Effective: May 9, 2022

Introduction and Scope

Data Sharing Hub Limited (“we,” “us,” “our”) takes the protection of your personally identifiable information (PII) very seriously and will not sell or trade PII. This Website Privacy Policy (the “Policy”) applies to our processing (e.g., collecting, recording, organizing, structuring, storing, adapting, altering, using, disclosing, erasing, destroying) of PII we receive when you use this website or any of our services. This Policy explains how we collect and use your PII for these purposes.

If we have entered into a written contract with you regarding your use of our services or applications, the PII processing terms of that contract (if any) are not limited by this Policy and will have control over any conflicting term of this Policy. This Privacy Policy applies to our general website visitors, and employees, and sub-contractors of collaborating tax offices using this website for business purposes.

Controllership

In the context of this Policy, we act as a data controller for PII we process about you.

Data We Collect

We may process the following categories of PII about our website visitors:

  • biographical information such as first and last name;
  • contact information such as phone number, email address, and mailing address;
  • professional information such as job title and position;
  • username and password;
  • internet or other similar network activity, such as your browsing history, search history, preferences, and information on your interaction with our website; and
  • any other categories of PII you choose to submit to us while using this website or by any other means.

We may receive your PII from you directly when you visit this website, or from you or your employer in connection with your employer’s use of our services.

We may also process the following categories of PII that we have received from collaborating tax offices:

  • employees’ contact information, such as phone number, email address, and mailing address;
  • employees’ professional information such as job title and position;
  • employees’ login information for the website, such as username and password;
  • biographical information (first and last name), contact information (phone number, email address, and mailing address), and professional information of collaborating tax offices’ sub-processors and their respective employees.

How We Use Your Data

We will use your PII to:

  • manage our business relationships;
  • contact you and to respond to your inquiries or other requests or questions;
  • facilitate your use of this website; and
  • help improve this website.

Basis of Processing

Within the scope of this Policy, we may process PII on the basis of the need to perform contractual obligations and responsibilities. Additionally, we may process PII on the basis of the pursuit of our legitimate interests, such as marketing, selling, and providing our services. In certain cases, we rely on your consent as the basis for processing. In such cases, you may revoke your consent at any time. To do so, please contact us using the contact information in the “Contact Us” section of this Policy.

Cookies

A “cookie” is a small file stored on your device that contains information about your computer. We may use cookies for session management and web analytics.

The use of cookies is industry standard, so your browser may be set to accept cookies. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you may not be able to access all of the features available on our website.

Sharing PII with Third Parties

We may use third party vendors to perform certain services on our behalf. These third party vendors include those providing:

  • hosting services;
  • processing services or software; and
  • e-signature software.

We may share your PII with these third party vendors solely to enable them to perform the services for us. In providing them with your PII, we require that these third party vendors maintain at least the same level of data protection that we maintain for your PII. We do not provide your PII to parties unconnected with the services we provide.

Some of our third party service providers may be located outside of the country that you reside in. In some cases, the authorities in your country may not have determined that the data protection laws in the countries where our third party service providers are located provide a level of protection equivalent to the laws in your country. We will only transfer your PII to third parties in these countries when there are appropriate safeguards in place. For example, if you are resident in the EU and the European Commission has not determined that the countries where our third party service providers are located provide an adequate level of protection for your PII, we will ensure that we have appropriate safeguards in place with the third parties, such as the European-Commission-approved standard contractual data protection clauses.

Other Disclosure of Your PII

We may also disclose your PII:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to, in response to subpoenas, search warrants, or court orders;
  • if we sell or transfer all or a portion of our equity, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
  • to our subsidiaries or affiliates if necessary for business and operational purposes.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about the users of our services as a group for any legal business purpose, such as analyzing usage trends.

If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.

Data Retention

PII processed by us in the context of this Policy may be retained indefinitely. However, you may send a request to us to ask to delete your PII, subject to the limitations described in this Policy.

Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect PII from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.

How We Respond to Do Not Track Signals

This website does not have the capability to respond to “Do Not Track” signals received from various web browsers. Please note that we do not allow third parties to collect PII about your online activities while using this website.

Accessing, Deleting, & Updating Your PII

If you are a data subject about whom we store PII, you may have a right to request access to, and the opportunity to update, port, correct, or delete such PII. Under certain circumstances, you may have a right to restrict or object to the processing of your PII. To submit such requests or raise any other questions, please reach out to us by using the contact information provided in the “Contact Us” section below.

To correctly respond to your privacy rights requests, we may need to confirm that you made the request. Consequently, we may require that you provide us with specific information that we already have on record about you to verify your identity and confirm that you are who you say you are.

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details set out below to verify their identity with us and confirm with us that they gave you permission to submit this request.

If you are a resident of the European Union, you may have the right to lodge a complaint with a data protection regulator in one or more of the EU member states.

If you are a California resident, you have the right not to receive discriminatory treatment for the exercise of your privacy rights.

Children’s Privacy

Our services are not designed to collect data from children under the age of 13. We do not knowingly collect PII from anyone under 18. If you believe your child’s PII may be processed in our services, you can contact us using the information in the “Contact Us” section of this Policy to request that we delete the PII.

Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page and update the “Effective” date above to reflect the date on which the new Policy became effective.

EU Representative

VeraSafe has been appointed as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted (in addition to us), only on matters related to the processing of PII. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative

Alternatively, VeraSafe can be contacted as follows:

VeraSafe Ireland Ltd
Unit 3D
North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

If you are a resident of the European Union, you may have the right to lodge a complaint with a data protection regulator in one or more of the EU member states.

Contact Us

If you have any questions about this Policy or our processing of your PII, please write to us by email at privacy@dsh.global or by postal mail at:

Data Sharing Hub Limited
Attn: Data Privacy
6900 Wedgwood Road N, Suite 400
Maple Grove, MN 55311
USA

We will respond to your inquiry within one month or less.