PRIVACY POLICY

As of June 01, 2024

Introduction

Thank you for visiting www.edgaragents.com, the Website of EdgarAgents LLC. and its affiliates doing business under the tradename EdgarAgents LLC (“EdgarAgents LLC” “we” or “us”).

To protect your privacy better, EdgarAgents LLC wants our clients, partners, employees, applicants, and other relevant parties to know how we collect personal data, the types of personal data we collect, and how we use and share your personal data. By visiting this Website (the “Site”), or providing your information to us, you are accepting the practices described herein. Note that this Privacy Policy only applies to personal data we collect (1) on our Site, (2) through our client and partner-facing applications and tools, (3) from communications or applications you send us, (4) when you interact with our advertising and applications on third-party websites and services, if they include links to this notice; and (5) through your contractual relationship with us, as applicable. This Privacy Policy does not apply to any other personal data.

Information We Collect

EdgarAgents LLC collects information that may be used to identify, describe, or link to people who visit our Site or request information about our product or the products of third parties. We collect and process personal data mainly from our clients and partners while doing business with them and we collect and receive personal data on this Site and through social networks. The personal data we process consists primarily of business contact information from our clients and partners and information you and our clients provide when using our products or accessing our websites or other applications.

We also collect and collate information (including some personal data) from third-party partners and public sources. We process the personal information to provide our services to our clients, to fulfill our contractual obligations and to improve our products and offerings. For more information on our processing activities, please review the sections below.

1. Personal data that we collect when you use the site

We collect several types of information and personal data, including data:

We collect this information and personal data:

Do Not Track (“DNT”) is a privacy preference that users are often able to set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. Please be advised that EdgarAgents LLC does not change its practices, described elsewhere in this Privacy Policy, in response to Do Not Track browser settings or signals. For information about DNT, visit www.allaboutdnt.com.

Third parties may collect personal information about your online activities over time and across different websites, including your use of this Site. This Privacy Policy does not apply to, and we are not responsible for, the practices of third parties that collect your personal information.

1. Personal data you provide to us

You may provide personal data to Us through your use of our Site or services, or when you apply for employment with us. The personal data we collect may include:

Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to conduct business with you or to resolve any inquiries or complaints.

We will indicate to you when personal data is required to enter into a contract with you (such as in anticipation of a services agreement) or to perform a contract with you (such as to provide services at your request), and when failure to provide any personal data may result in our inability to provide requested services or products.

For job applicants, we may collect various types of personal data about you for the purposes described in this Privacy Policy, including:

You may give us the personal data described above during the recruitment process, whether through the application forms on our online job portal, on the telephone or at interviews. We partner with certain third-party job sites, such as LinkedIn, and may receive your personal data via these organizations.

  • Personal data we collect through automatic data collection technologies If you navigate through and interact with our Site and some of our products, we may use automatic data collection technologies to collect certain usage information about your equipment, browsing actions, and patterns. Automatic data collection is carried out through the use of cookies and related technologies.

  • Personal data we collect from public sources and third parties In order to provide our content services to our clients, we rely on content provided by third-party partners, as well as content that is made available to the public. Some of that content includes general information about names of directors, registered board members, managers, fund managers and other official persons of companies published on public accessible websites, letterheads, prospects, annual financial statements, invitations to shareholder meetings etc.


During the job recruitment process, we may also receive personal data about you from other third parties; for example, recruiters; references from a previous employer; business partners; background check providers; as well as from publicly available sources such as social media.

Lawful Grounds for Processing

All processing and use of your personal data is justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the lawful ground that:

Where we rely on our legitimate interests to process personal data, those interests are:

How We Use Your Personal Data

The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or contract.

We use the personal data we collect to:

  • provide client services, including products and services; to take, verify, process, and deliver orders and returns; to process payments, technical support, or other similar purposes; and to establish and maintain client accounts;
  • address your inquiries associated with the information you provide to us;
  • provide training and after-sales-support on our products and answer to and perform change requests;
  • organize and perform incident management processes;
  • implement projects by working together with clients and their users as part of the project team;
  • communicate with clients and partners, including responding to requests for assistance and to update them about the status of their orders by postal mail, email, telephone, or text message;
  • investigate, prevent or take action regarding unauthorized use of our services, illegal activities, suspected fraud or situations involving potential threats;
  • provide you with underlying tools and applications helping to implement projects and resolve incidents;
  • discuss, carry out and implement change request and further developments of our products;
  • provide our content services to our clients and to report and administer clients’ users’ usage of third-party information products (e.g., real-time data from stock exchanges etc.);
  • administer and manage performance of purchase or sales agreements with our partners and clients;
  • to enhance the experience for our users, we use notes relating to support provided to specific employees, advisors or agents of clients in relation to our products and services for their future use of our services;
  • service your account;
  • to the extent it is lawful to do so, market and promote our products including through email or equivalent electronic means, to send news and newsletters, special offers and promotions, or to otherwise contact clients about products, services or information;
  • process, evaluate and complete certain transactions involving the Site, and more generally transactions involving EdgarAgents LLC products and services;
  • operate, evaluate, maintain, improve and develop the Site (including by monitoring and analyzing trends, tracking user behavior, access to, and, where lawful to do so, use of the Site for advertising and marketing);
  • to the extent it is lawful to do so, engage with you about events, promotions, the Site and EdgarAgents LLC  products and services and send you emails, event notifications, invitations, newsletters, announcements, and other communications regarding matters that may be of interest to you;
  • facilitate your job application process;
  • provide you with documentation or communications which you have requested, or which is part of a product;
  • correspond with users to resolve their queries or complaints;
  • protect the security of the Site, EdgarAgents LLC confidential and proprietary information (which may include personal data), and EdgarAgents LLC employees;
  • manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
  • share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets.
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EdgarAgents LLC will not sell or rent your personal data you provided to us to third parties for their own use; however, we may provide third parties with your personal data where there is a legal requirement to do so or where we need a third party to fulfill our services.

Sharing and Disclosure of Your Personal Data

When you have provided personal data to us, we may disclose personal data to other companies that we have engaged to assist us in providing you goods or services. This may include the following service providers:

  • fulfillment houses;
  • billing services;
  • transaction managers;
  • credit verification services;
  • market researchers; and
  • other third-party service providers.

We do not sell or rent personal data to third parties for their own use but may provide certain usage information to advertisers to help provide you with relevant advertising where we are allowed to do so. Usage information, as used in this policy, is anonymized and aggregated data, which does not identify you in the way Personal Data would.

We may also disclose any of your personal data or usage information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, as may be required by applicable law, or, as we may deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

We may also share your personal data in connection with the recruitment or employment application process, including sharing that data with:

  • EdgarAgents LLC affiliates;
  • recruiters;
  • IT service providers;
  • companies providing EdgarAgents LLC background check services; and
  • payroll systems.

If your application for employment with EdgarAgents LLC is successful, you will be provided with a separate notice during your on-boarding process, which will provide you with additional information.

We reserve the right to disclose, share, or otherwise transfer personal data and usage information in connection with a proposed or actual corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of our assets, or other fundamental corporate change, whatever form it may take. In the event that there is a change of ownership or control of your personal data or usage information, we will post a prominent notice to that effect on our Site.

Transferring Personal Data

EdgarAgents LLC is a global organization headquartered in the United States, and we may need to transfer your personal data to third-party partners and to our affiliates for the purposes described above. If your personal data is subject to the GDPR and is transferred outside the EU to other EdgarAgents LLC affiliates or to third-party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes. For transfers of personal data among EdgarAgents LLC affiliates we have put in place European Commission-approved Standard Contractual Clauses and have entered into an Intragroup data transfer agreement. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU, although please note that we may need to redact copies of transfer agreements for reasons of commercial confidentiality, provided that you can retain access to the relevant safeguards.

With respect to the information you provide to us through the recruitment or employment process, we may share and transfer your data with other members of the EdgarAgents LLC Group located globally (including in countries outside EU/EEA, such as the United States of America, India and the Philippines). EdgarAgents LLC has adopted an Intra-Group Data Transfer Agreement to ensure your personal data receives an adequate level of protection wherever it is processed within the EdgarAgents LLC group.

EdgarAgents LLC reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.

Retention of Your Personal Data

We keep personal data only for as long as required to fulfill the purposes for which it was collected. In general, we retain personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of client and partner dealings. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax or accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required in accordance with our document retention policy.

With respect to personal data we obtain from job applicants through the recruitment process, our general approach is to retain your application for a period of 6 months or, where you consent to a longer period of retention, for up to 2 years following the closure of the recruitment process for the role you applied for. Otherwise, you should note that, in certain cases, legal or regulatory obligations require us to retain specific records for a set period of time. If you accept employment with EdgarAgents LLC, your personal data will be held on the basis set out in our Employee Data Privacy Notice, which will be shared with you following your hiring.

Your Rights

You may have certain rights in connection with the personal data we collect from you or that you provide to us. Depending on where you reside, these rights may be specifically provided to you by statute. We will take steps in accordance with applicable legislation to keep personal data accurate, complete, and up to date.

Specifically, you may be entitled to exercise the below rights in connection with your personal data:

  • request that EdgarAgents LLC disclose our collection and use of your personal data during the past 12 months;
  • request that we provide your personal data to you in structured, commonly used and machine-readable format;
  • request that we correct any inadequate, incomplete, or incorrect personal data we hold;
  • request that we delete your personal data;
  • request that we restrict processing of your personal data;
  • object to processing or withdraw your consent for processing (including profiling) based on legitimate interest lawful grounds, without affecting the lawfulness of processing before withdrawal;
  • object to direct marketing (including profiling); or
  • file a complaint with the applicable supervisory authority.

Additionally, job applicants specifically have the following rights with respect to personal data:

  • withdraw your consent at any time; for example, if you are no longer happy for us to retain your unsuccessful application for an extended period of up to 2 years;
  • request that we restrict our processing of your personal data where:
    • you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
    • where the processing is unlawful but you do not want us to erase the personal data;
    • where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise, or defense of legal claims; or
    • where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether EdgarAgents LLC has compelling legitimate grounds to continue processing.

We will not discriminate against you in any way if you elect to exercise any of the above rights. Please contact us as indicated in the How To Contact Us section below or using the email-address: xe@edgaragents.com if you desire to exercise any of your rights, or if you have any questions or complaints regarding the processing of your personal data.

We may need to request additional information from you to respond to your request to exercise any of the above rights. We will respond to your verifiable request and to take action with respect to your request within 45 days. If we require additional time to disclose and or delete your personal information as provided under applicable law, we will inform you within 45 days of your request.

To the extent allowed under applicable law, EdgarAgents LLC may decline to comply with certain data deletion requests in the event that your personal data is required to:

  • complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between EdgarAgents LLC and you;
  • detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • debug to identify and repair errors that impair existing intended functionality;
  • exercise free speech, ensure the right of another client to exercise his or her right of free speech, or exercise another right provided for by law;
  • comply with applicable laws or legal obligations;
  • 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 that information is likely to render impossible or seriously impair the achievement to that research, if you have provided informed consent;
  • enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; or
  • otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.

Children

This Site is not intended or directed to anyone under the age of 16 and we do not provide services to anyone who we know to be under the age of 18, nor do we collect any personal information from anyone who we know to be under the age of 18. If you are under the age of 16, you should use this Site only with the involvement of a parent or guardian and should not submit any personal information to us.

Data Security

EdgarAgents LLC takes reasonable precautions to protect personal data from loss, misuse, unauthorized access, disclosure, altercation, and destruction. Unfortunately, while we work hard to ensure the security of your personal data while it is on our systems, no security measures are perfect, and data transmitted over the Internet is not guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any personal data you transmit, and you do so at your own risk.

Where we have given you (or where you have chosen) a password to access certain parts of our jobsites, you are responsible for keeping this password confidential. We request that you do not share a password with anyone. You are responsible for the confidentiality of the password related to your account.

Links to Other Websites

Our Site may provide links to other websites for your convenience and information. These websites may operate independently from EdgarAgents LLC. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by EdgarAgents LLC, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

Changes to Our Privacy Policy

This Privacy Policy may be amended from time to time. Please review it periodically. Changes to this Policy will be identified by the date at the top of this page.

How to Contact Us

If you have any questions or comments about this Privacy Policy, EdgarAgents LLC privacy practices or if you would like us to exercise any of your data subject rights, please contact us as provided below:

Legal Department
207 W 25th Street, 9th Floor New York NY 10001

Phone: (212) 265-3347

Email: info@edgaragents.com

Visit: www.edgaragents.com