DOLEAD, INCORPORATED PRIVACY POLICY

Dolead, Incorporated, a Delaware corporation, its parent company and affiliates (“Dolead”, “we”, “us”, or “our”), are committed to keeping any and all personal information collected from individuals that visit our website, use our marketing service audit, use our lead generation software as a service, products, and other services (collectively, “Services”) confidential, secure and private.

This Charter details Dolead’s policy on the protection of personal data. It concerns all personal information collected during your visit to our website. This Charter supplements the website's General Terms and Conditions of Use

Dolead may amend this Charter at any time. These changes will take effect upon publication on the website. We hence invite you to consult this document frequently.

By accessing and using our website and the Services, you (“you” or “your”) acknowledge and agree that you accept the policies set forth in this Privacy Policy (the “Privacy Policy”) as a condition of your use of our Services. If your use of the Services is through or on behalf of an organization or corporate entity, you are agreeing to accept the policies set forth in this Privacy Policy on behalf of such organization or entity, and are representing to us that you are authorized to do so.

This Privacy Policy shall be equally applicable to those parties that contract with us to use our Services (“Business Partners”), as well as those parties that access and use our Services through participation in our online paid marketing campaigns (“End Users”). Where this Privacy Policy refers to “you” rather than to Business Partners or End Users, that provision shall be deemed to refer collectively to both Business Partners and End Users.

1. WHO WE ARE

Dolead is a digital marketing company connecting End Users inquiring about certain goods and services to appropriate Business Partners who may provide such goods or services. Services are paid for by the Business Partner and free to End Users. If a commercial transaction is subsequently concluded between the End User and the Business Partner, it stems solely from the interaction of these two parties.

2. The data collected

From the Business Partner:

We may collect certain information that Business Partners specifically and intentionally provide to us. For example, when a Business Partner retains our Services to conduct a campaign for lead generation or the initiation of third-party interest or enquiry into a product or service offered by the Business Partner, we may collect personal information about the Business Partner such as the name of the business entity, a contact email address phone number, and physical address. We may also collect financial information that the Business Partner chooses to share with us, such as credit or debit card numbers, billing address, and other billing information. Other unique information that we may collect includes product and service preferences and contact preferences. This includes information provided at the time of engaging our Service, content you provide to execute and track the engagements with prospective End Users, or requesting further Services. We may also ask you for information when you report a problem with our Services. To the extent that an individual, and not a business entity, is a Business Partner, we may collect all of the above information about the individual Business Partner, as well as the individual’s age, sex, educational and employment background. To the extent that the Business Partner is a business entity, the data above may be provided to Dolead by a designated entity within the Business Partner’s company (such as a member of your Purchasing/IT/Facility Management department). For the avoidance of doubt, all information collected from a Business Partner hereunder shall be known as “Business Partner Information.”

From the End User:

We may collect certain information that End Users specifically and intentionally provide to us. For example, an End User may provide us with their name, email address, phone number, age, sex, and physical address. We also collect certain information about End Users when such End Users access and engage with the Service or complete online forms in connection with the Service. For the avoidance of doubt, all information collected from End Users hereunder shall be known as “End User Information.”

Data category Data collected
Identifaction Data We can collect first and last name, birth date
Coordinate email address, adress
Connexion data IP address.
Privacy Privacy We may collect information about your lifestyle, your family situation, the existence of pets or your consumption habits, the occurrence or absence of a disaster, etc.
Professional life Professional life We can collect information about your duties, your job, your business address, your business phone number, your business email address, and so on.
Economic and financial data We can collect your income level by fork, an estimate of your wealth by fork, if you own or rent your home and so on.

Dolead may collect additional personal data, which will then be marked with an asterisk. This data is required to provide the service of connecting users with a business partner. All other data entered that is not marked with an asterisk are collected with your express consent.

3. PERSONAL INFORMATION OF CHILDREN

WE DO NOT AND WILL NOT KNOWINGLY ALLOW ANYONE UNDER 13 YEARS OF AGE TO PROVIDE US ANY PERSONAL IDENTIFYING INFORMATION. USERS OF THE SERVICES WILL BE DEEMED TO HAVE FULL CONTROL OVER THEIR PRODUCTS AND USER ACCOUNTS, AND MUST ENSURE THAT NO CHILDREN UNDER THE AGE OF 13 USE OUR SERVIUCES IN ANY MANNER WHICH WOULD PROVIDE US OR ANY THIRD PARTY WITH ANY PERSONAL INFORMATION OF A CHILD. IF WE LEARN THAT WE HAVE COLLECTED PERSONAL INFORMATION FROM A CHILD UNDER AGE 13, WE WILL DELETE THAT INFORMATION AS QUICKLY AS POSSIBLE. IF YOU BELIEVE THAT WE MIGHT HAVE ANY PERSONAL INFORMATION ABOUT A CHILD UNDER AGE 13, PLEASE CONTACT US USING THE CONTACT INFORMATION PROVIDED BELOW.

4. HOW WE COLLECT INFORMATION

We use various technologies to collect the information described above, and to provide, improve and protect our Services, which may include the use of cookies and device identifiers. Cookies are small data files stored on your computer or mobile device that enable our website to recognize your browser and capture and remember certain information. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent on a website. If we use cookies, we will do so in order to understand and save your preferences for future visits, compile aggregate data about website traffic and interaction so that we can offer a better user experience and tools in the future. You can set your browser to not accept cookies; however this may limit your experience with, and ability to use, the Services.

5. ACCESS TO AND CONTROL OF PERSONAL INFORMATION

Business Partners can access, review and/or update their user profile and settings by logging into the Services and visiting their account profile page accessible at https://app.dolead.com which will allow the Business Partners to modify, update, or restrict access to certain information.

Business Partners and End Users may also contact us using the contact information provided below to request access to, correct or delete any personal information that has been provided us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6. HOW WE USE YOUR INFORMATION

We may use your information to:

  • Present our Services and its contents to you, such as by tracking Business Partner service, contact, historical, and locational data.
  • Provide you with information, products or services that you request from us.
  • Enhance or improve our website or our Service.
  • Process transactions.
  • Send e-mails about our website or respond to inquiries.
  • Send e-mails, updates, newsletters, and other promotional information about Dolead.
  • Notify you about changes to our Services or any products or Services we offer or provide though it.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between the Business Partner and us, including for billing and collection.
  • Send third party offers.
  • Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our website or Service.
  • Fulfill any other purpose for which you provide it.
  • For any other purpose with your consent.

We may also use your information to contact you through email about our goods and services that may be of interest to you. If you do not want us to use your information this way, please click the opt-out link.

7. THIRD PARTY ACCESS TO YOUR INFORMATION

Throughout the course of our provision of our Service to you, we may delegate our authority to collect, access, use, and disseminate your information. For example, our web host stores the information that you provide us, and we may hire outside contractors to perform maintenance or assist us in securing our website. ​ It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our website or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.

8. LINK TO THIRD PARTY WEBSITES

Dolead is not responsible for the practices employed by third party websites linked to or provided through the Services, the content, or for any information contained therein. Please note that once you leave our website our Privacy Policy is no longer in effect. End User browsing and interaction with any third party or Business Partners website, product, or service, is subject to that third party’s own rules and policies. Please be sure to read over those rules and policies before proceeding. End Users shall be responsible for anything published or shared through such third party websites, and Dolead is not responsible for anything contained therein.

We expect our Business Partners to use our Services responsibly and deliver appropriate content. Accordingly, content posted by Business Partners is subject to the restrictions included in the Terms of Service. If you are an End User and you see any Business Partner content which you believe violates this Privacy Policy or Terms of Service, please contact us immediately. Notwithstanding the foregoing, Dolead disclaims any responsibility to End Users for Business Partner content posted, transmitted, or otherwise disseminated by Business Partners via the Services.

8. ANALYTICS

We may implement analytics programs to track End User engagement with the Services which may collect certain information about End Users. We will use such information in accordance with this Privacy Policy, but make no representations or warranties as to the use of this information by our analytics services providers.

We use a tool called “Google Analytics” to collect information about use of our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we receive from Google Analytics only to improve our website. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service - https://www.google.com/analytics/terms/us.html and the Google Privacy Policy https://policies.google.com/privacy - . You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

9. SECURITY

Dolead uses reasonable security controls to protect your data and information from loss, misuse, unauthorized access, disclosure, alteration and destruction. The personal information you provide us is stored on computer systems located in controlled facilities which have limited access, and only carefully selected, authorized personnel have access to unencrypted user information. When collecting or transferring sensitive information such as credit card information, we use a variety of additional security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. When we transmit sensitive information over the internet, we protect it through the use of advanced encryption techniques, such as the Secure Socket Layer protocol, and firewall. Additionally, as part of real-time payment processing, Dolead may subscribe to fraud management services. These services provide Dolead with an extra level of security to guard against credit card fraud and to protect your financial data. Despite these precautions, no security safeguards guarantee 100% security all of the time, and no guarantees are made with respect to the same.

10. HOW LONG WE KEEP YOUR INFORMATION

We retain your personal information in accordance with our data retention policies and practices. The length of time we keep your information depends upon a number of factors, including the type of information. In general, we retain personal information for as long as we have an ongoing business need to retain it. Following that period, we will delete it.

11. USERS FROM THE EUROPEAN ECONOMIC AREA

Legal Basis for Processing: If you are an individual in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable European Union laws. The legal bases depend on how you use the website or the Services: We need to collect and use the information for you to use the website;

Our collection satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; You give us informed consent to do so for a specific purpose; or We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the website.

How To Access Or Control Your Information:

General Data Protection Directive (“GDPR”) provides individuals in the EEA certain rights with respect to their information. These include the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You can exercise these rights by contacting us using the contact information provided below.

The GDPR provides that we may limit or deny your requests in certain cases. For example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we have compelling legitimate interests to keep, including as required by law. You may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed if you have concerns about your rights.

12. YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY)

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of Business Partners' personal information with third parties. These businesses are required to accept requests for disclosures of these policies from Business Partners but are only required to honor one request per calendar year. Businesses have thirty (30) days to respond to each inquiry to the designated address. Each inquiring Business Partner will receive an explanation of the categories of Business Partner information shared and the names and addresses of any third-party businesses. In limited circumstances, Business Partners' failure to submit requests in the manner specified will not require a response from the business.

If you are a California resident, you may request such information from us by sending a letter to the address listed below. In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that Dolead provide its third-party information sharing disclosures required by section 1798.83 of the California Civil Code.”

Dolead, Incorporated 50 Milk Street, 16th floor Boston, Massachusetts 02109 United States

13. ENFORCEMENT AND DISPUTE RESOLUTION

If you have any questions, complaints or disputes regarding the manner in which we use or protect your information, please contact us using the contact information provided below. We will investigate and attempt to resolve any complaints and disputes in a reasonable time and in a manner that complies with the principles described in this Privacy Policy.

You agree to try to resolve the dispute informally first by contacting us in accordance with this Privacy Policy. We’ll try to resolve the dispute informally by contacting you via email. If a dispute is not resolved within ninety (90) days of submission, either you or Dolead may begin formal legal action, subject to the terms of this Privacy Policy. The validity, performance, construction, regulation and interpretation of this Privacy Policy shall be governed under the laws of Delaware using English language. Any dispute, controversy or claim arising out of or in connection with this Privacy Policy, or regarding any legal relations arising out of or in connection therewith, and/or the breach, termination or invalidity thereof, shall be finally settled by arbitration in accordance with the arbitration rules and procedures of Judicial Arbitration and Mediate Services. Inc. (“JAMS”) then in effect. The place of arbitration shall be Santa Clara County, California where the award shall be rendered. The arbitration proceedings shall be conducted in the English language.

Notwithstanding the foregoing, both you and the Company shall have the right to institute an action in a court of competent jurisdiction for injunction or other equitable relief. Except for the fees of the legal advisors, which shall be borne by each respective party, all other expenses and costs of arbitration shall be borne by either or both parties as the arbitration tribunal may award.

14. HOW WE AMEND THIS PRIVACY POLICY AND NOTIFY YOU OF THE CHANGES

This Privacy Policy was last updated as of the date indicated above. We reserve the right to amend and revise our Privacy Policy at any time, with or without notice. For example, we may amend or revise our Privacy Policy to comply with local, state, or federal laws or to accommodate changes in technology or the needs of our users. This Privacy Policy may therefore be amended from time to time, consistent with applicable data protection and privacy laws and principles. If we make any material changes to this Privacy Policy, we will post an updated policy here.

15. Contacting Us

If you have any questions or complaints about these Terms of Use or of our Website, please email us at sales.nam@dolead.com or write to us at Dolead Incorporated, 50 Milk Street, 16th floor, Boston, Massachusetts 02109, United States.


Last updated: 24 May 2018