DenSwap is an online marketplace for coworking spaces available at https://www.denswap.com/, which facilitates the buying and selling of coworking businesses (“Platform”). DenSwap is based in the United States of America but offers its goods and services, including its Platform to users all over the world (our “goods” and “services”).
For the purposes of the GDPR, DenSwap is both the “data controller” and a “data processor” of Personal Information and is legally responsible for how Personal Information is collected and used. This policy sets out how we collect, hold, protect, use or disclose your Personal Information, and how you may change or request that we amend your Personal Information.
What information do we collect?
We collect and hold your Personal Information which may include your name, email address, phone number, mailing address, information relating to your business and other information relevant to the supply of our goods and services. If you use our Platform to buy or sell a business, we may also collect your bank or credit card details and details about your credit history and creditworthiness.
We may also collect non-personally identifiable information about you (such as anonymous usage data, IP addresses and location, browser or platform type etc).
Further examples of the information we collect are set out below.
How do we collect Personal Information?
We collect your Personal Information during the course of providing our goods and services to you. This includes when you visit or use out Platform, provide information to us by email, when you create an account or profile via our Platform, when you provide us with information relating to your business, when you ask us to send you newsletters, alerts or other materials, or otherwise via customer enquiries and communications.
Generally, we collect your Personal Information directly or automatically through your use of our Platform but we may also collect your Personal Information from other people or organisations if you have given your consent.
More detailed examples of the information we collect include:
- Personal information you may give us when you use our Platform or register for an account with us
- Identifying information such as your name, addresses, telephone numbers or email addresses when you register for an account with us
- Buying, or selling information you provide during a transaction, or other transaction-based content that you generate or that is connected to your account as a result of a transaction you are involved in.
- Other content that you generate, or that is connected to your account.
- Financial information (such as credit card or bank account numbers) in connection with a transaction.
You may also provide us other information through a web form, by updating or adding information to your account, through your participation in community discussions, member-to-member communications, chats, dispute resolution, or when you otherwise communicate with us regarding our Platform.
Additional information we are required or authorised by applicable laws to collect and process in order to authenticate or identify you or to verify the information we have collected.
Personal information we collect automatically when you use our Platform or register for an account with us:
- We collect information about your interaction with our Platform, your usage preferences, and your communications with us. This is information we receive from devices (including mobile devices) you use when you access our Platform. This information could include the following:
- Location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.
- Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
Personal information collected from other sources
We supplement the personal information we collect directly with information collected from third parties and add it to your account information. For example, we collect and use demographic and other information that is publicly available, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable laws.
We also collect information from and share information with third party payment providers and parties who assist us with fraud prevention. These include without limitation, Stripe and PayPal.
We allow you to share information with social media sites, to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal information retained by the respective social media site about you. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site.
If you give us personal information about someone else, you must do so only with that person’s authorisation. You should inform them how we collect, use, disclose, and retain their personal information according to our privacy notice.
Why do we need your Personal Information?
We only collect or hold your Personal Information for legitimate purposes, including to provide you with our goods and services, and for the proper administration of our Platform.
In particular, we need your Personal Information to:
- provide you with the services we offer via the Platform including by creating accounts and seller listing descriptions, estimating sales values for domains or businesses, and assessing the validity of information about domains or businesses on the Platform, and processing payment for our services;
- maintain our business relationship with you by answering any questions you may have about DenSwap or the Platform, communicating with you about our products and/or services, creating and updating our database(s) and other records, ensuring compliance with our contractual and other legal obligations to you, providing support services to you and otherwise responding to enquiries;
- market and advertise to you including by sending you newsletters, special offers, and promotions, or otherwise contacting you about products or information we think may interest you. We may contact you through phone, email, SMS and social media;
- improve the quality and design of our goods and services by storing, tracking, analysing and processing user preferences and trends as well as user activity and communications to create new features, functionality and services in relation to the Platform;
- comply with the law including by complying with our legal obligations and by investigating, preventing or taking action in respect of suspected illegal activity, fraud, or similar activities; and exercise our legal rights including exercising rights we may have under law or a contract between us and you, or between us and a third party,
- (together our “Purposes”)
If you do not provide us with your Personal Information, we will not be able to carry out some or all of our Purposes.
Can you remain anonymous or use a pseudonym?
In some instances, if you do not provide us with some of Personal Information we may not be able to provide you with the relevant goods, services or information. This may also have an effect on whether we can begin or continue a relationship with you, and whether we allow you to use or transact on our Platform.
What disclosures do we make?
Generally speaking (and as described above under the heading “Why do we need your Personal Information”) we will disclose your Personal Information for our Purposes. We may also disclose your Personal Information in other ways with your consent, to any other party where we are authorised or required to do so by law, or to our partners or service providers (including technology partners, hosting providers, payment processors, and fraud prevention service providers) in order to assist us to provide our products or services to you.
Some of our partners and service providers or the services they provide may be based outside of the United States of America (including in Australia, Great Britian, the Philippines, and throughout the world). By providing us with your Personal Information, you acknowledge that your Personal Information may be used, stored and disclosed overseas, including in jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. To protect your Personal Information we take care to work with partners and service providers who are based in countries that provide adequate levels of data protection, or otherwise take steps to ensure that your Personal Information receives adequate levels of data protection in the jurisdictions in which it is processed in accordance with all applicable privacy laws (including the GDPR).
Personal Information of minors
We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use our goods or services (including by registering an account on our Platform). If we become aware that we have collected personal information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.
Do we use “cookies”?
When you visit our Platform, the server may attach a “cookie” to your computer’s memory. A “cookie” assists us to store information about how you use our Platform and to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity. We may use knowledge of your user experience to better understand what goods or services may be of interest to you and to collect statistical information.
Using other sites
Is your Personal Information confidential and secure?
We take all reasonable steps to keep your Personal Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may keep your Personal Information in both hard copy and electronic forms, but adopt appropriate technical and organisational security measures to protect it; including by storing it in secure systems accessible only to authorised personnel.
We also urge you to take steps to keep your Personal Information safe, such as choosing a strong password and keeping it private, as well as logging out of your account on our Platform, and closing your web browser when finished using the DenSwap Platform on a shared or unsecured device.
Your choices and rights
We welcome your inquiries and comments and encourage you to contact us to update your Personal Information if it changes. You may confirm if we are processing your Personal Information and request a copy of it. For your protection, however, we may require that you confirm your identity before we provide a copy of your Personal Information to you.
You may also update or correct your Personal Information by contacting us, or by amending your Personal Information on your account via our Platform.
In some instances, you may request that we delete your Personal Information. In accordance with and subject to relevant privacy laws (including the GDPR), you may object to certain Personal Information being processed and request that processing of your Personal Information be limited. You may also limit or manage our communications with you by “unsubscribing” from certain email and newsletter updates, and by closing your account on our Platform.
If you choose to limit the Personal Information we process about you we may not be able to communicate with you or fulfil our Purposes outlined above. This may include limiting your use of our Platform.
Queries and complaints
If you have a question or want to make a complaint about how we handle your Personal Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint).
We can be contacted at: firstname.lastname@example.org.
For more information about the GDPR, please contact the European Data Protection Supervisor, the European Union’s independent data protection authority or visit their website at: https://edps.europa.eu/.