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Last Updated: October 6, 2023
Privacy Policy
Effective Date: October 6, 2023
Your Privacy Rights:
This Privacy Policy describes the types of information gathered by ProDeal360 Inc. (“ProDeal360”, “us” or “we”) in the process of providing this website (the “Site”), the application and software tools, and the associated services, data, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information.
By entering into this Agreement, you consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, available here https://prodeal360.com/terms_of_service, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.
This Privacy Policy is subject to the provisions of the European Union General Data Protection Regulation ("EU GDPR"), The United Kingdom General Data Protection Regulation (the “UK GDPR”, and together with the EU GDPR, the “GDPR”), the California Consumer Privacy Act of 2018, as amended, (“CCPA”), and other applicable privacy laws. ProDeal360 agrees that under the GDPR, it is a data “Controller” and you, if you are an individual and reside in the United Kingdom, the European Economic Area, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” Similarly, under the CCPA, we are a “Business”, and you, if you are an individual residing in California, are a “Consumer” with certain protected privacy rights concerning your “Personal Information”. We will take commercially reasonable steps to maintain compliance with GDPR and CCPA requirements. Your Personal Data and Personal Information may identify you as a person, and thus may be referred to as Personally Identifiable Information ("PII").
1. Who Collects Your Information On Our Service?
We do. Under the GDPR ProDeal360 is what is known as the “Controller”, and a “Business” for purposes of the CCPA, with respect to the PII that you provide to us. We collect information from you on the Service, and we are responsible for protection of your information.
2. What Information Does ProDeal360 Collect?
2.1. Requested Information. During onboarding as a user of the Service, we may request specific PII about you in order to add you as a user, add you to our email list, facilitate your payments for Service, or fulfill your requests for services or information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Service. We only collect basic Personal Data about you that does not include any special categories of personal data as defined in the GDPR. The types of PII that we collect and save include:
- Contact and account information, such as name, mailing address, email address, phone number, and username;
- Technical information, collected in our logs and via cookies. Such information may include standard web log entries that contain your device identifiers and information, operating system information, clickstream data, IP address, previous page URL, referring page URL and timestamps;
- Employment information, such as the name of your employer, work history and work information, and your employer’s business name, URL, location and type of industry; and
- Location-based information.
2.2. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider. Additionally, we may anonymize PII and include such anonymous information in sets or collections of aggregate information;
2.3. Financial Information. We do not collect financial information from you on the Service. However, we use third party service providers to process payments for the Service and they do collect financial information, such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service.
2.4. User Content. Aside from the PII that we collect from you for the creation and administration of your account (“Account Information”), you may also choose to upload or otherwise submit non-anonymous information and material to the Service that does not relate to the creation and/or administration of your account (“User Content”). User Content may consist of non-public content you process and share with others via the Service, such as documents, contracts and similar material stored, transmitted and collaborated on via the Service, as well as non-public communications between users of the Service in the course of negotiating and conducting transactions through the productivity tools of the Service. We do not require you to provide, upload, or otherwise submit User Content in order to use the Service, and such content shall only exist in the Service if, and to the extent that, you elect to upload or otherwise submit it to the Service. User Content shall only contain your PII to the extent that you, or another User authorized by you, include such PII in such User Content.
3. Why Is My Information Being Collected?
We need to collect your PII so that we can respond to your requests for information or to be added to our email lists, and to process your requests to access, and make payment for, the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.
We collect User Content for purposes of providing the Services.
4. How Do We Use the PII That We Collect?
4.1. We use the PII you provide for the purposes for which you have submitted it including:
- Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information;
- Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service;
- Subscribing to the Service. We may use your PII to add your subscriptions to our Service;
- Paying for the Service. Although it may appear that the Service collects financial information, your information is collected and processed through a third-party service provider. We do not process or store your financial information, including credit card or other payment method information;
- Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you;
- Sending Administrative Emails and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) process your transactions to purchase our Service; (c) provide you with information regarding the Service; (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (e) provide you with information on our other services and products, or promotions related to the Service or our other services and products.
4.2. We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services.
4.3. We may use your User Content to provide certain functionalities of the Service, as directed by you, including the collaboration and communication functionalities of the Service.
5. Do We Share Your Personal Information?
We will not share your PII except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law, including to meet national security or law enforcement requirements, or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out Services, internal operations, or business activities. We may also share aggregate information with others, including affiliated and non-affiliated organizations. Finally, we may transfer your PII to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.
We may provide your payment information to a third-party service provider for purposes of payment processing.
We may share your User Content with other Users with whom you are conducting business, collaborating, or communicating with respect to the particular User Content, or otherwise as directed by you, via the Service. For example, if you are conducting business with a counterparty through the Service and you grant that User access to a particular workflow, that counterparty will have access to the User Content in that workflow. We do not otherwise share User Content except in accordance with this policy. Additionally, User Content may be accessible to the administrative account with which your account is associated.
6. How Can You Access And Control Your Information?
After becoming a user of the Service, you may view, revise or edit certain PII associated with you by logging into the Service, or by sending an email to privacy@prodeal360.com.
For instructions on how you can further access your PII that we have collected, or how to correct errors in such information, please send an email to privacy@prodeal360.com. We will also promptly stop using your PII and remove it from our servers and database at any time upon your e-mail request, where required by law. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your PII.
6.1. After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.
6.2. If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be stored in our servers and internal systems located within the USA.
6.3. We store your PII until the earlier of (i) your PII is no longer necessary for the purposes for which it was being processed; (ii) we delete your PII in accordance with our data retention decisions as well as retention and other internal policies; (iii) you request us to remove it from our servers, except in cases where we have the legal authority to maintain that information and elect to retain such information. We store our logs and other technical records indefinitely.
7. How Do We Use Cookies And Other Network Technologies?
7.1. To enhance your online experience with us, our web pages may use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies.
7.2. Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info. For more information about Google’s use of data for marketing purposes, please see the summary page: https://www.google.com/policies/technologies/ads. Google’s privacy policy is available at https://www.google.com/policies/privacy. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.
7.3. ProDeal360 or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some ProDeal360 Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the ProDeal360 Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
7.4. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the ProDeal360 Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site.
7.4. Do Not Track. At present, the Site and Service do not specifically respond to browser do-not-track signals.
8. Collection of Information by Others
Our Terms of Service document identifies certain third party websites to which we may provide links, and that you may access through our Site. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.
9. Data Subject Rights
If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject, as defined in the GDPR. The GDPR requires that we, as a Controller, have a legal basis to process your PII.
- We process your PII under one or more of the following legal bases:
- Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- To perform the contract that we are about to enter with you (e.g. our Terms of Service);
- To comply with a legal obligation; and/or
- If we have your consent to do so.
- Under the GDPR, as a Data Subject you have certain rights. They are:
- . This is your right to be informed about what we are processing, why, and who else the data may be passed to.
- . This is your right to see what data about you is held by us.
- . This is the right to have your data corrected or amended if what is held is incorrect in some way.
- . This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
- . This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- . This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
- . This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
- . This is the right to not be subject to a decision based solely on automated processing. The service does not engage in automated decision making and profiling.
You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at privacy@prodeal360.com.
10. Children and Young People’s Information
We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR, the CCPA, USA Children’s Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at privacy@prodeal360.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided personal information to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at privacy@prodeal360.com.
11. California Privacy Rights
To the extent that the CCPA applies to our practices with respect to Personal Information and you are a Consumer (as such terms are defined in the CCPA), the CCPA provides you with certain rights.
11.1. Right to Access. California Consumers have the right to request that we disclose Personal Information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information. In the previous 12 months, we have collected the following categories of personal information about Consumers:
- Identifiers, such as your name, email, and similar information;
- Personal Information Under the California Customer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”), such as your name, email, and similar information;
- Internet/Network Activity, such as your browsing history, cookies, search history and your interaction with our Site;
- Geolocation Data, such as your GPS data;
- User Content, to the extent it contains Personal Information;
- Inferences drawn from any other category of personal information.
We collect the Personal Information from you/the consumer, third parties, and by automatic means. Such Personal Information is collected in order to provide the Service and as otherwise described in “How Do We Use the PII That We Collect” Section above.
11.2. Right to Access. As a California consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, or sold, in the previous 12 months. With respect to Personal Information being disclosed for a business purpose, the consumer shall receive the categories of information disclosed and the types of entities they have been disclosed to. This right may not be exercised more than twice in a 12-month period. For Personal Information being Sold and/or Shared (as those terms are defined in the CCPA), this includes the categories of information being sold and the categories of third parties to whom it is being sold.
In the past 12 months, we have disclosed Personal Information falling under the following categories of personal information: Identifiers; CCRLPI; Internet/Network Activity; Geolocation Data; and User Content. We disclose the Personal Information in the preceding categories to the consumers themselves, to other parties as the consumer may direct, our service providers, third parties, other users, government/law enforcement agencies, and/or successor(s) in interest. This information is disclosed to comply with your directions, for the provision of the Services, to comply with applicable law, and/or our legitimate business purposes. User Content may be disclosed to other users and third parties at your direction, administrative users associated with your account, and as necessary comply with applicable law, which may include government and law enforcement agencies.
IN THE PAST 12 MONTHS WE HAVE NOT SOLD (AS DEFINED IN THE CCPA) OR SHARED (AS DEFINED IN THE CCPA), AND DURING THE PERIOD OF TIME WHICH THIS PRIVACY POLICY IS POSTED WE SHALL NOT SELL, OR SHARE, THE PERSONAL INFORMATION OF ANY CONSUMER, INCLUDING MINORS UNDER THE AGE OF 16.
11.3. Right to rectification. This is the right to have your Personal Information corrected or amended if what is held is incorrect in some way.
11.4. Right to deletion. Subject to certain exceptions, and limitations, this is the right to have your Personal Information deleted.
11.5. Right to Limit the Use and Disclosure of Sensitive Personal Information. To the extent that we use or disclose Sensitive Personal Information (as defined in the CCPA), Consumers may, at any time, request that we cease using or disclosing any Sensitive Personal Information that we have collected about them to only such uses as permitted by the CCPA. We have not in the past twelve (12) months, and do not anticipate during the time this version of the Privacy Policy is posted, collected Sensitive Personal Information. For the avoidance of doubt, we do not collect Sensitive Personal Information at this time.
11.6. Right to Opt-Out of Selling and/or Sharing of Your Personal Information. Consumers have the right to opt-out of the Sale, or Sharing, of their Personal Information. Consumers also have the right to opt back into such practices at their discretion after opting out.
11.7. Right to Data Portability. This is the right to ask for your Personal Information to be provided to you in a structured, commonly used, and machine-readable format.
11.8. Right to Non-Discrimination. In the event that you exercise one of your rights described in this policy, you will not be discriminated by us in any way, including by the denial of goods or services, providing you a different level of goods or services, or charging you different prices or rates for the goods or services, unless the change in price is reasonably related to the value we receive from your Personal Information.
Exercising Your CCPA Rights
Because we offer the Services exclusively online, you may submit requests to exercise your rights under the CCPA by emailing us at privacy@prodeal360.com, please include “CCPA Rights Request” in the subject line. We will acknowledge receipt of your request within 10 days of receiving it, and will do our very best to respond within 45 days of receipt of your request, and in no event will our response come more than 90 days after your request. If we are unable to provide our response within the first 45-day window, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.
Before we respond to any CCPA based requests relating to your personal information, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent. We do this to this avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way. To do this, we will ask the Requestor to confirm at least two pieces of information that we have in our files. As the sensitivity of the information being requested goes up, we will ask the Requestor to confirm more pieces of information. If an agent is acting on behalf of the consumer, we will need to also verify the agent’s identity and their authority to act on the consumer’s behalf. For requests to delete information, after verification, we will confirm the consumer’s desire to delete one final time before actually deleting the information. If the identity of the Requestor cannot be reasonably verified, either as the consumer or their agent, then in order to protect that consumer, we shall not disclose the personal information requested.
12. Changes to this Policy
Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future our privacy practices change materially from those described in this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the ProDeal360 Service, or other means of legal acceptance, following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.
13. EU-U.S. Data Privacy Framework
ProDeal360 complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF (collectively, the “Framework”) as set forth by the U.S. Department of Commerce. ProDeal360 has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, please visit https://www.dataprivacyframework.gov/. To view our certification under the Data Privacy Framework, please visit https://www.dataprivacyframework.gov/s/participant-search.
In compliance with the Principles, ProDeal360 commits to resolve complaints about our collection or use of your personal information. EEA residents with inquiries or complaints regarding this Framework privacy policy should first contact ProDeal360 at:
ProDeal360 Inc.
1314 E Las Olas Blvd. Unit #1750.
Ft Lauderdale FL 33301
TEL: +1 917-647-0513
Email: privacy@prodeal360.com
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, ProDeal360 commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to the American Arbitration Association (“AAA”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of the AAA are provided at no cost to you.
The Federal Trade Commission has jurisdiction over ProDeal360’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S.
We store your Personal Information on cloud servers located in the United States. If a third party that provides Services on ProDeal360s’ behalf processes personal data from the European Union in a manner inconsistent with the Principles, ProDeal360 will be liable, unless we can prove that we are not responsible for the event giving rise to the damage.
14. Arbitration
If you are located in the EU or UK and have not been able to resolve your complaint by any other mechanism, you may, in certain circumstances, be able to seek resolution via binding arbitration. For additional information about the arbitration process, please visit the following website, https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
15. Our Contact Information
If you have any questions or concerns about this Privacy Policy you may email us at privacy@prodeal360.com.
Copyright © ProDeal360 Inc. All rights reserved. The Site and Service are the property of ProDeal360, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.