Doo Finance US Privacy Policy

Last Updated: December 6, 2023

Doo Finance US Inc., a Delaware corporation (collectively “Doo Finance,” “we,” “us,” or “our”) provides back-office services, including Odoo accounting implementation and migration services (“Accounting Implementation Services”), bookkeeping and accounting processing services (“Accounting / Bookkeeping Services”), strategic consulting services (“Management Advisory Services”), tax advisory and preparation services (“Tax Services”), and other miscellaneous back-office support services (collectively our “Services”).

This Privacy Policy (“Privacy Policy”) provides information about our personal information processing practices in the context of marketing and selling our Services to prospective customers, providing our Services to our customers, and operating our business.

We collect, use, and disclose information for the purpose of marketing, selling, and providing services to businesses and other organizations worldwide, but primarily in North America and Europe, and not individuals. To the extent we process personal information about an individual (“you”), it is for the purpose of marketing and selling to the organization which employs you (or with which you are affiliated), or it is in connection with (a) providing our Services to the organization which has collected your data and (b) operating or improving our Services. As a provider of services to organizations we do not knowingly process data of individuals who are under sixteen (16) years old.

We primarily use Odoo’s platform to perform our Services. Please refer to Odoo’s Privacy Policy for more information regarding their policies and services.

If you have questions regarding our Privacy Policy or practices, or if you are a California or Virginia resident and wish to exercise any of the rights described below, please contact us at support@doo.finance.

Our Privacy Policy contains the following sections:

Information for Prospective Customers. This section describes the types of personal information we collect from and about representatives of the organizations that we desire to sell our Services to, our purposes for processing it, and how long we retain the various types of data.

Information for Customers. This section describes the types of data we process (which we call Customer Data, Business Record Data, and Administrative Data) in connection with providing our Services to our customers and the related operation and improvement of our Services and our business, as well as the purposes for processing, and how long we retain the various types of data.

Information for Job Candidates. This section describes how we collect, process, use, disclose, and retain personal information that we obtain about you in the course of our recruiting and hiring efforts.

General Information. This section describes our processing of personal information related to call recording and categories of third parties to which personal information is or may be disclosed (refer to this section for definitions when categories of third parties are discussed in earlier sections), as well as information about updates to this Privacy Policy, managing your personal information, your rights, and how to contact us with questions about this Privacy Policy or, as applicable, to exercise your rights.

INFORMATION FOR PROSPECTIVE CUSTOMERS

This section applies to you if you are a visitor to our website, if we have obtained your contact information in the context of our other marketing and sales activities (e.g., via a referral, lead purchase, or marketing survey), if you have attended a Doo Finance-organized or Doo Finance-sponsored event (whether online or in-person), or if you are in the process of purchasing our Services on behalf of your employer.

Information We Process.

Categories of personal information we collected in the context of our sales and marketing efforts in the last twelve (12) months and sources from which we obtain personal information are set forth in the table below:

Personal Information Category	Example	Source(s)
Website visitor; Referral, lead purchase, or other marketing; Representative of prospective customer purchasing Services; Event attendee
Identifiers	Name Phone number Email address Mailing address	You, if you choose to provide your name and contact information Someone else in your organization if they provide us with your name and business contact information An acquaintance of yours who thinks your organization could use our Services may provide us with your business contact information Our third-party data enrichment vendors Publicly available information Social media sites Promotional partners Integration partners
Employment-related information	Your employer’s name Your job title	You, if you choose to provide this information Someone else in your organization if they provide us with your name, title, and the company where you work An acquaintance of yours who thinks your organization could use our Services may provide us with your business contact information Our third-party data enrichment vendors Publicly available information Social media sites Promotional partners Integration partners
Website visitor; Representative of prospective customer purchasing Services
Identifiers	Internet protocol (IP) address Cookie identifier	Our tools for measuring activity on and use of our website collect your IP address and set Cookies on your browser Our tools for identifying the organization with which you are associated based on your IP address collect your IP address
Internet activity information	Information about your visit to our websites, including referring pages and your navigation through our websites Information about your interactions with our marketing emails	Our tools for managing email campaigns Our tools for measuring activity on and use of our website and engagement with email marketing efforts, which include the use of Cookies Our tools for monitoring the effectiveness of our advertising and sales campaigns, which include the use of Cookies
Inferences from personal information	Analysis of effective ways to position our products by sales personnel based on communications with you and/or your engagement with our website or marketing materials	Sales and marketing service providers that provide scoring and analytical tools
Geolocation data	IP address	Our tools for measuring activity on and use of our website collect your IP address
Representative of prospective customer purchasing Services
Audio and visual information	Recording of your voice and likeness in calls or video-conferences with our sales and service delivery personnel	You, with your consent as required by law

Sensitive personal information. Please do not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership). If you provide us with any sensitive personal information when you use the website or Services, you must consent to Doo Finance’s processing, retention, and use of such sensitive personal information in accordance with this Privacy Policy.

How We Use Your Information.

We collect and process personal information for the business purposes of marketing and selling our Services. We process your personal information with the goal of entering into an agreement to provide our Services with your employer or organization with which you are affiliated. This includes, for example:

Sending you marketing communications like emails to (1) make you aware of, or provide you with information you have requested about, our Services or the services of our partners, (2) engage with you, and (3) analyze and improve our marketing efforts based on your engagement with our marketing communications, including analyzing whether you opened an email and how you interacted with it.
Communicating with you during the sales process, including, for example, via email, call, or videoconference. During the sales process, you may provide samples of your business’s financial data that we may use to determine the appropriate Services to quote you.
Creating, managing, and maintaining lead lists.
Collecting information about your visits to our websites to (1) collect information about your organization’s needs and your position within your organization, (2) determine how to optimize our sales efforts with respect to your organization, (3) measure and improve the effectiveness of our website, and (4) measure the effectiveness of targeted marketing efforts. Please see “Operation of our corporate website” below for additional information.
Analyzing our interactions with you to optimize our sales processes.
Improving our sales and marketing processes, including training our sales personnel and updating strategies and initiatives.
Conducting market research and product research and development.
Conducting surveys for marketing or product research and development purposes, for example, to assess the needs of the industries that we serve.
Managing event registrations and attendance, including communicating with you about an event.

Operation of Our Corporate Website.

Cookies and tracking technologies. In accordance with applicable law, Doo Finance, our service providers, and other third-party website services providers whose services we use on our corporate website use commonly-used tools to recognize your visit and track your interactions with our corporate website (including subpages) such as cookies, web beacons, pixels, local shared objects, local storage, and other tracking technologies (collectively, “Cookies”). We use this tracking data to operate our corporate website. For example, we use Cookies to personalize and improve your experience on our corporate website and to record your preferences. If you identify yourself on our corporate website (e.g., by completing a web form), we can match (using a service provider) your identifying information with a Cookie associated with you (but which does not identify you by name, email, or phone number) to analyze the effectiveness of our marketing efforts (such as measuring the results of marketing campaigns), communicate with you and provide you relevant information, and determine sales efforts to apply to your company. We also combine data about your visit to our corporate websites collected from Cookies with that of other website visitors to improve your and other website visitors’ experience.

Third-party website service and analytic providers, like Microsoft or Google, may collect personal information from visitors to our website. When you visit our website, certain actions may be tracked automatically through the use of Cookies or tracking technologies and reported to us. For Microsoft’s privacy practices, please refer to their Privacy Statement. Please refer to the Google Privacy & Terms for more information.

Social Media Features. Our corporate website may use social media features, like buttons that enable you to share content from our corporate website on social media platforms (“Social Media Features”). These Social Media Features may collect your internet protocol address and which page you are visiting within our corporate website, and may set a Cookie to enable the feature to function properly. Social Media Features are governed by the privacy policy of the company providing the relevant Social Media Features.

Links to other sites. Our corporate website includes links to other websites whose privacy practices may differ from those of Doo Finance. If you visit or submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Re-targeted advertising. Re-targeted advertising or behavioral advertising uses information about an individual's web browsing behavior such as the webpages they have visited or the searches they have made. This information is then used to display more relevant ads. The information collected is linked to a cookie ID (alphanumeric number). The information used for targeted advertising usually comes through third-party website publishers. If you would like to opt out of re-targeted advertising from Doo Finance that occurs when visiting our third-party advertising publishers, please visit the opt-out pages of Network Advertising Initiative, here, and the Digital Advertising Alliance, here, or if located in the European Union, click here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

How long we retain information for prospective customers.

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (e.g., 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Retention of internet activity information collected by third-party website services providers is determined by the applicable third party.

INFORMATION FOR CUSTOMERS

This section applies to you if you are affiliated with one of our customers and would like to understand how we process personal data in the context of providing our Services and operating our business.

Information We Process.

In connection with providing our Services, we process Customer Data, Business Records Data, and Administrative Data. The sections below describe each of these data categories, purposes of processing, and retention period. The section titled “General Information” describes the categories of third parties to whom personal information is or may be disclosed.

Customer Data.

Customer Data is data provided by our customers or at their direction for the provision of the Services, and excerpts and reports of such data prepared as part of the Services for customers.

Customer Data includes financial and business information of our customers that they provide or make available to us that enables us to provide our Services. We receive this information directly from our customers or when they authorize us to access third-party data repositories (including customer vendors and data aggregating services). We may import transaction data from a customer’s legacy payment processing service, payroll service provider, bookkeeping software, or other service provider of customer via software integration (such as an application programming interface) or obtain transaction data via log-in information provided by the customer. We may develop ways to obtain transaction information from third-party repositories that are more efficient than the initial method, and may update the ways of obtaining transaction data under a customer's initial authorization.

This financial and business information may include personal information such as identifiers, names of individuals, relationships of individuals with our customers (like job title), and commercial information or employment-related information related to transactions between individuals and our customers (like invoice amounts or payroll amounts), as well as information related to entities (like names, transaction dates, and amounts). Customer Data provided in the context of our tax preparation services commonly includes the names of corporate officers and directors, ownership information, business contact information, and social security numbers of certain individuals for purposes of inclusion in the customer’s tax return or for completion of information returns.

Customer Data also includes financial information that we generate on behalf of our customers in the course of providing our Services, such as reports of financial information provided by our customers or at their direction, which may incorporate personal information. For example, we prepare financial statements on behalf of our bookkeeping customers, which contains data that we compute on our customers’ behalf. Depending on the customer’s form of business organization, the financial statements may include the names of individuals.

For customers who subscribe to more than one of our Services, one Service may obtain Customer Data from another Service to prevent duplicative requests for the same information. For longer term customers, we may use Customer Data from prior years’ Services for current Services.

IMPORTANT NOTE: Customers provide us access to third-party systems. Information practices of these third parties (e.g., Odoo) are governed by their privacy policies and data governance programs and are outside of Doo Finance’s control.

How we use Customer Data. We process Customer Data on behalf of our customers for purposes of providing Services to our customers, and maintaining and improving our Services. For example, we process Customer Data:

To provide, monitor, and improve our Services. We process Customer Data on behalf of our customers to provide, monitor, and improve our Services. For example:

Our service delivery personnel review reconciliations of transaction data to prepare financial statements on behalf of our customers.
We may create automated rules that increase efficiency in tasks such as categorizations based on learnings from Customer Data.
We may monitor a customer’s expenses to ensure appropriate pricing.
We may track changes in a customer’s business to monitor account health and identify opportunities for customer outreach, (e.g., if a customer has a financing event, we may contact the customer regarding additional offerings).
We test and analyze new features of our Services intended to improve their efficiency or to enable customer insights into their financial information. These activities may include processing of Customer Data.
We make product development investments based on trends in customer behavior.

To Provide Customer Service and Support. We may also process Customer Data in connection with customer support requests.

For Research, Including Publishing or Sharing Combined Information from Multiple Customers or Users, But Only in a Way that Would Not Allow the Customer or Any Other Person to be Identified. Only in a way that would not allow a customer or any other identifiable person to be identified, we may prepare and share information, such as benchmarking studies, about our customers with third parties. We or our third-party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow a customer or any other identifiable person to be identified. For example, we might analyze which vendors our customers most commonly have transitioned from and disclose the results on our website. We might also sample aggregate expense data from our customers to publish insights on our website.

How long we retain Customer Data. Except as discussed below in Business Records Data, we retain Customer Data relating to tax information for at least seven (7) years from the due date (including extensions) of the related tax filing and we retain other Customer Data for the purposes of assisting former customers (upon request at current hourly rates) with post-termination questions related to our Services as they transition to a different service provider, complying with legal obligations, resolving disputes, enforcing our agreements, completing any outstanding transactions, and detecting and preventing fraud. We may retain Customer Data until we receive a request to delete it, in which case, subject to any applicable legal requirements, we will take reasonable steps to remove or anonymize Customer Data in our systems that is not contained in Business Record Data. We retain Customer Data incorporated into our reconciliation rules in a manner that does not identify the customer indefinitely and in accordance with applicable law.

Business Record Data. In the course of providing our Services, our personnel communicate with representatives of our customers through a number of channels, including email, messaging applications, and conference calls (including video conference calls), all of which generate Business Record Data. Business Record Data includes customer instructions and authorizations that we rely on to provide our Services to our customers, as well as work papers and other information incidental to Service delivery, such as meeting scheduling information and follow up questions to customers (and information relating to our methodology that guides our processes and timing of gathering information from customers in order to provide our Services). Categories of personal information we collect and sources from which we obtain personal information are set forth in the table below:

Personal Information Category	Example	Source(s)
Identifiers	Name Email address Phone number Mailing address	Individual points of contact of our customers who correspond with us as we provide our Services. Customer points of contact provide personal information about additional points of contact.
Employment-related information	Your employer’s name and your job title	Individual points of contact of our customers who correspond with us as we provide our Services (e.g., a job title commonly appears in an email signature). Customer points of contact provide personal information about additional points of contact.
Audio and visual information	Recording of your voice and likeness in calls or video conferences with our sales and service delivery personnel	Individual points of contact of our customers who participate in calls or video conferences, with their consent
Inferences from personal information	Customer satisfaction survey results	Individual points of contact of our customers who respond to customer satisfaction surveys

How we use Business Record Data. We collect and process Business Record Data for our business purposes, which include, for example:

To Provide Our Services and Operate Our Business. We process Business Record Data to provide our Services and customer support to our customers and for our business purposes, including service delivery management, analysis and improvement, new product and process development, and record keeping.

Customer Service and Support. We may use various Internet chat services, for example, Odoo’s “Chatter” or the WhatsApp integration in order to speak with each other. A transcript of the chat session may be retained to resolve questions or issues related to our Services.

How long we retain Business Record Data. We retain Business Record Data for the purposes of maintaining documented customer instructions and approvals and a record of our relationships with customers, complying with legal obligations, resolving disputes, enforcing our agreements, completing any outstanding transactions, and detecting and preventing fraud. We retain this data for as long as we may have a legal reason to keep it, which is up to the end of the longest applicable statute of limitations period. We may delete this data earlier if we determine that it is not necessary to retain for the purposes mentioned above. Customer Data may also be included in emails, messages, or call recordings. To the extent Customer Data exists in our Business Record Data, it is incidental to our business purpose for retaining Business Record Data, and we process this Customer Data only for record keeping and legal purposes, and only in the context of our business relationships with our customers. The retention period for service fulfillment partners providing additional services is governed by the service fulfillment partners’ privacy policy and data governance practices.

Administrative Data. Administrative Data includes information related to Service management (e.g., user account credentials, billing information, etc.), and information about the usage of our Services (e.g., log data or metadata from service delivery communications and customer interactions, such as email senders and recipients, subject lines, dates of communication, and response times).

Categories of personal information we may collect and sources from which we obtain personal information are set forth in the table below:

Personal Information Category	Example	Source(s)
Identifiers	Name Email address Phone number Mailing address Internet protocol address Cookie identifiers	You, if you choose to provide this information Individual points of contact of our customers who correspond with us as we provide our services. Customer points of contact provide personal information about additional points of contact Doo Finance’s systems collect identifiers like internet protocol addresses and Cookies automatically
Employment-related information	Your employer’s name and your job title	You, if you choose to provide this information Our third-party data enrichment services
Internet activity information	Information about a user’s navigation through our application Your responses to a customer satisfaction survey included in the email signatures of correspondence related to Doo Finance Services	Our tools for measuring activity on and use of our application, which include the use of Cookies
Inferences from personal information	Analysis of effective ways to improve our Services for all customers	Our analysis of metadata that we collect about the use of our products and services

How we use Administrative Data. We collect and process Administrative Data for our business purposes, which include, for example:

Account Registration. We may use your name, mailing address, phone number, and email address to register an account for you for certain Services we provide (e.g., to create an account in our system) and to communicate important information to you. If you set up an account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your personal information.

To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing our Services to your employer, providing support related to our Services, and protecting our Services, including to combat fraud and to protect your information.

Customer Service and Technical Support. We may use your name, mailing address, phone number, email address, and how you interact with our Services to resolve questions you may have about our Services and to follow-up with you about your experience.

Communicate with You and Tell You About Other Services. We may use your business contact information to communicate with you about our Services and to give you offers for third-party (e.g., our Integration Partners) products and services that we think may be of use to you. Please see below under “General Information—Your Rights and Managing Your Privacy” for the choices you have regarding these communications.

To Improve Services and Develop New Services. We may use Administrative Data to personalize or customize your experience and our Services, develop new features or services, and to improve the overall quality of our Services.

Feedback. We may use (a) any suggestions that you make to us and (b) information you volunteer in surveys you answer for us, and combine them with feedback and/or answers from other customers, in order to better understand our Services and how we may improve them. Answering any survey is optional.

Research, Including Publishing or Sharing Combined Information from Multiple Customers or Users, But Only in a Way that Would Not Allow the Customer or Any Other Person to be Identified. Only in a way that would not allow a customer or any other identifiable person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes. We or our third-party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow a customer or any other identifiable person to be identified.

How long we retain Administrative Data. We will retain Administrative Data as long as necessary to serve you, to maintain a customer’s account for the entire period during which a customer subscribes to our Services, or as otherwise needed to operate our business. We retain and use Administrative Data as required by applicable law and Doo Finance’s records and information management policies to comply with our legal obligations, resolve disputes, enforce our agreements, complete any outstanding transactions, and for the detection and prevention of fraud, as well as to improve our Services, develop new services, and for any other business use, including disclosure to third parties or publicly, provided that we will not publicly disclose information that identifies a customer by name or its employees without the customer’s consent, unless otherwise required by law. We retain Administrative Data until we determine that we no longer need it for the purposes described above. We may retain different types of Administrative Data for different periods, some of which may be retained indefinitely.

When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and, unless you have opted out of receiving marketing communications, let you know about products and services that may interest you.

INFORMATION FOR JOB CANDIDATES

This section applies to you if you voluntarily provide us with personal information when you apply for a job or otherwise contact us in a recruiting context. This includes, for example, when you submit a job application to us, you complete a form containing your personal information, or you include employment information like the content of your resume.

We may also obtain personal information from sources other than you. Sometimes we obtain information about potential job candidates from third parties (e.g., recruiters may send us job application information that includes your personal information for an employment position that may interest you). We may source potential candidates using LinkedIn or another sourcing tool to find names, contact information, and qualifications (e.g., employment and educational history) of potential candidates. We may also receive personal information about you from prior employers and professional references, educational institutions, credentialing and licensing organizations, consumer reporting agencies for employment background checks (as applicable and in accordance with applicable law), and other sources as may be directed by an applicant. In the course of the application and interview process, we generate additional personal information about you. For example, if you interview with us, our personnel who meet with you will ask you questions about your experience and skills in order to evaluate your ability to meet the business needs of the role that you are applying for. Interviewers then discuss their assessment of your ability to meet the business needs of the role to arrive at a final employment decision. For many roles, we administer assessments of applicant skills, the results of which we factor into our evaluation of your ability to meet the business needs of the role you have applied for.

The subsections below describe the categories of personal information you provide to us and categories of personal information that we obtain from other sources. The section titled “How Do We Use Personal Information?” describes the purposes for which we use job candidate personal information.

Personal Information You Provide to Us.

Category	Examples
Identifying Information	Legal name, preferred name, previous last name (as applicable), date of birth, postal address or location, email address, phone number, last four digits of Social Security number, driver’s license number (which you provide to our background check provider)
Educational and Professional Background	Work history, academic, and professional qualifications and other information you include in your resume, responses to interview questions and assessment results, as applicable, and cover letter; whether you would seek to work for another employer while working at Doo Finance
Third Party Identifying Information	Name and contact information of references that you provide
Criminal history	With your consent, background check results
Employment eligibility	Whether you would need us to sponsor visa now or in the future
Health information	If you request a reasonable accommodation, we collect disability information in accordance with applicable law and to the extent needed to evaluate and, as applicable, provide reasonable accommodation

‍Personal Information We Obtain from Other Sources

Category	Examples
Identifying Information	Legal name, preferred name, email address, phone number
Educational and Professional Background	Work history, academic, and professional qualifications and other information you include in your resume, responses to interview questions and assessment results, as applicable, and cover letter; whether you would seek to work for another employer while working at Doo Finance
Recruitment information	Job interview notes, responses to screening questions, test scores and other assessment results, as applicable, information from reference checks, and any other information we gather from third parties in connection with the recruitment process
Inferences drawn from personal information	A profile reflecting your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes

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The above tables describe categories of personal information that we collect and process in the course of our recruiting efforts. It is possible that you may share other personal information that comes to our attention, for example, through social media or the news. We may also use this information for the purposes described below.

How Do We Use Personal Information? We may use your personal information for the following categories and subcategories of business purposes.

General Recruiting Purposes

Recruitment of Employees and Processing and Managing Job Applications: We use your personal information to process your job application. For example, we use your personal information to create an applicant profile in our system, evaluate your qualifications and skills against the requirements of the position for which you are applying, schedule and conduct interviews, and communicate with you.

Conducting Pre-Employment Screening and Background Checks. In accordance with applicable law, we use your personal information to conduct employment screening and background checks via third-party service providers, as well as to conduct reference checks.

Operate and Improve our Recruiting Efforts. We use our recruiting experience to analyze and improve our recruiting efforts, which may include analyzing a particular candidate’s experience in the process. We analyze our recruiting pipeline, processes, and operations to assess, audit, and improve our recruiting program’s effectiveness.

Compliance

Recordkeeping. We keep records of your personal information as required by law and in accordance with our record retention policies.

Preventing Fraud or Illegal Activities. We process applicant personal information to detect, prevent, and respond to fraud, misuse of our recruiting process, and potentially illegal activities.

Compliance with Legal Requirements. We use your personal information to comply with applicable laws, regulations, and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, and enforce our legal rights.

To Whom is Job Candidate Personal Information Disclosed? We may disclose your personal information for the business purposes described above with the following parties:

Service Providers. We may disclose your personal information to service providers, such as recruiters, pre-employment screening services like a technical interviewing service, background check providers, and consultants who perform recruiting tasks. Note that many of our service providers provide software that enables the service providers to monitor usage of their software. Service providers’ use of this data is subject to the applicable service provider’s privacy policy.
Affiliates and Subsidiaries. We may disclose your personal information to our affiliates and subsidiaries.
Governmental Authorities and in Legal Matters. As required by law or legal process, we may disclose your personal information to federal or state regulatory agencies, law enforcement, courts, and other governmental authorities. In addition, we may be required to disclose your information in the context of civil litigation. When possible, we will endeavor to take steps to preserve the confidentiality of your personal information.
Professional Advisors. We may disclose your personal information to our professional advisors, such as auditors and law firms.
Parties Involved in Business Transfers. If we sell, merge, or transfer any part of our business, we may transfer to the acquirer information in our possession or control, including personal information.
Third Parties as Directed by You. If you request us to provide your personal information to a third party, we may provide personal information to the requested third party.

How Long Do We Keep Personal Information for Recruiting Purposes? We retain your personal information as long as we have a business purpose to do so or as long as required by law. This generally means that we will retain your personal information for purposes of complying with legal requirements (by law we are required to retain certain information for a certain period), recruitment, processing and managing employment applications, and keeping a record of our relationship, and until the earlier of: (a) these purposes are fulfilled, which is currently indefinitely, or (b) your request that we delete your information. Exceptions may include retention periods that are set in our systems related to content or retention periods required by law or our internal recordkeeping policies.

GENERAL INFORMATION

Call Recordings.

As noted above, we may record calls and video conferences both in the sales and service delivery context. Recordings might contain identifiers of individual participants in the call, such as name, as well as audio and, if a participant has their camera on in a video conference, visual information. We use these recordings for training, note-taking, service delivery, process analysis and optimization, recordkeeping, and research and development. Recordings may be shared with Doo Finance personnel who need to access it for these business purposes. We retain recordings until the earlier of your request that we delete your information (subject to any limitations provided by applicable law) and our determination that we no longer need your information for the purpose for which we collected it.

How We Disclose Your Personal Information? In the course of providing our Services and operating our business we disclose personal information outside of Doo Finance.

Service Providers. Use of our service providers’ services may generate data (e.g., log data or aggregated usage data) that we do not input into these services and over which we have no control. These types of usage data are subject to the privacy policies of the applicable service provider.

Service Fulfillment Partners. From time-to-time, we may work with non-affiliated service providers which fulfill certain of our Services. With customer consent (1) we disclose customer business contact information to these service fulfillment partners for customer relationship management purposes and (2) we also disclose, or make available with our access, Customer Data to these service fulfillment partners so that they can perform the services. These partners’ activities are subject to their privacy policies and data governance programs.

Third-Party Website Services Providers. We may use services of third parties that are not “service providers” (as defined in the California Consumer Privacy Act (CCPA)) on our website. These include ad networks and analytics and marketing services that we use for internet marketing and website analytics purposes.

Response to Subpoenas and Other Legal Requests. We may share information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request. We may also share information with litigants in civil litigation in accordance with our customer agreements and as required by law.

Protection of Doo Finance and Others. We may share account information, personal information and Usage Data when we believe it is appropriate to enforce or apply our agreements; or protect the rights, property, or safety of Doo Finance, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the practices described in this Privacy Policy.

Affiliates. We may disclose the information you provide or that we collect to our affiliates for service delivery purposes.

Sale of Our Business. If we sell, merge, or transfer any part of our business, we may transfer to the acquirer information in our possession or control, including personal information.

Business Advisors. We may disclose information customers provide to us or that we collect or prepare to professional advisors who are subject to professional or contractual confidentiality requirements such as lawyers, bankers, auditors, brokers, and insurers.

With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your personal information may be shared with other third parties.

Per Customer Instructions. An authorized representative of a Doo Finance customer may from time-to-time instruct us to disclose information to a third party that includes personal information.

De-identified and Aggregated Data

Once de-identified or aggregated in a way that does not permit reidentification, data is not personal information and we may use it for any purpose and retain it for any period.

International Data Transfers

In accordance with and as permitted by applicable laws and regulations, we reserve the right to transfer your information, process and store it outside your state, province, or country of residence to locations where we or our third-party service providers operate. We may use personnel or service fulfillment partners who may be located outside of the United States. Information that we provide or make available, or that you provide directly, to our service fulfillment partners may, as permitted by law, be transferred outside the United States for purposes of Service fulfillment.

Cross-border data transfer. If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed (i) pursuant to the recipient’s compliance with GDPR standard contractual clauses, or, (ii) as otherwise permitted by applicable European requirements.

How to Contact Us

If you have questions or comments about this Privacy Policy, please contact us via email at support@doo.finance. We welcome your feedback and comments.

Changes to our Privacy Policy

From time-to-time we may change or update our Privacy Policies. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.

If we make material changes to the way we process your Personal Information, we will provide you notice via our Services or by other communication channels, such as by email or posting on this website. Please review any changes carefully. All changes are effective immediately upon posting and your use of our Services after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes.

Your Rights and Managing Your Privacy

Updates and Access. You can update information that you have provided to us (e.g., in the context of account creation). Contact your relationship team to make an update request or email support@doo.finance. In addition, as required by applicable law (see for example, “California and Virginia Privacy Rights” below), you may contact us to confirm whether we maintain any of your personal information and to review it in order to verify its accuracy. Where you have determined that the personal information that we collected about you is inaccurate, you may also request that your personal information be updated or corrected. Subject to applicable law, you may also request that we delete your personal information. Requests for access to your personal information and to have it corrected, amended, or deleted should be sent to support@doo.finance.

IMPORTANT NOTE: If you believe that one of our customers, affiliates, or third-party services providers processes personal information about you, please contact them directly.

Managing Marketing Communications From Us. We will honor your choices about receiving marketing communications from us. Please note that even if you choose not to receive marketing communications from us, we will continue to send you required Service or transactional communications.

Cookies and Other Tracking Technologies. You have control over some of the Cookies that we use on our corporate websites. Information on changing your browser settings to opt out of Cookies can be found in your browser settings. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For the third-party services and re-targeted advertising described in “Information for Prospective Customers—Types of information we collect—Operation of our corporate website” you can opt-out by following the instructions at the links provided. If you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track. Like many companies online, we may use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. You may be able to block our website from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

Additionally, the following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

Google: https://adssettings.google.com
X (formerly Twitter): https://twitter.com/settings/account/personalization?lang=en
LinkedIn: https://www.linkedin.com/psettings/guest-controls

Note: Because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Mobile Settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Refer to the capabilities and instructions for your mobile application(s) to find out more.

California and Virginia Privacy Rights

If the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA) or the Virginia Consumer Data Protection Act (VCDPA), applies to you (e.g., if you are a “consumer” under the CCPA), you have the following rights with respect to personal information that we process in our capacity as a “business” under the CCPA (“controller” under the VCDPA), which includes personal information described in the following sections and subsections:

"Information for Prospective Customers,"
“Information for Customers”

“Business Record Data” (other than any “Customer Data” contained in “Business Record Data”) and
“Administrative Data” sections of “Information for Customers,”

“General Information”

“Call Recordings”

If you submit a verifiable consumer request, you have the right, subject to either the CCPA, CPRA, or VCDPA, if and as applicable:

To receive disclosure of:

The categories of personal information that we have collected about you;
the categories of sources of the personal information we have collected about you;
the business or commercial purpose for our collecting, selling or sharing of personal information about you;
the categories of third parties to whom we disclose your personal information (please note that this Privacy Policy provides the information that we would provide upon verifiable request for this data category and the above three data categories);
the categories of personal information that we have sold or shared;
the categories of third parties to whom personal information was sold or shared;
the categories of third parties to whom personal information was disclosed for a business purpose; and
the specific pieces of personal information that we have collected about you (subject to applicable legal limitations);

To request deletion of your personal information by us, subject to applicable legal limitations;
To request correction of inaccurate personal information;
To be free of discrimination on the basis of having exercised your rights under the CCPA, CPRA, or VCDPA.

In the previous twelve months, we may have “shared” within the meaning of the CCPA the following categories of personal information to the following categories of third party:

Category of Personal Information	Category of Third Party to Whom Disclosed
Identifier (cookie or internet protocol address)	Third-party web services providers
Internet activity information	Third-party web services providers
Geolocation data (to the extent that is determinable from your internet protocol address)	Third-party web services providers

For disclosures required by CCPA Section 1798.110(c) and Section 1798.115(c)(2), as well as additional information related to our data processing in our capacity as a “business” under the CCPA, please see the tables and sections set forth above in this Privacy Policy.

You have the right to opt out of “sales” or “sharing” within the meaning of the CCPA of your personal information if you are a California resident. You can opt out of our “selling” or “sharing” of your personal information if you are a California resident, or targeted advertising if you are a Virginia resident, by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our webpages. To our knowledge, we have not sold personal information of consumers (as defined in the CCPA) under sixteen (16) years of age.

If you have any questions about how we handle your information, the contents of this Policy, how to update your records or how to obtain a copy of the information that we hold about you or exercise your rights under the CCPA, CPRA, or VCDPA, please write to support@doo.finance. We will generally verify your identity using information in your inquiry and data in our possession. We may ask you for additional information to verify your request.