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PREIPO.COM GDPR PRIVACY NOTICE

‍PREIPO.COM GDPR PRIVACY NOTICE

Last Updated: March 1, 2023 

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European Residents

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If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom Data Protection Regulation (the “UK-GDPR” and, together with the GDPR, the “European Privacy Laws”) with respect to your Personal Data, as outlined below.   

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the European Privacy Laws, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. PreIPO will be the controller of your Personal Data processed in connection with the Service. For purposes of this GDPR Privacy Notice, “Personal Data” includes (but is not limited to) user profile data, as defined in our Privacy Policy [Link Here]. 

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, PreIPO’s Privacy Policy [Link Here] (the “Privacy Policy”). If there are any conflicts between this GDPR Privacy Notice and PreIPO’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at privacy@PreIPO.com.   

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Category of Data
Source of Data
Purpose of Processing
Grounds for Processing (e.g. contractual necessity, legitimate interest, consent)
Specific Legitimate Interest (if applicable)
Customer Account Data (e.g. first last name, email, IP address)
Data Subject
Analytics
Legitimate Interest
Monitoring and conducting analytics on website & App use, pages/links clicked, traffic demographics, patterns of navigation, on potential security/spam breach, on performance issues, etc.
Customer Account Data (e.g. first last name, email, company)
Data Subject
Customer Success Communication
Legitimate Interest
Creation of public profiles, improving performance, troubleshooting bugs, other internal development needs.
User Session Data (e.g. page url, utms)
Data Subject
Advertising
Legitimate Interest
Personalization, market research, targeted advertisement, or direct marketing.
Customer Account Data (e.g. first last name, device type, browser)
Data Subject
Product Development
Legitimate Interest
Improving performance, troubleshooting bugs, other internal development needs.
Customer Account Data (e.g. first last name, email, company)
Data Subject
Sales Communication
Legitimate Interest
Targeted advertisement or direct marketing.
Customer Account Data (e.g. first last name, email)
Data Subject
Using PreIPO Products
Contractual Necessity 
Contractual Necessity.
Customer Account Data (e.g. image, gender)
Data Subject
Using PreIPO Products
Legitimate Interest
Creation of public profiles using public known data, personalized service and communications related to the customer’s use of the product.
Billing Data (e.g. first last name, card type, card country)
Data Subject
Analytics
Legitimate Interest
Monitoring and conducting analytics on website & App use, pages/links clicked, traffic demographics, patterns of navigation, on potential security/spam breach, on performance issues, etc.
Billing Data (e.g. first last name, card type, card country)
Data Subject
Customer Success Communication
Legitimate Interest
Personalized service and communications related to the customer’s use of the product.
Billing Data (e.g. first last name, card type, card country)
Data Subject
Product Development
Legitimate Interest
Improving performance, troubleshooting bugs, other internal development needs.
Customer Support Data (e.g. first last name, email, address)
Data Subject
Analytics
Legitimate Interest
Monitoring and conducting analytics on website & App use, pages/links clicked, traffic demographics, patterns of navigation, on potential security/spam breach, on performance issues, etc.
Customer Support Data (e.g. first last name, email, address, last 4 digits of credit card)
Data Subject
Customer Success Communication
Legitimate Interest
Personalized service and communications related to the customer’s use of the product.
Customer Support Data (e.g. first last name, email)
Data Subject
Marketing Campaign (email, list creation, ads)
Legitimate Interest
Personalization, market research, targeted advertisement, or direct marketing.
Customer Support Data (e.g. first last name, email)
Data Subject
Product Development
Legitimate Interest
Improving performance, troubleshooting bugs, other internal development needs.
Customer Support Data (e.g. first last name, email)
Data Subject
Sales Communication
Legitimate Interest
Targeted advertisement or direct marketing.
Customer Support Data (e.g. first last name, email)
Data Subject
Using PreIPO Products
Contractual Necessity
Contractual Necessity.
Person Profile Data (e.g. first last name, news articles, company, investments)
Data Subject, Publicly-available web sources, Third Parties
Analytics
Legitimate Interest
Monitoring and conducting analytics on website & App use, pages/links clicked, traffic demographics, patterns of navigation, on potential security/spam breach, on performance issues, etc.
Person Profile Data (e.g. first last name, news articles, company, investments)
Data Subject, Publicly-available web sources, Third Parties
Product Development
Legitimate Interest
Creation of public profiles, improving performance, troubleshooting bugs, other internal development needs.
User Session Data (e.g. page url, utms)
Data Subject
Advertising
Legitimate Interest
Personalization, market research, targeted advertisement, or direct marketing.
User Session Data (e.g. page url)
Data Subject
Mobile App Marketing
Legitimate Interest
Personalization, market research, targeted advertisement, or direct marketing.
User Session Data (e.g. utms, logged in, xsrf token)
Data Subject
Using PreIPO Products
Legitimate Interest
Maintain logged-in state during a single browsing session. Maintain their logged in state across browsing sessions. Enable users to log back in when a new session is started. Prevent cross-site request forgery attacks. Product feature rollout, conducting analysis. Ad performance and conversion tracking. Personalization of Web Content.

Sharing Your Data

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us or you with services related to the purposes described in this Privacy Notice, our Privacy Policy [Link Here] and our Terms of Service [Link Here]. These parties include: 

  • Payment processors 
  • Fraud prevention service providers 
  • Ad networks 
  • Analytics service providers 
  • Staff augmentation and contract personnel  
  • Hosting service providers 
  • Co-location service providers 
  • Marketing service providers 
  • Product development service providers 
  • Customer success providers 

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include: 

  • Other users (where you post information publicly, direct us to share the information (such as with other members of your team), or as otherwise necessary to effect a transaction initiated or authorized by you through the Service)  
  • Social media services (if you interact with them through your use of the Service) 
  • Third party business partners who you access through the Service 
  • Your vendors and service providers, such as customer relationship management system providers 

We also share Personal Data when we believe it is necessary to: 

  • Comply with applicable law or respond to valid legal process, including requests from law enforcement or other government agencies 
  • Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud 
  • Maintain the security of our products and services 

We also share information with third parties when you give us consent to do so. 

In addition to the foregoing, we share Personal Data that is profile data with other users, our customers, partners, resellers, and our resellers’ customers.  

We also share Personal Data with our affiliates, partners or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy. 
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Security Measures

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. 

  • The PreIPO website uses SSL (https). [Please confirm]
  • Account passwords are hashed when stored in our database. 
  • Access to AWS and Payment Processors is limited and requires Two-Factor Authentication (2FA). 
  • PreIPO performs third-party penetration testing. 

Retaining Your Personal Data. We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service. In some cases we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. 

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Personal Data of Children. As noted in the Terms of Service [Link Here], we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@PreIPO.com.  

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Your Rights Regarding Your Personal Data 

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@PreIPO.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.   

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing privacy@PreIPO.com.  
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by emailing privacy@PreIPO.com. 
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.   
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.  
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.  
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.  
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data. 
  • Right to File Complaint: You have the right to lodge a complaint about PreIPO’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.  

Transfers of Personal Data.

The Service is hosted and operated in the United States (“U.S.”) through PreIPO and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to PreIPO in the U.S. and will be hosted on U.S. servers, and you authorize PreIPO to transfer, store and process your information to and in the U.S., and possibly other countries, as the case may be. You hereby consent to the transfer of your data to and from the U.S. 

PreIPO is committed to the privacy principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse and enforcement with respect to all Personal Data received from you. Please contact us at privacy@PreIPO.com with any questions or concerns relating to your privacy and to resolve your complaints. We commit to cooperate with you as applicable under the law. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means. 

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Questions Regarding Your Personal Data

If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact our Data Protection Officer (DPO) using the following information:    

Email address for contact: privacy@PreIPO.com 

Physical address: [Please provide] 

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5690801.1

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