Privacy Policy

Collection of Personal Data

• Online Activity. Depending on the Service used and how our Business Services are implemented by the Business Users, we may collect information related to:

  • The devices and browsers you use across our Sites and third party websites, apps, and other online services (“Third Party Sites”).
  • Usage data associated with those devices and browsers and your engagement with our Services, including data elements like IP address, plug-ins, language preference, time spent on Sites and Third Party Sites, pages visited, links clicked, payment methods used, and the pages that led you to our Sites and Third Party Sites. We also collect activity indicators, such as mouse activity indicators, to help us detect fraud.

• Communication and Engagement Information. We also collect information you choose to share with us through various channels, such as support tickets, emails, or social media. If you respond to emails or surveys from EoD, we collect your email address, name, and any other data you opt to include in your email or responses. If you engage with us over the phone, we collect your phone number and any other information you might provide during the call. Additionally, we collect your engagement data, like your registration for, attendance at, or viewing of EoD events and any other interactions with EoD personnel.

• Forums and Discussion Groups. If our Sites allow posting of content, we collect Personal Data that you provide in connection with the post.

Use of Personal Data.

Besides the use of Personal Data described above, we use Personal Data in the ways listed below:

• Improving and Developing our Services. We use analytics on our Sites to help us understand your use of our Sites and Services and diagnose technical issues. We also collect and process Personal Data throughout our various Services, whether you are an End User, End Customer, Representative, or Visitor, to improve our Services, develop new Services, and support our efforts to make our Services more relevant and useful to you. Communications. We use the contact information we have about you to deliver our Services, which may involve sending codes via SMS for your authentication.If you are an End User, Representative, or Visitor, we may communicate with you using the contact information we have about you to provide information about our Services and our affiliates’ services, invite you to participate in our events, surveys, or user research, or otherwise communicate with you for marketing purposes, in compliance with applicable law, including any consent or opt-out requirements. For example, when you provide your contact information to us or when we collect your business contact details through participation at trade shows or other events, we may use this data to follow up with you regarding an event, provide information requested about our Services, and include you in our marketing information campaigns. Where permitted under applicable law, we may record our calls with you to provide our Services, comply with our legal obligations, perform research and quality assurance, as well as for training purposes.

• Social Media and Promotions. If you opt to submit Personal Data to engage in an offer, program, or promotion, we use the Personal Data you provide to manage the offer, program, or promotion. We also use the Personal Data you provide, along with the Personal Data you make available on social media platforms, for marketing purposes, unless we are not permitted to do so.

• Fraud Prevention and Security. We collect and use Personal Data to help us identify and manage activities that could be fraudulent or harmful across our Services, enable our fraud detection Business Services, and secure our Services and transactions against unauthorized access, use, alteration or misappropriation of Personal Data, information, and funds. As part of the fraud prevention, detection, security monitoring, and compliance efforts for EoD and its Business Users, we collect information from third parties (such as credit bureaus) and via the Services we offer. In some instances, we may also collect information about you directly from you, or from our Business Users, Financial Partners, and other third parties for the same purposes. Furthermore, to protect our Services, we may receive details such as IP addresses and other identifying data about potential security threats from third parties. Such information helps us verify identities, conduct credit checks where lawfully permitted, and prevent fraud. Additionally, we might use technology to evaluate the potential risk of fraud associated with individuals seeking to procure our Business Services or arising from attempted transactions by an End Customer or End User with our Business Users or Financial Partners.

• Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism activities, safeguarding vulnerable customers, export control, and prohibition of doing business with restricted persons or in certain business fields, among other legal obligations. For example, we may monitor transaction patterns and other online signals and use those insights to identify fraud, money laundering, and other harmful activity that could affect EoD, our Financial Partners, End Users, our Business Users and others. . Ensuring safety, security, and compliance for our Services is a key priority for us, and collecting and utilizing Personal Data is crucial to this effort.

• Minors. Our Services are not directed to children under the age of 13, and we request that they do not provide Personal Data to seek Services directly from EoD. In certain countries, we may impose higher age limits as required by applicable law.

Sharing of Personal Data.

Besides the sharing of Personal Data described above, we share Personal Data in the ways listed below:

• EoD Affiliates. We share Personal Data with other EoD-affiliated entities for purposes identified in this Policy.

• Service Providers or Processors. In order to provide, communicate, market, and advertise our Services, we depend on service providers. These providers offer critical services spanning from providing cloud infrastructure, conducting analytics for the assessment of speed, accuracy, and/or security of our Services, verifying identities, to providing customer service and audit functions. We authorize these service providers to use or disclose the Personal Data we make available to them to perform services on our behalf and comply with relevant legal obligations. We mandate these service providers to contractually commit to ensuring the security and confidentiality of the Personal Data they process on our behalf. The majority of our service providers are based in the European Union, the United States of America, and India. 

• Financial Partners. We share Personal Data with certain Financial Partners to provide Services to Business Users seeking such Services as well as offer certain Services in conjunction with these Financial Partners. For instance, we share certain Personal Data about Representatives, such as loan repayment data and contact information, with institutional investors who purchase or provide credit that's secured through the Capital loans we've extended to the Business Users they are associated with.

• Others with Consent. In some situations, we may not offer a service, but instead refer you to others (like professional service firms that we partner with to deliver the Atlas Service). In these instances, we will disclose the identity of the third party and the information to be shared with them, and seek your consent to share the information.

• Corporate Transactions. If we enter or intend to enter a transaction that modifies the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or part of our business, assets, or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity that buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.

• Compliance and Harm Prevention. We share Personal Data when we believe it is necessary to comply with applicable law; to abide by rules imposed by Financial Partners in connection with the use of their payment method; enforce our contractual rights; secure and protect the Services, rights, privacy, safety, and property of EoD, you, and others, including against malicious or fraudulent activity; and to respond to valid legal requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

• Contractual and Pre-Contractual Business Relationships. We process Personal Data to enter into business relationships with prospective Business Users and End Users and fulfill our respective contractual obligations with them. These processing activities include:

  • Creation and management of EoD accounts and EoD account credentials, including the assessment of applications to initiate or expand the use of our Services;

Legal Compliance. We process Personal Data to verify the identities of individuals and entities to comply with obligations related to fraud monitoring, prevention, and detection, laws associated with identifying and reporting illicit and illegal activities. 

Consent. We may rely on consent or explicit consent to collect and process Personal Data regarding our interactions with you and the provision of our Services such as Link and Identity. When we process your Personal Data based on your consent, you have the right to withdraw your consent at any time, and such a withdrawal will not impact the legality of processing performed based on the consent prior to its withdrawal.

Substantial Public Interest. We may process special categories of Personal Data, as defined by the GDPR, when such processing is necessary for reasons of substantial public interest and consistent with applicable law, such as when we conduct politically-exposed person checks. We may also process Personal Data related to criminal convictions and offenses when such processing is authorized by applicable law, such as when we conduct sanctions screening to comply with AML and KYC obligations.

Opting out of receiving electronic communications from us

If you wish to stop receiving marketing-related emails from us, you can opt-out by clicking the unsubscribe link included in such emails. We'll try to process your request(s) as quickly as reasonably practicable. However, it's important to note that even if you opt out of receiving marketing-related emails from us, we retain the right to communicate with you about the Services you receive (like support and important legal notices) and our Business Users might still send you messages or instruct us to send you messages on their behalf.

• Your data protection rights

  Depending on your location and subject to applicable law, you may have the following rights regarding the Personal Data we control about you:

  • The right to request confirmation of whether EoD is processing Personal Data associated with you, and if so, request access to that Personal Data
  • The right to request that EoD rectify or update your Personal Data if it's inaccurate, incomplete, or outdated;
  • The right to request that EoD erase your Personal Data in certain circumstances as provided by law
  • The right to request that EoD restrict the use of your Personal Data in certain circumstances, such as while EoD is considering another request you've submitted (for instance, a request that EoD update your Personal Data);
  • The right to request that we export the Personal Data we hold about you to another company, provided it's technically feasible;
  • The right to withdraw your consent if your Personal Data is being processed based on your previous consent;
  • The right to object to the processing of your Personal Data if we are processing your data based on our legitimate interests; unless there are compelling legitimate grounds or the processing is necessary for legal reasons, we will cease processing your Personal Data upon receiving your objection 
  • The right not to be discriminated against for exercising these rights; and 
  • The right to appeal any decision by EoD relating to these rights by contacting EoD’s Data Protection Officer (“DPO”) at hello@enterprise-ondemand.ai.

You may have additional rights, depending on applicable law, over your Personal Data. For example, see the Jurisdiction-specific provisions section under United States below.