PRIVACY POLICY

Introduction

Propelr Limited (“us”, “we”, or “our”) operates the Safelink Data Rooms website (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use the Service.
We will not use or share your information with anyone except as described in this Privacy Policy.

Changes to this Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Information that you provide or that we collect

Account and Profile Information:

We collect information about you and your company as you register for an trial or live account, or modify your profile within the Service.

Information we collect includes:

  • Contact information such as your name, email address, mailing address, and phone number.
  • Billing information such as your billing address.
  • Profile information such as a username, profile photo, and job title.
  • Preferences information such as notification and marketing preferences.

You may provide this information directly when you enter it with the Service.

In some cases another user (such as a Room Manager) may create an account on your behalf and may provide your information, including Personal Information (most commonly when you are invited in by a manager of a Room for the purpose of accessing documents and other information within the Service).

We collect Information under the direction of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.

Content:

We collect and store Content that you enter or upload in the process of using the Website or Services. Such Content includes any Personal Information or other sensitive information that you choose to include. Most types of Content are stored in an encrpyted form, using keys that to which we have no special right of access. If we are not invited into the room in which the Content is stored, we cannot decrypt the Content.

Audit and Activity Logs:

We collect information about your activity within the Service, including a record of which information, pages or content you enter, upload, display, print, or download.

Information from your Browser:

When you access the Website or the Service, we record your IP address, the access time, and information about your operating system, browser type and version, browser capabilities, language, and the URL of the web page you visited before navigating to the Website or Service. These details are provided by your browser automatically.

Cookies:

We use various technologies to collect information, including the use of browser cookies, to deliver the Website and the Service. Cookies are small data files stored on your hard drive or in device memory. Cookies enable the Service to establish a "session" when you sign in, allowing the Service to identify who you are signed in as when you move through its pages. Cookies also allow you to access and use the Service without re-entering your User ID and/or password, and help us to understand usage patterns and which areas and features of the Website and Service are most popular.

A limited number of pages on our Website contain references to third party services, including Google AdSense, to manage our advertising on other websites. These third parties may use tracking technologies such as cookies to gather information about your activities on this Website and other websites you visit in order to provide you advertising based upon your browsing activities and interests. You can choose to block cookies from these websites using your browser settings or specialised plugins.

Accessing and Updating your Information

You may often correct, update, amend, or remove your Personal Information in your account settings or by directing your query to your account administrator. You may also contact the Safelink Helpdesk, or contact us by postal mail using the address listed below. We will respond to your request for access within 30 days.

You can often remove Content using editing tools associated with that Content. In some cases, you may need to contact your administrator to request they remove the Content. You can contact us to request removal of Personal Information that is within our control from the Service.

How we use your information

General Uses:

We use the Information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:

  • Provide, operate, maintain, improve, and promote the Service;
  • Enable you to access and use Service, including uploading, downloading, collaborating on and sharing Content; Calculate usage and billing information and send invoices;
  • Send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
  • Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and sending updates about the Rooms to which you have access. You have the ability to opt out of receiving any of these communications as described below under "Your Choices";
  • Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  • Personalize the Service, including by providing content, features or suggestions that match your interests and preferences;
  • Enable you to communicate, collaborate, and share Content with users you designate; and
  • For other purposes about which we obtain your consent.

Notwithstanding the foregoing, we will not use Personal Information appearing in our Analytics Logs or Web Logs for any purpose. The use of Information collected through our Services shall be limited to the purposes disclosed in this policy.

Web Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and with the Service. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, and system configuration information. In the case of the Service, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content (such as room names) as necessary for the Service to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve the Services for individual customers. In such a case, we would treat the combined Information in accordance with this privacy policy.

Audit Logs:

The information we collect about your activity within the Service may be included within reports that are available to Room Managers or other authorised users within a Room. This is a standard feature of data room technology. The information is available in both a detailed and summarised form. The log information used for these reports, and by extension, the reports themselves, are stored in encrypted form and not available to us unless we are invited to the relevant Room. As these reports will allow other users to see detailed information about your actions within the Service, you should consider what information your actions may reveal or imply and adjust your actions accordingly.

Analytics Information from Website and the Service:

We collect analytics information when you use our Websites and the Service to help us improve the Service. This analytics information consists of the name of the feature or function being used, the username and IP address of the individual who is using the feature or function (which will include Personal Information if the Personal Information was incorporated into the username), and additional information required to detail the operation of the function.

Information we Share

We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.

Your Use:

When you use Service, Content you provide will be displayed back to you. You, or another user who has access to the Room you are using may make your identity or some of the Content you have added available to other users. We urge you to consider the sensitivity of any data you input into the Service.

Collaboration:

As a natural result of using the Service, you may create Content and grant permission to other users to view, access, download or collaborate around the Content. Some of the collaboration features of the Service display your profile information, including Personal Information included in your profile, to users with whom the Content has been shared. Where this information is sensitive, we urge you to use the various security and privacy features of the Service to limit those who can access such information, and to consider whether any current or future Room Managers or administrators of the Room might share your information.

Access by your system administrator:

You should be aware that the administrator of Rooms and parts of the Service to which you have access may be able to:

  • access information in and about your account;
  • access communications history, including your Content;
  • disclose, restrict, or access information that you have provided or that is made available to you when using the Service, including your Content; and
  • control how your account may be accessed or deleted.

Business Transfers:

We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Aggregated or Anonymized Data:

We may also share aggregated or anonymized information that does not directly identify you with the third parties described above.

With Your Consent:

We will share your Personal Information with third parties when we have your consent to do so.

Compliance with the Law

We will disclose your Personal Information where required to do so by law or in accordance with an order of a court of competent jurisdiction, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

Information we don’t share

We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.

Information Security

The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

International Users

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We transfer the information, including Personal Information, to both Jersey and Guernsey and process it in one or both jurisdictions. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.

Policy Scope

This Privacy Policy applies to the information that we obtain through your use of the Website or the Services via a "Device" or when you otherwise interact with us.

A "Device" is any computer used to access the Website or the Service, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

By registering for or using the Service you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Jurisdiction

This Privacy Policy shall be governed and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

Definitions

Content: any information or data that you upload, submit, post, create, transmit, store or display in the Service.

Information: all of the different forms of data, content, and information collected by us as described in this Privacy Policy.

Personal Information: information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymised such that it does not allow for the ready identification of specific individuals.

Room: An area within the Service into which Content or Information may be added.

Room Manager: A user who has been authorised to administer the users, access rights and Content within the room.

Service: The‘Software as a Service’ facility known as ‘Safelink’, available at the Website.

Website: The website at www.safelinkdatarooms.com, plus and other web site addresses agreed in writing with our clients.

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