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Privacy


PRIVACY POLICY

 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

 

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

 

1.     Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 

We, us, our = DeedEasy.com, LLC

Our representative = Michael Lartey

Personal information = Any information relating to an identified or identifiable individual.

Special category personal information = Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.

Sensitive Personal Information = Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.

Biometric Information = An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

2.     Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

 

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

Name and IP address

​

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Name, and if provided by you, medical information and bank account number, credit card number, debit card number, or any other financial information.

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

If provided by you, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

Characteristics of protected classifications under California or federal law.

None.

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

None.

Biometric information

None.

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

None.

Geolocation data

None.

Audio, electronic, visual, thermal, olfactory, or similar information

None.

Professional or employment-related information

None.

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

None.

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

None.

Racial or ethnic origin, religious or philosophical beliefs, or union membership

None.

Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication

None.

Genetic data

None.

Processing of biometric information for the purpose of uniquely identifying a consumer

None.

Health information

None.

Sex life or sexual orientation

None.

 

If you do not provide certain personal information required to provide our products AND/OR services to you, it may delay or prevent us from providing our products AND/OR services to you.

3.     How Your Personal Information is Collected. We collect personal information from the following categories of sources:

  • You, directly in person, by telephone, text, or email and/or via our website and apps 

  • Third party with your consent (e.g., your bank)

  • Advertising networks

  • Internet service providers

  • Data analytics providers

  • Operating systems and platforms

  • Social networks

  • Cookies on our website

4.     How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations

  • For the performance of our contract with you or to take steps at your request before entering into a contract

  • For our legitimate interests or those of a third party –or–

  • Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for

Our reasons

To provide products AND/OR services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

If financial information is provided to us, then for our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity

Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator

To comply with any applicable  legal and regulatory obligations

Ensuring business policies are adhered to, e.g., policies covering security and internet use

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

·      Existing and former customers

·      Third parties who have previously expressed an interest in our services

·      Third parties with whom we have had no previous dealings

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

If you are applying for any kind of credit, then for credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

 

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

5.     EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside of our organization for marketing purposes.[MT1] 

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at info@DeedEasy.com.[MT2] 

  • Using the “unsubscribe” link in emails or “STOP” number in texts or

  • Updating your marketing preferences on our info@DeedEasy.com

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.

6.     Who We Share Your Personal Information With. We routinely share personal information with:

  • Our affiliates, including companies within the DeedEasy.com, Inc. group

  • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies

  • Other third parties we use to help us run our business, such as marketing agencies or website hosts

  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers

  • Credit reporting agencies

  • Our insurers and brokers

  • Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

7.     Personal Information We Sold or Shared. In the preceding 12 months, we have sold or shared the following categories of personal information:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

  • Characteristics of protected classifications under California or federal law

  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

  • Biometric information

  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

  • Geolocation data

  • Audio, electronic, visual, thermal, olfactory, or similar information

  • Professional or employment-related information

  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) –and–

  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

8.     Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)

  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

  • Characteristics of protected classifications under California or federal law

  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

  • Biometric information

  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)

  • Geolocation data

  • Audio, electronic, visual, thermal, olfactory, or similar information

  • Professional or employment-related information

  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) 

  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–

  • Sensitive personal information

9.     How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf

  • To show that we treated you fairly –or–

  • To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. 

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10.  California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

·      The categories of personal information we have collected about you, including sensitive personal information

·      The categories of sources from which the personal information is collected

·      The categories of third parties to whom we disclose personal information, if any –and–

·      The specific pieces of personal information we have collected about you

Please note that we are not required to:

·      Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained

·      Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–

·      Provide the personal information to you more than twice in a 12-month period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

·      The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–

·      The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, send us an email at info@DeedEasy.com

 

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

·      Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services

·      To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–

·      As authorized by further regulations

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

·      Delete your personal information from our records –and–

·      Delete your personal information from our records –and–

·      Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

·      Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us

·      Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes

·      Debug to identify and repair errors that impair existing intended functionality

·      Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law

·      Comply with the California Electronic Communications Privacy Act

·      Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent

·      Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us

·      Comply with an existing legal obligation –or–

·      Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

·      Deny goods or services to you

·      Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties

·      Provide a different level or quality of goods or services to you –or–

·      Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

 

11.  EEA Data Subjects: Your Rights Under the EU GDPR.

 

Right to Be Informed

The right to know or be notified about the collection and use of your personal information.

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

·      At any time to your personal information being processed for direct marketing (including profiling)

·      In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

12.  How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: info@DeedEasy.com. You may also call us at[MT3]  1-855-917-3860. 

  • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

  • If you choose to contact us directly by email you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number)

  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–

  • A description of what right you want to exercise and the information to which your request relates

  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.

  • Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13.  EEA Data Subjects: Where Your Personal Information is Held. Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

14.  EEA Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA

  • With your and our service providers located outside the EEA

  • If you are based outside the EEA –or–

  • Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses details of where they have been made available (where possible providing a link to the mechanism or information.

If you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).

15.  Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

16.  EEA Data Subjects: How to File a GDPR Complaint. We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. 

17.  Changes to This Privacy Notice. This privacy notice was published on August 13, 2023 and last updated on August 13, 2023.

We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email.

18.  How to Contact Us. Please contact us our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

 

Our contact details

Our Data Protection Officer's contact details

By Mail: 

DEEDEASY.COM, LLC

1441 Woodmont Ln NW #2905

Atlanta GA 30318

Email: info@deedeasy.com

Toll Free Tel: 1-855-917-3860

With a Copy to

Meghan Thomas, Esq

100 Hartsfield Centre Pkwy Ste 500-505

Atlanta, GA 30354

By Mail: 

DEEDEASY.COM, LLC

1441 Woodmont Ln NW #2905

c/o Data Protection Officer  Michael Lartey

Atlanta GA 30318

Email: info@deedeasy.com

Toll Free Tel: 1-855-917-3860

With a Copy to

Meghan Thomas, Esq

100 Hartsfield Centre Pkwy Ste 500-505

Atlanta, GA 30354

 

 

19.  Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

 

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