This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make an application for funding from Double Down (the “Site”).

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make an application for funding we will gather information directly from you on you, your business and other individuals connected to your business. This includes, but is not necessarily limited to, name, home address, date of birth, email, phone number and geographical location. Details about your business include industry, business size and financial information to determine eligibility for funding.

Should we proceed further with an assessment of eligibility for funding we’ll need to verify your identity and search your record with fraud prevention agencies, Anti Money Laundering (AML), and Know Your Customer (KYC) service providers. We may also request access to the platforms you use to run your business (such as banking, sales, advertising, and accounting) and use the data shared to determine eligibility and monitor performance.

When you use our services, we gather details on payments to and from your Double Down account and details about how you use our website.

HOW WE USE YOUR PERSONAL INFORMATION

We use your data for a contract we have with you, or to enter into a contract with you. We use details about you to consider your application, to provide services in line with our terms and conditions, inform you of changes to your account, to resolve any complaints and to exercise our rights under contracts we have entered into with you, such as managing, collecting and recovering money you owe us.

Further, we need to use your data to comply with the law. This includes confirming your identity when you get in touch, checking your record with fraud prevention agencies, preventing illegal activities like tax evasion or fraud, adhering to banking laws and regulations, and keeping records in line with legal requirements.

We need to use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which doesn’t involve overriding your privacy rights. These include tracking, analysing and improving the services we give you and other customers, carrying out security and maintenance checks to ensure our services run smoothly for you, and sharing information with credit agencies so we can benefit from up to date information when making lending decisions.

SHARING YOUR PERSONAL INFORMATION

We share your personal information with third parties to help us use your personal information, as described above. We share as little information as possible and where feasible will also anonymise your personal data. The third parties we use include: companies that issue our virtual credit cards, credit card processors (e.g. Visa), KYC and AML providers, cloud computing providers (e.g. Google Cloud), our business intelligence and analytics provider, software companies that we use for mailing you, companies that help us with customer support, companies that help us with marketing, and companies that print written statements and notices.

We may also share your information with entities that you give us permission to share it with. These include tools to transmit information relating to payment accounts, your own banking, sales, advertising, accounting or other business platforms to determine eligibility and monitor performance, and people you’ve asked to represent you (e.g. accountants).

Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIOURAL ADVERTISING

As described above, we use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:
Facebook – https://www.facebook.com/settings/?tab=ads
Google – https://www.google.com/settings/ads/anonymous
Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted, and withdraw any consents you may have given us. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an application through the Site), or otherwise to pursue our legitimate business interests listed above. Should we transfer your information outside the European Economic Area we make sure your data is protected and the European Commission says the country or organisation has adequate data protection, or we’ve agreed to standard data protection clauses approved by the European Commission with the organisation.

DATA RETENTION

We keep your information as long as you are a client of Double Down and for five years thereafter to comply with the law and should we face legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that’s in our legitimate interest) and/or the law says we have to.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@d2.fund.

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