Privacy Policy

We – meaning DealRoom, Inc., doing business as FirmRoom (also "FirmRoom," "our" or "us") – prepared this Privacy Policy to help you understand our practices with respect to the collection, use, and disclosure of information we collect from you through FirmRoom’s web or mobile applications (the "FirmRoom Products"), our websites that link to this Privacy Policy, and any other services we provide to our customers or end users (collectively with the FirmRoom Products, the "Services").
By accessing or using the Services, you agree to this Privacy Policy and our Terms of Service.
Effective date: May 25, 2018. Last Updated: Dec 16, 2021
Thanks for using FirmRoom. Our goal is to empower individuals and organizations to structure and organize data. As such, we take very seriously the respect and protection of your privacy and security. We are committed to following and continuously evolving best practices to support this principle.

What Information We Collect

What types of information we collect from you depends on how you use the Services, what Services you use, and what information you choose to provide or make available to us. We collect information from you when you:

• Create or register an account, and when you administer your account
  
• Input information or data into any of our Services, or post or upload Content to our Services
• Submit questions, requests, other communications to us via forms, email, or other communication media
• Contact us for customer support or technical support
• Visit any of our websites or download any of our apps
• Participate in any promotions, demonstrations, contests, surveys, or other marketing events
• Interact with other FirmRoom users and guests on our community forums
• Integrate third-party products and services with your FirmRoom account

Customer Information

Information related to the creation of accounts or that otherwise identifies you as a customer or end user of FirmRoom is what we call "Customer Information." Customer Information may include certain "personally identifiable information" or "PII", such as your name, email address, gender, postal address and phone number. It also may include payment information, such as payment method, credit card information, and any contact information (such as name and postal address) associated with payment billing information. If you are an end user using the Services through an account created on your behalf by an FirmRoom customer (such as an employer, organization of which you are a member, or another individual), we may collect and process Customer Information about you on behalf of the FirmRoom customer with whom your use of the Services is associated.
When you create an account with FirmRoom, we may collect certain Customer Information directly from you or, if you create your account using a third-party service (such as Google or a single sign-on service such as Okta), we may collect Customer Information about you from the third-party service (such as your username or user ID associated with that third-party service). By choosing to create an account using a third-party service, you authorize us to collect Customer Information necessary to authenticate your account with the third-party service provider.
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Certain aspects of the Services allow you to link or integrate third-party products and services to enable certain features and functionalities with the Services. For example, you can connect your Google Drive account so as to generate Content in FirmRoom from information and data contained in your Google Drive or integrate with third-party services using Blocks. If you choose to use these features or functionalities, you may be asked to create an account with a third-party service provider or link your existing account with that service provider (and, by doing so, agree to the privacy policy and/or terms and conditions of that third-party). You may also be asked to authorize FirmRoom to collect information from the third-party service provider on your behalf. We will then collect information (such as your username or user ID associated with that third-party service) from you and/or that third-party service provider as necessary to enable the Services to access your data and content stored with that third-party service provider. Once the authentication is complete, we have the ability to access information you provided to us or was otherwise collected by the third-party service in accordance with the privacy practices of that third-party service. We will store the information and data we collect and associate it with your FirmRoom account, and we will only use that information and data to enable the integration of the Services with the third-party service provider and to perform actions requested or initiated by you, or that are reasonably necessary to carry out instructions provided by you.

Content

One of the core aspects of the FirmRoom Products (and our related Services) is that you can upload any information, data, content, material – anything. We call anything you upload through the FirmRoom Products "Content." You (and anyone who can interact with your use of the FirmRoom Products) ultimately controls the nature of the Content, and our collection, use, and disclosure practices with respect to Content are separate from those with respect to other sorts of information we collect, including Customer Information. As explained in detail above, we may also upload Content automatically with your authorization from third-party service providers (such as from your Google Drive).

Information collected automatically through your use of the Services

We collect information about how you use the Services and your actions on the Services, including IP addresses, what software and hardware you use (such as browser types, operating systems, ISPs, platform type, device type, mobile device identifiers such as make and model, mobile carrier), pages or features of FirmRoom used and associated dates and time stamps, search terms, links you click, whether you open messages sent to your account, and other statistics related to your usage of the Services. We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of "cookies" and other tracking technologies, such as web beacons, session replay scripts, and similar technologies ("tracking technologies"). We may also work with third party partners to employ tracking technologies.
If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, please see "Managing Your Information," below. Please note that doing so may negatively impact your experience using the Services, as some features may not work properly.

Location information

In some cases, we may collect limited location information. For example, we may use Google Analytics convert your IP address into a rough geolocation to understand in what areas our users are located and to improve and personalize FirmRoom (for example, to display time data in the correct local time).

Aggregated and anonymized information

We may collect information by aggregating and anonymizing other information. The aggregation and anonymization process prevents the information from being reassociated or identified with any one customer account, user, or individual. We may use aggregated and anonymized information for a wide variety of statistical and analytical purposes.

How we use the information we collect

We use the information we collect for a variety of purposes, and how we use it depends on what we collect and what Services you use (or features of the Services). These purposes may include:

• Providing the Services to you
  
• Responding to requests or inquiries from you
• Providing customer support or technical assistance

• Contacting you to provide product updates, information about products you have requested or purchased
• Marketing FirmRoom products, services and features that you may be interested in, and monitoring the performance of our advertisements and marketing efforts
• Creating or administering your account, including identifying you with your account or the account of an FirmRoom customer
• Billing you
• Deriving market insights, ways to improve the Services, and other business analysis or research purposes
• Customizing existing and future product offerings and other aspects of the Services to you and other users
• Securing the Services and our systems, and protecting your information and data
• Sharing with third parties for the purposes discussed in "How we share information", below
• Any legitimate business purpose, provided that the information is aggregated and anonymized

Personally Identifiable Information

Specifically, we may use personally identifiable information (including those contained within the Customer Information or otherwise collected by us) for the above purposes, but only as to the extent necessary for the purposes for which you have provided us with the information, to respond to inquiries or requests (including requests for customer support or technical assistance), to otherwise perform our obligations or act consistently with our Terms of Service, to respond to law enforcement or other governmental or legal authorities, and to otherwise use the information consistent with your instructions to us (both explicit, such as when you contact us directly with a request, and implied, such as when you engage us to provide you with the Services). If you wish to change these instructions, either by request, by correcting, amending, or deleting information we may have collected about you, or by opting out of certain data collection practices, please see "Managing Your Information", below.

Use of Content

Notwithstanding anything else in this Privacy Policy to the contrary, we will not use or access your Content except in the following cases: for providing the Services to you; where you (or, if you are an end user, the FirmRoom customer through which you have an account) explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the Services and our systems (e.g., where we have reason to believe specific Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also analyze metadata related to Content (such as total number of records, file size, API volume, access logs, etc.).

How we share information

We disclose information we collect in the following cases:

• You asked us to, or otherwise gave your specific consent (for example, by posting Content using the Universe feature, you consent to our sharing that Content with other FirmRoom users).
  
• With vendors we engage to provide you with aspects of the Services, such as data storage, hosting, and payment processing.

• With third-party service providers who enable certain features or functionalities of the Services that you’ve requested (for example, by installing applications in FirmRoom).
• With vendors we engage to help us gain insights and analytics into how the Services are used and how they might be improved (for example, we may use third-party data enrichment services to match Customer Information or other personally identifiable information we collect with publicly available database information in order to communicate more effectively with you).
• As necessary to comply with applicable law, including governmental requests, law enforcement requests, and otherwise to protect the rights, privacy, safety, or property of you, us, or others.
• As necessary in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, financing, or other disposition of all or any portion of FirmRoom business, assets, or stock.
• With others for any legitimate business purpose, provided the information is aggregated and anonymized.

How we secure your information

We implement appropriate technical and organizational measures to protect the information we collect and store. Unfortunately, no security measures are 100% foolproof, and as such no network or system (including ours) can be guaranteed to be 100% secure against destruction, loss, alteration, unauthorized disclosure of, or access to information we collect and store. If you believe your information may not be secure for any reason, please contact us immediately at privacy@FirmRoom.com.

Managing Your Information

You have many choices to access information we collect about you and about how we use or disclose that information. This section details many of those choices, including how you can exercise rights you may with respect to your information (including personally identifiable information), how you can opt out of collection and use of certain types of information for certain purposes (such as marketing), and how you can use your browser or third-party tools to disable certain collection methods (such as cookies or tracking technologies).
You may access, correct, amend, or delete Content by accessing it within FirmRoom. You control all Content you upload. Content you delete (including Content containing personal information) may be retained in archived or backup copies in order to enable you to use certain features like revision history and archive storage. For instructions on how to permanently delete Content from your FirmRoom account, please contact us at privacy@FirmRoom.com. Please note that permanent deletion of Content through this process will impair or disable those features with respect to that Content.
You may access, correct, amend, or delete Customer Information we have about you by logging into your account and navigating to your Account page. If you wish to cancel your account, you may do so through your Account page. If you do, personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.
We may use some of the information we collect for marketing purposes, including to send you promotional communications about new FirmRoom features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at privacy@FirmRoom.com to opt out.

Cookies and Tracking Technologies – How to Opt Out

If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. Disabling cookies may limit your ability to use the Services.
Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. No personally identifiable information is shared with these advertising networks, but please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. To learn more about advertising networks and how to opt out of sharing information with them, please click here and here. If you’re in the EU, you can find additional information about your choices with respect to advertising networks and online behavioral advertising by clicking here.
Certain tracking technologies we use involve the use of session replay scripts or other scripts that run directly from your browser. If you wish to disable these tracking technologies, you can install a third-party browser analytics blocker plug-in such as Ghostery.
If you have any questions about how we or our third-party service providers use cookies or other tracking technologies that aren’t answered in this Privacy Policy, please contact us at privacy@FirmRoom.com.

International Transfers (including Transfers Outside of the European Union)

We process and store information on servers located in the United States, and we may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By using the Services, you consent to the transfer of information (including Customer Information, Content, and personally identifiable information) to locations that may be outside of your country of residence, including the United States. You acknowledge and agree that, as a condition of providing any Content, you can legally transfer it to the United States or another country.
With respect to transfers of information out of the European Union (EU), we may process some personally identifiable information pursuant to data processing agreements that include the EU Standard Contractual Clauses. To learn more about our data processing agreements, please contact us at privacy@FirmRoom.com.

European Territory Visitors

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR), FirmRoom provides specific additional rights for individuals from European Territories who interact with FirmRoom such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

·     the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.

·     the right to request that personal data should be deleted.

·     the right to demand that the processing of personal data should be restricted.

·     withdraw your consent to the processing and use of your data completely or partially at any time with future application.

·     have the right to obtain your personal data in a common, structured and mechanically readable format.

·     contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.

·     the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

In addition to the above, we reference certain rights for European Territory citizens throughout this Privacy Policy.Pursuant to the GDPR, citizens from "European Territories" mean theEuropean Economic Area (EEA), the European Free Trade Area (EFTA) andSwitzerland. For the purpose of this Privacy Policy, the term "EuropeanTerritories" shall continue to include the United Kingdom, even after theUnited Kingdom leaves the European Economic Area following Brexit. If you are in the UK, or the European Economic Areas, the controller of your data is FirmRoomUK Limited. Please email privacy@firmroom.com with any questions about exercising any of the above rights.

Information from Children

FirmRoom is not directed to children under the age of 13 and we do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have collected personally identifiable information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable. Please contact us at privacy@FirmRoom.com if you believe we have any information from or about a child under the age of 13.

Changes to Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.
If you have any questions about this Privacy Policy, please contact us at privacy@firmroom.com.