Revised January 2022
This policy does not apply to third-party websites, products, or services, even if they link to our services or Website, and you should consider the privacy practices of those third parties carefully.
Provider assists you in creating, tracking, and maintaining an inventory of assets, including information regarding individuals, business assets, personal property, insurance policies, contracts and warranties (“Services”). Provider obtains Personal Data about you from various sources to provide our Services and to manage our Website. “You” may be a visitor to our Website, or a user of one or more of our Services (“User”).
2. Processing of Personal Data
Personal Data will be collected, stored, processed, and transmitted in accordance with Provider’s established policies and applicable federal, state, local and international laws, rules, and regulations. Provider will do the following with respect to the processing of Personal Data: (1) Process all Personal Data in a fair and lawful manner, (2) Collect Personal Data for specified, explicit, and legitimate purposes and not process it for incompatible purposes, (3) Collect Personal Data in a manner that is adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) Collect Personal Data that is accurate and keep it up to date to the best of our ability, (5) Protect Personal Data from unauthorized access and processing using appropriate technical and organizational security measures and controls; and (6) Retain Personal Data as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.
Although we use appropriate technical and organizational controls to secure and protect your Personal Data, we cannot warrant or guarantee that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.
Provider will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) stored by or for us, in accordance with applicable laws.
3. Collection of Personal Data
Provider may collect Personal Data about you from a variety of sources, including, directly from you, from other users, from resellers and distributors, from our vendors, from our service providers, from third-party information providers, from our affiliates, and through the operation of the Website. We may also obtain Personal Data from publicly available sources such as open government databases or other data in the public domain.
If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
4. Usage of Personal Data
- The Personal Data we collect is used to operate our business and provide you with Services, as well as to improve our Services and personalize your experiences. We may use Personal Data for a variety of purposes (“Purposes”), including the following:
- To register you as a new user.
- To provide, maintain, and improve the Website and our Services, including to operate certain features and functionality of the Website.
- To understand user preferences to enhance users’ experience with Provider and its contractors and business partners.
- To research and analyze the effectiveness of the Website and the marketing, advertising, and sales efforts of Provider, its contractors and business partners.
- To process orders and payments made through the Website.
- To develop additional Services.
- To process job applications.
- To comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements).
- To manage our everyday business needs.
- To prosecute and/or defend a court, arbitration, or similar legal proceedings.
- To communicate directly with you by sending you newsletters, surveys, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications by clicking “Unsubscribe” at the bottom of the email or by contacting us using the details below.
- To communicate directly with you by phone to respond to customer service inquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support.
- To deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third-party sites, and to tailor ads based on your interests and browsing histories.
- To monitor and record your call, emails and text messages, social media messages and other communications in relation to your dealings with us.
- To comply with our contractual or legal obligations to share data with credit reference agencies, fraud prevention agencies and law enforcement agencies.
- To compile aggregated statistics about the operation and use of our Website and to better understand the preferences of Users.
- To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
- We may combine and enhance the Personal Data we collect about you with other information we receive from third parties.
- We may also use the Personal Data we collect about you through the Website to generate aggregated data that is anonymized so that it is no longer personally identifiable and may not later be used to identify you. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
- Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- The Personal Data that we have collected from you when setting up an account may be shared from time to time with credit reference and fraud prevention agencies who use it to prevent fraud and money laundering and to verify your identity. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide services to you or to allow you to access the Website. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing to you. Fraud prevention agencies can hold your information for different periods of time.
5. Sharing of Personal Data
We share your Personal Data with your consent or as necessary to complete any transaction or provide any Service you have requested or authorized. We also share Personal Data with third-party vendors, resellers and distributors, third-party service providers, affiliates, and business units, when required by law or to respond to legal process, to protect our customers, to maintain the security of our Services, to protect the rights or property of Dispoteca, or in connection with merger and acquisition discussions.
We may also share aggregated, anonymized data with third parties for other purposes. If we are required under applicable law to treat such information as Personal Data, then we will only disclose it as described above.
Without your consent, we will never sell, trade, or disclose your Personal Data to third parties that want to market products to you.
The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information. In addition, we restrict access to personal information to Provider employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Services. All Provider personnel who have access to this information are trained in the maintenance and security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us through use of the Services and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
7. International Data Transfers
8. Privacy Choices for EEA Residents
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Data information described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (such as to fulfill your purchase of a Service), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third-party), this interest will normally be to operate our platform and communicating with you as necessary to provide our Services to you, and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If we collect and use your Personal Data based upon your consent, the consequences of denying or withdrawing consent will be made known at the time your consent is provided.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.
Where required we have implemented the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our affiliates outside the EEA and United States, which require us to protect Personal Data they process from the EEA in accordance with European Union data protection law. Where required we have implemented similar appropriate safeguards with our third-party service providers and partners and can provide further details upon request.
If you are a resident of the European Union, all the Personal Data related to you and received and stored by Provider are erased after 5 years, save for any Personal Data in documents and files we must keep for a longer period under applicable law or that is needed to provide the Services.
If you are a resident of the European Union, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data by contacting us using the contact details provided below.
9. Privacy Choices for California Residents
10. Other Important Privacy Information
- If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided below.
- You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
- We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
- The Website is intended solely for use by individuals 18 years of age and older and thus is not directed to children under 18 years of age. Provider does not knowingly solicit or collect Personal Data from children under 18 years of age.
- Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your express consent.
- If you believe that your Personal Data has been processed or disclosed in violation of this Privacy Statement, Provider encourages you to raise any concerns using the contact information provided below. Provider will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data.
11. Questions and Contact Information