Decile Group Inc.
Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Information You Provide to Us. We may collect Personal Data from you. If you provide us feedback, post an event or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the form, in order to send you a reply. We may also collect Personal Data at other points in the Sites that state that Personal Data is being collected.
Information Collected via Technology. To make our Sites more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP“) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Cookies necessary for essential purposes: These cookies are essential to provide you with services and features available through our Sites.
- Analytics Cookies: These cookies are used to collect information about how visitors use our Sites. The information gathered does not identify any individual visitor and is aggregated. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
- Performance Cookies These cookies collect information about how visitors use the Sites, so that we can analyze traffic and understand how our Site is performing.
- Functionality Cookies: These cookies allow our site to remember choices you make and provide enhanced, more personal features.
- Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social networking site. This information may be linked to targeting/ advertising activities.
Do Not Track Browser Setting. We do not currently respond to “do not track” signals from web browsers.
Pixel Tags. We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
Collection of Data by Advertisers. We do not use third parties to serve ads on the Site or collect personally identifiable information about your online activities over time and across different websites.
General Use of Your Personal Data. In general, we use your Personal Data in the following ways:
- provide improved administration of the Sites;
- improve the quality of experience when you interact with the Sites;
- send you follow-up communications when you contact us via e-mail, submit feedback, or post an event;
- send you administrative e-mail notifications, such as updates regarding the Sites, security, or support and maintenance advisories; and
- to determine which of our services and products could be useful to you and to send you information on such services and products.
Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of, and improve navigation on, the Sites. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
Uploaded Documents. Documents that are uploaded to the Sites for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with Personal Data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that users keep back-up copies of their documents.
Third Party Service Providers. We may share your Personal Data with third party service providers for the following purposes:
- provide you with Materials;
- conduct quality assurance testing;
- provide technical support; and
- provide other services to us.
These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
Corporate Restructuring. We may share some or all of your Personal Data with entities within our group of companies. We may also share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
Data Protection. We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Sites. However, no security system is impenetrable and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
Members of Decile Hub
If you become a registered member of Decile Hub (“Decile Hub”), we may collect additional Personal Data from you that may include the types of information listed below.
|First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, picture, signature, social security number and/or tax identification number, password, copies of ID cards or other forms of identification.
|Your home address, work address, billing address, email address and telephone numbers.
|Professional Background Data
|Educational and professional history, interests and accomplishments, job and salary preferences, third party recommendations, projects completed.
|Online Presence Data
|Links to your public account pages at social media websites, links to personal websites, and other online materials related to you.
|Your bank account and payment card details, statements about your wealth and financial situation.
|Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history).
|Information about your investment objectives, investment experience, prior investments, and information provided by completing documents.
|Any content you post to Decile Hub not already included in another category, including without limitation, your profiles, questions, preference settings, answers, messages, comments, and other contributions, and metadata about them (such as when you posted them) ("Content").
|Marketing and Communications Data
|Your preferences in receiving marketing from us and our third parties and your communication preferences.
|Inferred or assumed information relating to your behavior and interests, based on your online activity.
Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available. Examples of these sources are broken down in the table below.
|Third party data source
|Credit Reporting Agencies
|Social Media Sites
|Our Fund Administration Partners
|Identity Verification and Compliance Service Providers
Google Gmail. If you sign up for Decile Hub with a Gmail address and upon your authorization, Decile Hub will automatically sync with your Gmail account. This means that Decile Hub will access your Gmail contacts, emails, calendar, distribution lists, subject lines and URLs of tracked links from your email, if you use the email tracking functionality. In addition, you can use Decile Hub to read, modify, create, and send emails from your Gmail account. Decile Hub will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and email bodies. By default, synced emails are visible to account owners and admins, and you may make them visible to other members of your team.
Google Calendar. Upon your authorization, Decile Hub also automatically syncs with the Google Calendar application, accessing your calendar events and tasks in your Google Calendar. It also allows you to create and edit events and tasks and send invitations from your Google Calendar account.
Google Drive. You have the option to connect your Google Drive account to Decile Hub. If you choose to do so, you will be able to see your files, upload and download your files, and store file contents and titles on Decile Hub. Decile Hub uses these permissions to associate files with records stored on our platform and allow users to share them with clients and other users.
Your Choices Regarding Information. You have several choices regarding the use of information on the Sites:
- Cookies. If you decide at any time that you no longer wish to accept Cookies from the Sites for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions, or all functionality, of the Sites. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
If you reside in Singapore, you may request to access and/or correct your Personal Data currently in our possession by writing to us. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data.
If you reside in the UK or any country within the European Economic Area (“EEA“): Decile Group Inc. is the Controller (for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and any implementing legislation or legislation having equivalent effect in the UK (together, “EU Data Protection Legislation”)) of your Personal Data.
- We ask that you not provide us with any Special Category Personal Data (as defined in the GDPR), e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership, or any criminal background information. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through any of the Sites.
- We may transfer your Personal Data to a country outside the UK or EEA in accordance with requirements prescribed under EU Data Protection Legislation. When we transfer your Personal Data outside the UK or EEA, we hold it subject to appropriate safeguards and controls and ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards: We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
- Your Rights Regarding Your Personal Data: you have certain, you have certain rights regarding your Personal Data and may, in certain circumstances, ask us to take the following actions in relation to such data: (a) provide you with information about our processing of your Personal Data and give you access to such data; (b) update or correct inaccuracies in your Personal Data; (c)delete your Personal Data; (d) transfer a machine-readable copy of your Personal Data to you or a third party of your choice; (e) restrict the processing of your Personal Data; and (f) object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
Children under 16. The Sites and the services available on the Sites are not intended for children below 16 and we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under the age of 16, please do not submit any personal information through the Sites. We encourage parents and legal guardians to monitor their children's Internet usage to instruct their children never to provide personal information on our Sites. If we become aware that we have collected personal information from a child under age 16, we will take steps to remove that information.