This Privacy Policy explains how Dice Enterprises N.V., a Curacao limited liability company and its subsidiaries and affiliates (“Enterprise Dice”, “we” or “us”) collects, uses, and discloses information about you when you access or use our website and other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
Collection of Information
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services (like send a message through the Services), fill out an application, investor questionnaire, subscription agreement or another form, make an investment, apply for a job, communicate with us via third party social media sites (such as LinkedIn), request customer support, or otherwise communicate with us. The types of information we may collect when you access or use our Services as a non-investor include your contact information (name, email address, postal address, phone number) and educational information (post-secondary education level, postsecondary institution of attendance), as well as any other information you choose to provide. If you are an investor, we will collect the above-listed information in addition to other information including additional identifiers (your social security number), financial information (bank account and routing information, other payment information, wire transfer instructions, information in support of your accredited investor status, transaction history, other payment information, income sources, net worth, investment preferences), employment information (current and former employers, job titles, duration of employment), and any other information you choose to provide.
Other Information We Collect When You Use our Services
When you access or use our Services, transact business with us or engage with us at events, we automatically collect information about you, including:
- Usage Information: We collect information about your use of the Services as more fully described below.
- Transactional Information: When you make an investment, we collect information about the investment, such as fund details, investment vehicle, investment amount, and date of the investment.
- Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Location Information: We may derive the approximate location of your device from your IP address. In accordance with your device permissions, we may also collect information about the precise location of your device. You have the ability to stop the collection of precise location information at any time (see Your Choices below for details).
- Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us to: improve our Services and your experience, see which areas and features of our Services are popular, count visits, email you recommendations, and share data with advertisers, such as location, search history, YouTube history, and data from sites partnering with our service providers, so that the ads you see are more relevant to you. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below.
Information We Collect from Other Sources
We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, publicly available sources, customer feedback, financial services providers, and marketing service providers. Additionally, if you create or log into your account through a social media site, such as LinkedIn, we will have access to certain information from that site, such as your name, account information, and friends lists, in accordance with the authorization procedures determined by such social media site.
Information We Derive
We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address, or your eligibility for certain types of private investment based on your personal and/or financial information.
Use of information
We use the information we collect for our everyday business and commercial purposes, such as to process your transactions, maintain your accounts, and provide you with information, and for our and our marketing purposes, such as to offer ENTERPRISE DICE or its subsidiaries offerings, notify of and invite you to events, and customize your experience with us. We also use the information we collect to:
- Comply with corporate governance, audit, reporting and regulatory and legal requirements;
- Provide, maintain and improve our products and services;
- Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
- Communicate with you about products, services, and events offered by ENTERPRISE DICE and others, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, and browsing and purchasing behavior and audit your interactions with our online ads, including by counting ad impressions and verifying positioning and quality of ad impressions;
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of ENTERPRISE DICE and others;
- Debug to identify and repair errors that impair existing intended functionality;
- For limited internal uses, provided the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction;
- In connection with research and development activities; and
- Carry out any other purpose described to you at the time the information was collected.
Sharing of Information
We will not share data except in the following circumstances:
- With vendors, service providers, and consultants that perform services for us, including providers who assist us with operating and supporting the Services and with other investment processing functions, financial institutions, third-party custodians including third- party custodians, and our analytics, marketing and consulting service providers assisting us with the preparation and circulation of our business and marketing communications and event planning;
- With our attorneys, accountants, and/or auditors;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among ENTERPRISE DICE and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
- With your consent or at your direction.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, such as LinkedIn, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by ENTERPRISE DICE and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.
Transfer of Information to the CURACAO and Other Countries
ENTERPRISE DICE is based in the CURACAO and we process and store information in the CURACAO and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
Your Choices
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Additional Disclosures for Individuals in Europe
If you are located in the European Economic Area, United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
When we process your personal data, we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the investments or services you have requested).
We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our investments and Services, and to provide, secure, and improve our investment and Services.
We find such processing is necessary to comply with our legal obligations.
We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
Data Subject Requests
You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account.
Data Retention
We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.