used in order to make sites work, or to work more efficiently, as well as to provide information to the owners of the platform. We use cookies to enhance the online experience of our visitors and to better understand how our site is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor. This type of information is collected to make the Sites more useful to you. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Sites. Our Sites use the following types of cookies:
- Cookies necessary for essential purposes: These cookies are essential to provide you with services and features available through our Sites.
- Analytics Cookies: These cookies are used to collect information about how visitors use our Sites. The information gathered does not identify any individual visitor and is aggregated. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
- Performance Cookies These cookies collect information about how visitors use the Sites, so that we can analyze traffic and understand how our Site is performing.
- Functionality Cookies: These cookies allow our site to remember choices you make and provide enhanced, more personal features.
- Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social networking site. This information may be linked to targeting/ advertising activities.
Do Not Track Browser Setting. We do not currently respond to “do not track” signals from web browsers.
Pixel Tags. We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
Collection of Data by Advertisers. We do not use third parties to serve ads on the Site or collect personally identifiable information about your online activities over time and across different websites.
Google Analytics. We use Google Analytics to help analyze how users use the Sites. Google Analytics uses Cookies to collect information such as how often users visit the Sites, what pages they visit, and what other sites they used prior to coming to the Sites. We use the information we get from Google Analytics only to improve the Sites. Google Analytics collects only the IP address assigned to you on the date you visit the Sites, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Sites, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can avoid the use of Google Analytics relating to your use of our site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
General Use of Your Personal Data. In general, we use your Personal Data in the following ways:
- provide improved administration of the Sites;
- improve the quality of experience when you interact with the Sites;
- send you follow-up communications when you contact us via e-mail, submit feedback, or post an event;
- send you administrative e-mail notifications, such as updates regarding the Sites, security, or support and maintenance advisories; and
- to determine which of our services and products could be useful to you and to send you information on such services and products.
Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of, and improve navigation on, the Sites. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
Uploaded Documents. Documents that are uploaded to the Sites for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with Personal Data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that users keep back-up copies of their documents.
Third Party Service Providers. We may share your Personal Data with third party service providers for the following purposes:
- provide you with Materials;
- conduct quality assurance testing;
- provide technical support; and
- provide other services to us.
These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
Corporate Restructuring. We may share some or all of your Personal Data with entities within our group of companies. We may also share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
Other Disclosures. Regardless of any choices you make regarding your Personal Data, we may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Decile Group; (c) to protect or defend the rights or property of Decile Group or users of the Sites; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
Third Party Websites. The Sites may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Data Protection. We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Sites. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
Members of Decile Hub
If you become a registered member of Decile Hub (“Decile Hub”), we may collect additional Personal Data from you that may include the types of information listed below.
| Category | Details |
|---|---|
| Identity Data | First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, picture, signature, social security number and/or tax identification number, password, copies of ID cards or other forms of identification. |
| Contact Data | Your home address, work address, billing address, email address and telephone numbers. |
| Professional Background Data | Educational and professional history, interests and accomplishments, job and salary preferences, third party recommendations, projects completed. |
| Online Presence Data | Links to your public account pages at social media websites, links to personal websites, and other online materials related to you. |
| Financial Data | Your bank account and payment card details, statements about your wealth and financial situation. |
| Transaction Data | Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history). |
| Investment Data | Information about your investment objectives, investment experience, prior investments, and information provided by completing documents. |
| Content Data | Any content you post to Decile Hub not already included in another category, including without limitation, your profiles, questions, preference settings, answers, messages, comments, and other contributions, and metadata about them (such as when you posted them) ("Content"). |
| Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties and your communication preferences. |
| Behavioral Data | Inferred or assumed information relating to your behavior and interests, based on your online activity. |
Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available. Examples of these sources are broken down in the table below.
| Third party data source | Categories |
|---|---|
| Credit Reporting Agencies |
|
| Social Media Sites |
|
| Our Affiliates |
|
| Our Fund Administration Partners |
|
| Analytics Providers |
|
| Advertisers |
|
| Data Brokers |
|
| Identity Verification and Compliance Service Providers |
|
Google Gmail. If you sign up for Decile Hub with a Gmail address and upon your authorization, Decile Hub will automatically sync with your Gmail account. This means that Decile Hub will access your Gmail contacts, emails, calendar, distribution lists, subject lines and URLs of tracked links from your email, if you use the email tracking functionality. In addition, you can use Decile Hub to read, modify, create, and send emails from your Gmail account. Decile Hub will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and email bodies. By default, synced emails are visible to account owners and admins, and you may make them visible to other members of your team.
Google Calendar. Upon your authorization, Decile Hub also automatically syncs with the Google Calendar application, accessing your calendar events and tasks in your Google Calendar. It also allows you to create and edit events and tasks and send invitations from your Google Calendar account.
Google Drive. You have the option to connect your Google Drive account to Decile Hub. If you choose to do so, you will be able to see your files, upload and download your files, and store file contents and titles on Decile Hub. Decile Hub uses these permissions to associate files with records stored on our platform and allow users to share them with clients and other users.
What additional requirements apply to information collected through our Gmail integration and Google APIs? Decile Hub enables you to read, create and modify messages in your Gmail account. In order to provide you with this service, we obtain, process and store a copy of the Google user data contained in or associated with messages in your Gmail account, such as the email addresses of persons to whom you send or from whom you receive messages in your Gmail account, electronic copies of the files attached to those messages, and the contents of those messages (all such data, "Google User Data"). We will use Google User Data only to provide or improve user-facing features of Decile Hub that are prominent in the user interface. We will only transfer Google User Data to unaffiliated third parties (a) if necessary to provide or improve user-facing features that are prominent in the user interface, (b) as necessary to comply with applicable law or (c) as part of a merger, acquisition or sale of assets with notice to you. We will not use or transfer your Google User Data for serving ads, including retargeting, personalized or interest-based advertising. We will not allow humans to read your Google User Data unless we have first obtained your affirmative agreement for specific messages; it is necessary for security purposes (such as investigating a bug or abuse); it is necessary to comply with applicable law; or our use is limited to internal operations and the data (including derivations) have been aggregated and de-identified. Note that we may obtain personal data that is included in your Google User Data from sources other than the messages in your Gmail account. For example, we may obtain your email address when you register for Decile Hub. Personal data that we obtain from sources other than messages in your Gmail account is not considered Google User Data for the purposes of this Privacy Policy and is not subject to the additional requirements described above. Our use and transfer to any other application of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Your Choices Regarding Information. You have several choices regarding the use of information on the Sites:
- Email Communications. We may periodically send you free newsletters and promotional e-mails if you have indicated that you would like us to do so. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.
- Cookies. If you decide at any time that you no longer wish to accept Cookies from the Sites for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions, or all functionality, of the Sites. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
- Changing or Deleting Your Personal Data. Personal Data submitted by you for document generation and other purposes will be retained for such period as may be required to fulfill the purposes set out in this Privacy Policy, or such other period as may be required by law. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required by law to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
If you reside in Singapore, you may request to access and/or correct your Personal Data currently in our possession by writing to us. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data.
If you reside in the UK or any country within the European Economic Area (“EEA“): Decile Group Inc. is the Controller (for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and any implementing legislation or legislation having equivalent effect in the UK (together, “EU Data Protection Legislation”)) of your Personal Data.
- The legal basis of our processing of your Personal Data as described in this Privacy Policy is our legitimate interests where those interests are not overridden by the impact on you (unless our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us at the address or phone number above.
- We ask that you not provide us with any Special Category Personal Data (as defined in the GDPR), e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership, or any criminal background information. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through any of the Sites.
- We may transfer your Personal Data to a country outside the UK or EEA in accordance with requirements prescribed under EU Data Protection Legislation. When we transfer your Personal Data outside the UK or EEA, we hold it subject to appropriate safeguards and controls and ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards: We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
- Your Rights Regarding Your Personal Data: you have certain, you have certain rights regarding your Personal Data and may, in certain circumstances, ask us to take the following actions in relation to such data: (a) provide you with information about our processing of your Personal Data and give you access to such data; (b) update or correct inaccuracies in your Personal Data; (c)delete your Personal Data; (d) transfer a machine-readable copy of your Personal Data to you or a third party of your choice; (e) restrict the processing of your Personal Data; and (f) object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
If you reside in Singapore: You agree that your accessing or using the Sites in any way constitutes your agreement that (a) we may process your Personal Data for the purposes identified in the Privacy Policy, and (b) your Personal Data may be transferred to and 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. We may transfer your Personal Data to a country or territory outside Singapore in accordance with requirements prescribed under the Singapore Personal Data Protection Act (“PDPA“) to ensure that we provide a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA. By providing your Personal Data, you consent to such transfer. We will take commercially reasonable efforts to ensure that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that the purpose for which your Personal Data was collected is no longer being served by the retention of such Personal Data.
Children under 16. The Sites and the services available on the Sites are not intended for children below 16 and we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under the age of 16, please do not submit any personal information through the Sites. We encourage parents and legal guardians to monitor their children's Internet usage to instruct their children never to provide personal information on our Sites. If we become aware that we have collected personal information from a child under age 16, we will take steps to remove that information.
Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.