Privacy Policy

Effective starting: 25 May 2018

Ansarada Pty Limited and our related entities (“Ansarada”, “us”, “we” and “our”) are committed to protecting the privacy of our customers and users.

This Privacy Policy describes how and why we collect personal information about you, how we use, store and disclose that information, and how you can exercise your privacy rights. It also outlines how you can contact us to access and update your personal information or to raise any privacy concerns.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

“Ansarada Services” are all the products and services we may provide to you, including our websites, our online virtual data rooms and associated services, the Material Information Platform™ and the Ansarada Intelligent Deal Assistant™.

As used in this Privacy Policy, “personal information” means any information or an opinion that identifies you, or that could reasonably be used (for instance, in combination with other data) to identify you directly or indirectly, including by reference to an identifier such as a name, identification number, location data, online identifiers. It can include information you provide to us (for example, through our websites and your use of the other Ansarada Services), publicly available information, and information we collect from other sources as described in this Privacy Policy.

We may update this Privacy Policy from time to time by posting a new version on our websites. When an updated Privacy Policy is posted, we will change the “Effective starting” date at the top of the policy accordingly.

Where our changes are material, we will try to notify you – this may be by way of an email or a notice on our websites, or an alert on the login screens for the Ansarada Services that will appear for at least 30 days. We may not notify you if the way in which we use your personal information has not changed.

If you do not agree with its terms or any of the changes we make, you should either cease using the Ansarada Services or exercise whatever rights you may have, as described in this Privacy Policy, to opt-out of how we use your personal information.

We collect your personal information to supply you with the Ansarada Services and to further develop, enhance and safeguard those services. We may also use your personal information to:

  • perform and administer the Ansarada Services;
  • understand the way you use the Ansarada Services;
  • improve your experience when using the Ansarada Services, including by personalising the services;
  • facilitate the predictive functionality and the provision of recommendations, comments and prompts forming part of the Ansarada Services;
  • address and reply to requests for customer support;
  • identify, remedy and prevent any technical or security issues affecting the Ansarada Services;
  • send you information by email, mail or other channels;
  • send you marketing communications, offers and opportunities relating to us or to carefully chosen third-party businesses where we think they might be relevant to you; and
  • perform any other functions described in our terms and conditions or this Privacy Policy.

If we do not collect this information from you, you might not be able to use the Ansarada Services or create an account or profile with us, some of the functions comprising the Ansarada Services might not be available to you, and/or we might not be able to communicate with you (including through marketing communications).

We may also collect, use, store and disclose your personal information for purposes and to recipients additional to those that are set out in this Privacy Policy. Where we do so, we will disclose those purposes and recipients to you when you provide your information to us.

The personal information we may collect includes information that you provide voluntarily to us, information that we collect automatically and information that we obtain from third party sources. This may include:

  • your contact details, including your name, mailing and email addresses, and telephone numbers;
  • your username, job title, company name and a photograph, and any additional information connected with a profile or account that you create or that is created for you;
  • your billing information, including your payment details and billing address;
  • preferences about the way you would like us to communicate with you, including in respect of marketing communications;
  • information about the way you access and use the Ansarada Services, including the way you use the online virtual data rooms or Material Information Platform™, the content you post, your interactions with other users, and your use of features, links and third-party integrations;
  • log information such as your IP address, the date and time when you used the Ansarada Services, the details of the webpage you visited before accessing the Ansarada Services, your browser type, configuration and plug-ins, your language preferences, and cookie data. For more information on our use of cookies, please see our Cookie Policy;
  • information about the device on which you are using the Ansarada Services, including the device type and settings, operating system, device identifiers, application IDs, and crash information. We may use your Wi-Fi and IP address from your device or browser to ascertain your general location, but we will only collect GPS location data from your mobile device with your consent;
  • analytics information collected when you use the Ansarada Services, or information that we generate or derive, including through queries we run in respect of use of the services and content contained in the services. This data, which could incorporate personal information, may include the username and IP address of the person using the Ansarada Services, the parts of the Ansarada Services being accessed and used, any relevant domain names and identifiers, and data about attachments (including their original filenames and sizes). We may also collect aggregated analytics data about the use of the Ansarada Services, which will not contain personal information;
  • information about third-party services you integrate when using the Ansarada Services. We will connect any such services to the Ansarada Services, and we may receive information about your account (including personal information) from the third-party service provider. We will not collect or hold your passwords for any third-party services; and
  • information about our user base and the performance of marketing campaigns. This might include personal information and/or aggregated information that does not identify individuals.

We may also process personal information incorporated in the content that users create, provide, post, host, upload, store, communicate or display when you use the Ansarada Services (“User Content”). This may include sensitive information, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Where we process personal information in content, we do so on behalf of our customers and users and it is their responsibility to have lawful grounds to use that personal information. We will not be responsible for obtaining consent for the use of any sensitive information that is incorporated in any User Content.

We collect personal information in a number of ways, including:

  • when you establish an account with us, or when another user (for instance, a user from your company) creates an account for you;
  • when you create or amend your profile;
  • when you use the Ansarada Services;
  • through your device or browser, as outlined above;
  • when you submit personal information directly to us, including through the use of our websites and the other Ansarada Services, where you submit online forms, and where you send emails or other communications to us;
  • from third parties. To ensure we are providing you with information, marketing, offers and opportunities that are relevant to you, we may collect information about you from sources including our marketing partners, publicly-accessible databases and social media. We may also collect information about our user base, the Ansarada Services and our marketing campaigns from our related bodies corporate, our service partners, or others;
  • from your third-party service providers. We may collect information from the providers of third-party services you integrate when using the Ansarada Services, as described above; and
  • by running analytics or generating analytics data in connection with the Ansarada Services, including through queries we run in respect of use of the services and content contained in the services.

We may disclose the personal information we collect:

  • with your team administrator, where you use the Ansarada Services as part of a team (for instance, a purchaser team in an acquisition transaction). In line with your company’s policies, your team administrator may be able to access and control your Ansarada account and retrieve, share or delete your personal information;
  • with other users of the Ansarada Services. For instance, your name, photograph and contact details may be displayed to other users, including in your profile and in posts or notifications. Similar types of personal information might also be made available to others in your organisation to allow them to locate and collaborate with you. You can also choose to share information with others as part of the Ansarada Services, such as when you use our online virtual data rooms to communicate with others;
  • with our service providers, such as our technology and customer assistance service providers. Those providers may access your personal information as we may direct or permit in order to facilitate and improve your use of the Ansarada Services;
  • in accordance with legal requirements and our legal rights – for instance, where necessary to comply with statutory requirements, to prevent fraud, to prevent death or serious injury, or to protect our proprietary rights. Where you use our Q&A functionality, we may provide certain organisations whose registered users view or post Q&A information with a separate copy of that information, in order for them to comply with the rules of the U.S. Securities and Exchange Commission (SEC). Those organisations (and their related companies) may use and disclose such information to the extent required to comply with those SEC rules, and any other law to which they are subject (and may transfer and store that information offshore); and
  • to related entities of Ansarada Pty Limited for the purposes of performing the Services and operating our group’s business. A list of our group companies is set out below:

    • Ansarada Newco Pty Ltd
    • Ansarada Subco Pty Ltd
    • Ansarada International Pty Ltd
    • Ansarada UK Limited
    • Ansarada US Inc
    • Ansarada Pte Ltd
    • Ansarada (Pty) Ltd
    • Ansarada Hong Kong

  • to a new owner or potential buyer of Ansarada, where the ownership of all or substantially all of the Ansarada business, or individual business units owned by Ansarada, were to change. This information would be provided in order to allow the Ansarada Services to continue to operate.

Some of the recipients described above, including our service providers, your team administrator, other users of the Ansarada Services, any new owner of Ansarada, and the SEC, are or may be located offshore.

We may disclose your personal information to third parties to allow them to market to you (including through direct marketing) if we have first obtained your consent or if we have other lawful grounds to do so.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have privacy laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our group companies and third party service providers and partners operate around the world and, in particular, in Australia, the United States of America, Amsterdam, Germany, Hong Kong, the United Kingdom and Vietnam. This means that when we collect your personal information we may process it in any of these countries.
We currently host our servers for the Ansarada Services in Australia using a third party hosting provider (Amazon Web Services or ‘AWS’).

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to continue providing access to the Ansarada Services or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We only retain User Content for such time as permitted by our contracts with our customers or for such time as they instruct or permit us to do so.

You have the following privacy rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by using the setting made available via the Ansarada Services or by, if settings are not available via the Ansarada Services, by contacting us using the contact details provided under the “Contacting Ansarada about Privacy” heading below.
  • In addition, if you are a resident of the European Union, you can object to processing of your personal information or ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Ansarada about Privacy” heading below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contacting Ansarada about Privacy” heading below.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a privacy authority about our collection and use of your personal information. For more information, please contact your local privacy authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable privacy laws.

Please note that we do not offer any of the rights described above with respect to any personal information that is incorporated in any User Content. We process such content on behalf of our customers and if your personal information is contained in any such content, you should contact the customer on whose behalf we have stored the information. If you consider that one of our customers is unlawfully using your personal information by incorporating it within any content on

In storing your personal information, we use a number of security and organisational measures and technologies to safeguard your personal information from unauthorised access, modification or disclosure and misuse, interference or loss. We have personnel tasked with protecting your information, developing new security features, and identifying and mitigating vulnerabilities. Our existing security measures include encryption, two-factor authentication, and notifications when new devices and apps are connected with your user account. We also have in place security measures and policies focused on restricting access to sensitive information to authorised personnel.

While we hold your information on a secured server behind a firewall and we encrypt data transfer using 256 bit SSL encryption, please be aware that there are inherent risks in transmitting information using the internet.

The Ansarada Services are certified to meet ISO 27001 information security standards. Please contact us for further information on the scope of our ISO 27001 certification.

Please contact us using the below details if you have queries about our Privacy Policy and privacy practices, or the way we deal with your personal information. You may also contact us using these details if you wish to exercise any of your privacy rights described in the section entitled “Your privacy rights” above.

Postal Address:
Ansarada
Level 2, 80 George Street, The Rocks
Sydney NSW 2000
Australia

Telephone: +61 2 8241 0800

Email: [email protected]

Position title and name: Head of Legal – Michael Bates

Where you are located in the European Economic Area (EEA), you may also contact Ansarada UK Limited, our UK related company who also acts as our EU representative for the purposes of European privacy law:

Postal Address:
288 Bishopsgate,
London
EC2M 4QP, UK

Telephone: +44(0) 20 3058 1060

Email: [email protected]

Position title and name: Global Head of Customer Success – Richard Thomas

When you request that we access or correct your personal information, we will need to locate the relevant information, so it would assist us if you could supply as much supporting detail as possible. Where we refuse your access or correction request, we will comply with any requirements under applicable laws to notify you of our reasons for doing so and the mechanisms through which you may complain. Where we deny a request to correct information and where you make a request to us, we will comply with any applicable legal requirement to associate with the information a statement that it is inaccurate, out of date, incomplete, irrelevant or misleading.

We take your privacy complaints seriously. Where you inform us that you have a complaint about our handling of your personal information, we will contact you to let you know which of our team members will investigate your matter and the timeframe within which they will aim to respond to you.

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