Privacy Policy

Since the protection of your personal data (“data“) is of particular concern to us, we process your data exclusively on the basis of the applicable legal provisions. In this Privacy Policy, we inform you in accordance with Art 13 and 14 of the General Data Protection Regulation (“GDPR“) about how we, as the data controller, process your data in connection with the provision of our Services and our websites www.valutico.com and www.done-diligence.com (“website“). Unless otherwise defined in this Privacy Policy, the definitions in our General Terms of Service or GTS or specific product terms will apply here.

 

This Privacy Policy is directed to (i) our customers (“Customers“), and (ii) other users of our services as well as website visitors (“Users”; in particular employees of our Customers or other interested parties). Unless the following expressly refers to Customers or Users, the provisions of this Privacy Policy are addressed to both Users and Customers (collectively referred to as “you“, “your“).

 

  1. The controller of your data is:

Web Value GmbH

FN 424876 v

Siebensterngasse 54/10

1070 Vienna, Austria

(“we“, “us“)

info@valutico.com

 

  1. How do we process your data?
  1. Business relationship with Customers

 

We process data of our Customers (in particular contact data, billing data) to fulfill our obligations arising from the contractual relationship with the Customers, namely the provision of services to Customers and Users, in particular SaaS solutions with regard to business valuation (Art 6 para 1 lit b GDPR). We further process Customers’ data to fulfill legal obligations (e.g. tax obligations; Art 6 para 1 lit c GDPR) and/or to protect legitimate interests, unless the interests of the Customers in the confidentiality of their data prevail (Art 6 para 1 lit f GDPR).

 

  1. Registration / Provision of Services

 

Our Services are generally offered via our website (SaaS, web applications). If no login is required, only data according to 2.d) is processed.

 

If Services are accessible via user accounts subject to your prior login, your name, email address and passwords are processed. Additionally, within the user account also other data such as your contact information as well as information regarding the valuation reports or regarding other queries performed within the service is processed.

 

The aforementioned data is processed for the purpose of operating and providing our Services.

 

As regards Customers, the processing of data in the context of registration for a user account or the provision of services is based on Art 6 para 1 lit b GDPR.

 

As regards Users, the processing of data in the context of registration for a user account or the provision of services is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to fulfill the contract with our Customers and to grant Users access to our services.

 

  1. Estimate

 

If you use our service Estimate, available at https://my.valutico.com, you may generate limited business valuation reports. In this case, your contact details will be obtained so that the valuation report can be sent to you by email.

 

With your consent, the valuation  report will also be sent to experts in the field of business valuation (e.g. tax and business advisors) and you agree to potentially be contacted by them (by email or phone) and be presented an offer for further consulting services by them. You can withdraw your consent that your data may be shared with experts at any time for effect in the future by sending an email to customer-success@valutico.com.

 

The data processing for the creation of the report and sending to you is based on the performance of the contract pursuant to Art 6 para 1 lit b GDPR. The transfer of your contact data to experts is based on your explicit consent according to Art 6 para 1 lit a GDPR.

 

  1. Cookies and Tracking

 

In the course of using our services and or visiting our website, we collect the following data from you, in particular for the purposes of quality assurance and further development of our services and website: date, time and duration of use of the services / website, IP address, system data on the device and operation system used as well as data with regard to your browsing behavior and search operations conducted. We collect this data automatically with cookies and tracking tools provided by third-party providers on the basis your consent pursuant to Art 6 para 1 lit a GDPR (or in connection with Section 165 para 3 Austrian Telecommunication Act in the case of so-called “persistent” cookies, which are stored on your end device).

 

You can reject the storage of individual cookies or the use of tracking tools (via configuration in the cookie banner) or revoke the storage or use of tracking tools in the browser settings at a later time. When cookies are stored or tracking tools are used on the basis of your voluntary consent, your data is sometimes transmitted to recipients in third countries outside the EEA, in particular to the USA. The USA has not been certified by the European Court of Justice as having an adequate level of data protection; in particular, there is a risk that data may be viewed by US authorities for control and monitoring purposes. By giving your consent, you agree that cookies and tracking tools from third-party providers in the USA or from other insecure third countries may be used and accept a possible lower level of data protection (Art 49 para 1 lit a GDPR).

 

Cookies that are absolutely necessary for the structure or functioning of our services or website (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to be able to provide the services and the website in a correspondingly functional manner.

 

  1. Contact / Request

When you contact us via email or through other contact options offered, the data provided by you will be processed in order to handle and respond to the respective request, in particular: name, email or phone number, any data provided in the text or conversation.

 

We process data to administrate the Customers’ contact requests in the context of (pre)contractual relationships pursuant to Art 6 para 1 lit b GDPR.

 

We process data to administrate the Users’ contact requests in the context of our legitimate interest to provide User support and to fulfill our contracts with Customers according to Art 6 para 1 lit f GDPR.

 

  1. Newsletter

If you subscribe to our newsletter, we process the data you voluntarily provide, in particular your name and email address, in order to send you up-to-date information on our products, events and other relevant news at regular intervals.

 

The data processing is based on your explicit consent according to Art 6 para 1 lit a GDPR in connection with Section 174 para 3 Austrian Telecommunication Act. You can withdraw your consent at any time with effect for the future (by email to customer-success@valutico.com) or via the “unsubscribe button” in the respective newsletter email. Your data will be stored until your valid withdrawal.

 

  1. Testimonials

 

If you give us your explicit consent, we will process your name and if possible your photo in the context of evaluations of our company (testimonials) and publish them on our homepage, in (print) publications and on other social media sites.

 

You are aware that such information can be accessed on the internet by any person. Despite all technical precautions, it cannot be ruled out that such persons may use this information or pass it on to other persons.

 

You can withdraw your consent to the use of your testimonial at any time by e-mail to customer-success@valutico.com with effect for the future.

 

  1. Interaction Metadata for AI Features

When you use our AI Features (including DoneDiligence), we collect, use and analyse Interaction Metadata to train, develop or improve the AI Features or other aspects of our Services.

“Interaction Metadata” means anonymised and aggregated data regarding how Users interact with the AI Features, which may include:

(a) navigation patterns (such as clicks, page views, and feature usage);

(b) questionnaire structures and templates (but not the specific content or data entered);

(c) query types and categories (but not the actual queries or their results);

(d) selection of valuation methods, peers, or analytical approaches; and

(e) usage frequency and timing patterns.

We ensure that any Interaction Metadata:

(a) is de-identified so that it does not identify you, your organization, or any other person;

(b) is aggregated with data across multiple customers;

(c) excludes any queries, patterns or data points that are unique to you or any specific User; and

(d) does not contain, reflect or enable the reconstruction of any Customer Data, Inputs or Outputs.

Interaction Metadata, as processed in accordance with the safeguards above, does not constitute Customer Data or Confidential Information.

The processing of Interaction Metadata is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to improve and develop our Services and AI Features for the benefit of all Users.

 

  1. Storage Duration

 

  1. Users

 

If Users have created an account with one of our services, we generally store User data for the duration of the Users’ active account, unless there are mandatory provisions for the further retention of certain data or for our defense of legal claims.

 

If, in addition, User data is processed on the basis of the Users’ consent, we store User data until the Users withdraws their consent.

 

Cookies that are stored on the Users’ end device are stored for a maximum period of 14 months.

 

  1. Customers

 

We store data within the scope of business relationships with Customers for the duration of the active contractual relationships as well as beyond that in accordance with the statutory retention and documentation obligations (e.g. in accordance with the Austrian Commercial Code as well as the Austrian Tax Code). Further storage of Customers’ data is possible in particular for the defense of our legal claims.

 

  1. Who will your data be shared with?

Your data will be communicated to the following recipients in the course of processing for the above purposes:

 

  • Service providers (in particular IT providers)
  • Company subsidiaries, insofar as necessary for the provision of our services
  • Experts in the field of business valuation when using Estimate product (only upon your consent)
  • Banks, tax consultants, auditors (for our internal accounting and financial processes)
  • In case of occasion to legal representatives, notaries, courts and administrative authorities
  1. Transfer to third countries

If the above-mentioned recipients of your data are located outside the EEA and the country in question has not been determined by decision of the EU Commission to have an adequate level of data protection, we will ensure that the transfer is made on the basis of standard contractual clauses or otherwise in accordance with Art 46, 47 or 49 of the GDPR.

 

  1. What rights do you have?

Right to information

 

As long as we process your data, you have the right to information about the purposes of processing, the categories of data, the origin and the recipients of your data and the duration of storage.

 

Rectification and erasure of data

 

If we process inaccurate or incomplete data, you have the right to rectification of such data. If your data is processed unlawfully, you may also request us to erase your data. You may also request the erasure of your data if your data is processed unlawfully, subject to legal obligations preventing the erasure of your data.

 

Limitation of processing

 

You may request us to limit the processing of your data in certain cases.

 

Data portability

 

You have the right to receive the data, which you have provided to us, in a structured, commonly used and machine-readable format. You have the right to direct transmission of those data to another controller as far as this is technically feasible.

 

Right to object

 

You have the right to object, on grounds relating to your particular situation, at any time to processing of data concerning you. If you object to processing of your data, we shall cease to process this data unless our legitimate interests to processing your data prevail. Where data are processed for direct marketing purposes, you shall have the right to object at any time to processing of data concerning you. In this case, we will cease the processing of your data for marketing purposes immediately.

 

Withdrawal of consent

 

You have the right to withdraw your consent to process your data (where such processing is based on Art 6 para 1 lit a GDPR) at any time. This does not affect the lawfulness of the data processing carried out up to this point.

 

Complaint

 

You have the right to lodge a complaint with the supervisory authority, if you believe that the processing of your data violates data protection law or your rights to protection of your data have been infringed. In Austria, this is the Austrian Data Protection Authority (Österreichische Datenschutzbehörde).

Since the protection of your personal data (“data“) is of particular concern to us, we process your data exclusively on the basis of the applicable legal provisions. In this Privacy Policy, we inform you in accordance with Art 13 and 14 of the UK GDPR (as retained in UK law by the Data Protection Act 2018) about how we, as the data controller, process your data in connection with the provision of our Services and our websites www.valutico.com and www.done-diligence.com (“website“). Unless otherwise defined in this Privacy Policy, the definitions in our General Terms of Service or GTS or specific product terms will apply here.

 

This Privacy Policy is directed to (i) our customers (“Customers“), and (ii) other users of our services as well as website visitors (“Users”; in particular employees of our Customers or other interested parties). Unless the following expressly refers to Customers or Users, the provisions of this Privacy Policy are addressed to both Users and Customers (collectively referred to as “you“, “your“).

 

  1. The controller of your data is:

 

Valutico UK Limited

 CRN: 12185279

85 Great Portland Street

First Floor

London

W1W 7LT

(“we“, “us“)

info@valutico.com

 

  1. How do we process your data?

 

  1. Business relationship with Customers

 

We process data of our Customers (in particular contact data, billing data) to fulfill our obligations arising from the contractual relationship with the Customers, namely the provision of services to Customers and Users, in particular SaaS solutions with regard to business valuation (Art 6 para 1 lit b UK GDPR). We further process Customers’ data to fulfill legal obligations (e.g. tax obligations; Art 6 para 1 lit c UK GDPR) and/or to protect legitimate interests, unless the interests of the Customers in the confidentiality of their data prevail (Art 6 para 1 lit f UK GDPR).

 

  1. Registration / Provision of Services

 

Our Services are generally offered via our website (SaaS, web applications). If no login is required, only data according to 2.d) is processed.

 

If Services are accessible via user accounts subject to your prior login, your name, email address and passwords are processed. Additionally, within the user account also other data such as your contact information as well as information regarding the valuation reports or regarding other queries performed within the service is processed.

 

The aforementioned data is processed for the purpose of operating and providing our Services.

 

As regards Customers, the processing of data in the context of registration for a user account or the provision of services is based on Art 6 para 1 lit b UK GDPR.

 

As regards Users, the processing of data in the context of registration for a user account or the provision of services is based on our legitimate interest pursuant to Art 6 para 1 lit f UK GDPR to fulfill the contract with our Customers and to grant Users access to our Services.

 

  1. Estimate

 

If you use our service Estimate, available at https://my.valutico.com, you may generate limited business valuation reports. In this case, your contact details will be obtained so that the valuation report can be sent to you by email.

 

With your consent, the valuation  report will also be sent to experts in the field of business valuation (e.g. tax and business advisors) and you agree to potentially be contacted by them (by email or phone) and be presented an offer for further consulting services by them. You can withdraw your consent that your data may be shared with experts at any time for effect in the future by sending an email to customer-success@valutico.com.

 

The data processing for the creation of the report and sending to you is based on the performance of the contract pursuant to Art 6 para 1 lit b UK GDPR. The transfer of your contact data to experts is based on your explicit consent according to Art 6 para 1 lit a UK GDPR.

 

  1. Cookies and Tracking

 

In the course of using our services and or visiting our website, we collect the following data from you, in particular for the purposes of quality assurance and further development of our services and website: date, time and duration of use of the services / website, IP address, system data on the device and operation system used as well as data with regard to your browsing behavior and search operations conducted. We collect this data automatically with cookies and tracking tools provided by third-party providers on the basis your consent pursuant to Art 6 para 1 lit a UK GDPR (or in connection with Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) (PECR) in the case of so-called “persistent” cookies, which are stored on your end device).

 

You can reject the storage of individual cookies or the use of tracking tools (via configuration in the cookie banner) or revoke the storage or use of tracking tools in the browser settings at a later time. When cookies are stored or tracking tools are used on the basis of your voluntary consent, your data is sometimes transmitted to recipients in third countries outside the EEA, in particular to the USA. The USA has not been certified by the European Court of Justice as having an adequate level of data protection; in particular, there is a risk that data may be viewed by US authorities for control and monitoring purposes. By giving your consent, you agree that cookies and tracking tools from third-party providers in the USA or from other insecure third countries may be used and accept a possible lower level of data protection (Art 49 para 1 lit a UK GDPR).

 

Cookies that are absolutely necessary for the structure or functioning of our services or website (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest pursuant to Art 6 para 1 lit f UK GDPR to be able to provide the services and the website in a correspondingly functional manner.

 

  1. Contact / Request

 

When you contact us via email or through other contact options offered, the data provided by you will be processed in order to handle and respond to the respective request, in particular: name, email or phone number, any data provided in the text or conversation.

 

We process data to administrate the Customers’ contact requests in the context of (pre)contractual relationships pursuant to Art 6 para 1 lit b UK GDPR.

 

We process data to administrate the Users’ contact requests in the context of our legitimate interest to provide User support and to fulfill our contracts with Customers according to Art 6 para 1 lit f UK GDPR.

 

  1. Newsletter

 

If you subscribe to our newsletter, we process the data you voluntarily provide, in particular your name and email address, in order to send you up-to-date information on our products, events and other relevant news at regular intervals.

 

The data processing is based on your explicit consent according to Art 6 para 1 lit a UK GDPR in connection with Regulation 22 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) (PECR). You can withdraw your consent at any time with effect for the future (by email to customer-success@valutico.com) or via the “unsubscribe button” in the respective newsletter email. Your data will be stored until your valid withdrawal.

 

  1. Testimonials

 

If you give us your explicit consent, we will process your name and if possible your photo in the context of evaluations of our company (testimonials) and publish them on our homepage, in (print) publications and on other social media sites.

 

You are aware that such information can be accessed on the internet by any person. Despite all technical precautions, it cannot be ruled out that such persons may use this information or pass it on to other persons.

 

You can withdraw your consent to the use of your testimonial at any time by e-mail to customer-success@valutico.com with effect for the future.

 

  1. Interaction Metadata for AI Features

When you use our AI Features (including DoneDiligence), we collect, use and analyse Interaction Metadata to train, develop or improve the AI Features or other aspects of our Services.

“Interaction Metadata” means anonymised and aggregated data regarding how Users interact with the AI Features, which may include:

(a) navigation patterns (such as clicks, page views, and feature usage);

(b) questionnaire structures and templates (but not the specific content or data entered);

(c) query types and categories (but not the actual queries or their results);

(d) selection of valuation methods, peers, or analytical approaches; and

(e) usage frequency and timing patterns.

We ensure that any Interaction Metadata:

(a) is de-identified so that it does not identify you, your organization, or any other person;

(b) is aggregated with data across multiple customers;

(c) excludes any queries, patterns or data points that are unique to you or any specific User; and

(d) does not contain, reflect or enable the reconstruction of any Customer Data, Inputs or Outputs.

Interaction Metadata, as processed in accordance with the safeguards above, does not constitute Customer Data or Confidential Information.

The processing of Interaction Metadata is based on our legitimate interest pursuant to Art 6 para 1 lit f UK GDPR to improve and develop our Services and AI Features for the benefit of all Users.

 

  1. Storage Duration

 

  1. Users

 

If Users have created an account with one of our services, we generally store User data for the duration of the Users’ active account, unless there are mandatory provisions for the further retention of certain data or for our defense of legal claims.

 

If, in addition, User data is processed on the basis of the Users’ consent, we store User data until the Users withdraws their consent.

 

Cookies that are stored on the Users’ end device are stored for a maximum period of 14 months.

 

  1. Customers

 

We store data within the scope of business relationships with Customers for the duration of the active contractual relationships as well as beyond that in accordance with applicable UK statutory retention and documentation obligations (including under the Companies Act 2006, the Limitation Act 1980, and HM Revenue & Customs requirements). Further storage of Customers’ data is possible in particular for the defense of our legal claims.

 

  1. Who will your data be shared with?

 

Your data will be communicated to the following recipients in the course of processing for the above purposes:

 

  • Service providers (in particular IT providers)
  • Company subsidiaries, insofar as necessary for the provision of our services
  • Experts in the field of business valuation when using Estimate product (only upon your consent)
  • Banks, tax consultants, auditors for our internal accounting and financial processes
  • In case of occasion to legal representatives, notaries, courts and administrative authorities

 

  1. Transfer to third countries

 

If the above-mentioned recipients of your data are located outside the EEA and the country in question has not been determined by decision of the EU Commission to have an adequate level of data protection, we will ensure that the transfer is made on the basis of standard contractual clauses or otherwise in accordance with Art 46, 47 or 49 of the UK GDPR.

 

  1. What rights do you have?

 

Right to information

 

As long as we process your data, you have the right to information about the purposes of processing, the categories of data, the origin and the recipients of your data and the duration of storage.

 

Rectification and erasure of data

 

If we process inaccurate or incomplete data, you have the right to rectification of such data. If your data is processed unlawfully, you may also request us to erase your data. You may also request the erasure of your data if your data is processed unlawfully, subject to legal obligations preventing the erasure of your data.

 

Limitation of processing

 

You may request us to limit the processing of your data in certain cases.

 

Data portability

 

You have the right to receive the data, which you have provided to us, in a structured, commonly used and machine-readable format. You have the right to direct transmission of those data to another controller as far as this is technically feasible.

 

Right to object

 

You have the right to object, on grounds relating to your particular situation, at any time to processing of data concerning you. If you object to processing of your data, we shall cease to process this data unless our legitimate interests to processing your data prevail. Where data are processed for direct marketing purposes, you shall have the right to object at any time to processing of data concerning you. In this case, we will cease the processing of your data for marketing purposes immediately.

 

Withdrawal of consent

 

You have the right to withdraw your consent to process your data (where such processing is based on Art 6 para 1 lit a UK GDPR) at any time. This does not affect the lawfulness of the data processing carried out up to this point.

 

Complaint

 

You have the right to lodge a complaint with the supervisory authority, if you believe that the processing of your data violates data protection law or your rights to protection of your data have been infringed. In the UK, this is the Information Commissioner’s Office (ICO).

Since the protection of your personal data (“data“) is of particular concern to us, we process your data exclusively on the basis of the applicable legal provisions. In this Privacy Policy, we inform you in accordance with Personal Data Protection Act 2012 (“PDPA”) about how we, as the data controller, process your data in connection with the provision of our Services and our websites our websites www.valutico.com and www.done-diligence.com (“website“). Unless otherwise defined in this Privacy Policy, the definitions in our General Terms of Service or GTS or specific product terms will apply here.

 

This Privacy Policy is directed to (i) our customers (“Customers“), and (ii) other users of our services as well as website visitors (“Users”; in particular employees of our Customers or other interested parties). Unless the following expressly refers to Customers or Users, the provisions of this Privacy Policy are addressed to both Users and Customers (collectively referred to as “you“, “your“).

 

  1. The controller of your data is:

 

Valutico SG Pte. Ltd.

 UEN: 202318880G

90 EU TONG SEN STREET

#03-02B

SINGAPORE (059811)

(“we“, “us“)

info@valutico.com

 

  1. How do we process your data?

 

  1. Business relationship with Customers

 

We process data of our Customers (in particular contact data, billing data) to fulfill our obligations arising from the contractual relationship with the Customers, namely the provision of Services to Customers and Users, in particular SaaS solutions with regard to business valuation based on the performance of a contract under the Second Schedule of the PDPA. We further process Customers’ data to fulfill legal obligations (e.g. tax obligations; legal obligation exception under the Second Schedule of the PDPA) and/or to protect legitimate interests, unless the interests of the Customers in the confidentiality of their data prevail (legitimate interests exception under the Second Schedule of the PDPA).

 

  1. Registration / Provision of Services

 

Our Services are generally offered via our website (SaaS, web applications). If no login is required, only data according to 2.d) is processed.

 

If Services are accessible via user accounts subject to your prior login, your name, email address and passwords are processed. Additionally, within the user account also other data such as your contact information as well as information regarding the valuation reports or regarding other queries performed within the service is processed.

 

The aforementioned data is processed for the purpose of operating and providing our Services.

 

As regards Customers, the processing of data in the context of registration for a user account or the provision of services is based on the performance of a contract under the Second Schedule of the PDPA.

 

As regards Users, the processing of data in the context of registration for a user account or the provision of Services is based on our legitimate interest under the Second Schedule of the PDPA to fulfill the contract with our Customers and to grant Users access to our Services.

 

  1. Estimate

 

If you use our service Estimate, available at https://my.valutico.com, you may generate limited business valuation reports. In this case, your contact details will be obtained so that the valuation report can be sent to you by email.

 

With your consent, the valuation  report will also be sent to experts in the field of business valuation (e.g. tax and business advisors) and you agree to potentially be contacted by them (by email or phone) and be presented an offer for further consulting services by them. You can withdraw your consent that your data may be shared with experts at any time for effect in the future by sending an email to customer-success@valutico.com.

 

The data processing for the creation of the report and sending to you is based on the performance of the contract under the Second Schedule of the PDPA. The transfer of your contact data to experts is based on your consent pursuant to Section 13 of the PDPA.

 

  1. Cookies and Tracking

 

In the course of using our services and or visiting our website, we collect the following data from you, in particular for the purposes of quality assurance and further development of our services and website: date, time and duration of use of the services / website, IP address, system data on the device and operation system used as well as data with regard to your browsing behavior and search operations conducted. We collect this data automatically with cookies and tracking tools provided by third-party providers on the basis your consent pursuant to Section 13 of the PDPA.

 

You can reject the storage of individual cookies or the use of tracking tools (via configuration in the cookie banner) or revoke the storage or use of tracking tools in the browser settings at a later time. When cookies are stored or tracking tools are used on the basis of your voluntary consent, your data is sometimes transmitted to recipients in third countries outside Singapore, in particular to the USA. By giving your consent, you acknowledge

that data may be transferred to countries that may not provide a comparable standard of data protection as Singapore, and you consent to such transfer in accordance with Section 26 of the PDPA.

 

Cookies that are absolutely necessary for the structure or functioning of our services or website (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest under the Second Schedule of the PDPA  to be able to provide the services and the website in a correspondingly functional manner.

 

  1. Contact / Request

 

When you contact us via email or through other contact options offered, the data provided by you will be processed in order to handle and respond to the respective request, in particular: name, email or phone number, any data provided in the text or conversation.

 

We process data to administrate the Customers’ contact requests in the context of (pre)contractual relationships based on the performance of a contract under the Second Schedule of the PDPA.

 

We process data to administrate the Users’ contact requests in the context of our legitimate interest to provide User support and to fulfill our contracts with Customers under the Second Schedule of the PDPA. 

 

  1. Newsletter

 

If you subscribe to our newsletter, we process the data you voluntarily provide, in particular your name and email address, in order to send you up-to-date information on our products, events and other relevant news at regular intervals.

 

The data processing is based on your consent pursuant to Section 13 of the PDPA  and the Spam Control Act 2007. You can withdraw your consent at any time with effect for the future (by email to customer-success@valutico.com) or via the “unsubscribe button” in the respective newsletter email. Your data will be stored until your valid withdrawal.

 

  1. Testimonials

 

If you give us your explicit consent, we will process your name and if possible your photo in the context of evaluations of our company (testimonials) and publish them on our homepage, in (print) publications and on other social media sites.

 

You are aware that such information can be accessed on the internet by any person. Despite all technical precautions, it cannot be ruled out that such persons may use this information or pass it on to other persons.

 

You can withdraw your consent to the use of your testimonial at any time by e-mail to customer-success@valutico.com with effect for the future.

 

  1. Interaction Metadata for AI Features

When you use our AI Features (including DoneDiligence), we collect, use and analyse Interaction Metadata to train, develop or improve the AI Features or other aspects of our Services.

“Interaction Metadata” means anonymised and aggregated data regarding how Users interact with the AI Features, which may include:

(a) navigation patterns (such as clicks, page views, and feature usage);

(b) questionnaire structures and templates (but not the specific content or data entered);

(c) query types and categories (but not the actual queries or their results);

(d) selection of valuation methods, peers, or analytical approaches; and

(e) usage frequency and timing patterns.

We ensure that any Interaction Metadata:

(a) is de-identified so that it does not identify you, your organization, or any other person;

(b) is aggregated with data across multiple customers;

(c) excludes any queries, patterns or data points that are unique to you or any specific User; and

(d) does not contain, reflect or enable the reconstruction of any Customer Data, Inputs or Outputs.

Interaction Metadata, as processed in accordance with the safeguards above, does not constitute Customer Data or Confidential Information.

To the extent that any personal data (within the meaning of the PDPA) is processed during the intermediate steps of generating Interaction Metadata before de-identification and aggregation are complete, such processing is carried out on the basis of our legitimate interests, pursuant to paragraph 1, Part 3 of the First Schedule to the PDPA (as amended by the Personal Data Protection (Amendment) Act 2020), in improving and developing our Services and AI Features for the benefit of all Users.

  1. Storage Duration

 

  1. Users

 

If Users have created an account with one of our services, we generally store User data for the duration of the Users’ active account, unless there are mandatory provisions for the further retention of certain data or for our defense of legal claims.

 

If, in addition, User data is processed on the basis of the Users’ consent, we store User data until the Users withdraws their consent.

 

Cookies that are stored on the Users’ end device are stored for a maximum period of 14 months.

 

  1. Customers

 

We store data within the scope of business relationships with Customers for the duration of the active contractual relationships as well as beyond that in accordance with the statutory retention and documentation obligations (e.g. in accordance with the Singapore Companies Act and the Income Tax Act). Further storage of Customers’ data is possible in particular for the defense of our legal claims.

 

  1. Who will your data be shared with?

 

Your data will be communicated to the following recipients in the course of processing for the above purposes:

 

  • Service providers (in particular IT providers)
  • Company subsidiaries, insofar as necessary for the provision of our services
  • Experts in the field of business valuation when using Estimate product (only upon your consent)
  • Banks, tax consultants, auditors for our internal accounting and financial processes
  • In case of occasion to legal representatives, notaries, courts and administrative authorities

 

  1. Transfer to third countries

 

If the above-mentioned recipients of your data are located outside Singapore, we will ensure that the transfer complies with Section 26 of the PDPA, which requires that we take reasonable steps to ensure that the overseas recipient is bound by legally enforceable obligations to provide a standard of protection to the personal data that is comparable to the protection under the PDPA.

 

  1. What rights do you have?

 

Right to information

 

As long as we process your data, you have the right to information about the purposes of processing, the categories of data, the origin and the recipients of your data and the duration of storage.

 

Rectification and erasure of data

 

If we process inaccurate or incomplete data, you have the right to rectification of such data. If your data is processed unlawfully, you may also request us to erase your data. You may also request the erasure of your data if your data is processed unlawfully, subject to legal obligations preventing the erasure of your data.

 

Limitation of processing

 

You may request us to limit the processing of your data in certain cases.

 

Data portability

 

You have the right to receive the data, which you have provided to us, in a structured, commonly used and machine-readable format. You have the right to direct transmission of those data to another controller as far as this is technically feasible.

 

Right to object

 

You have the right to object, on grounds relating to your particular situation, at any time to processing of data concerning you. If you object to processing of your data, we shall cease to process this data unless our legitimate interests to processing your data prevail. Where data are processed for direct marketing purposes, you shall have the right to object at any time to processing of data concerning you. In this case, we will cease the processing of your data for marketing purposes immediately.

 

Withdrawal of consent

 

You have the right to withdraw your consent to process your data (where such processing is based on your consent under the PDPA) at any time. This does not affect the lawfulness of the data processing carried out up to this point.

 

Complaint

 

You have the right to lodge a complaint with the supervisory authority, if you believe that the processing of your data violates data protection law or your rights to protection of your data have been infringed. In Singapore, this is the Personal Data Protection Commission (PDPC).

Since the protection of your personal data (“data“) is of particular concern to us, we process your data exclusively on the basis of the applicable legal provisions. In this Privacy Policy, we inform you in accordance with Art 13 and 14 of the General Data Protection Regulation (“GDPR“) about how we, as the data controller, process your data in connection with the provision of our Services and our websites www.valutico.com and www.done-diligence.com(“website“). Unless otherwise defined in this Privacy Policy, the definitions in our General Terms of Service or GTS or specific product terms will apply here.

 

This Privacy Policy is directed to (i) our customers (“Customers“), and (ii) other users of our services as well as website visitors (“Users”; in particular employees of our Customers or other interested parties). Unless the following expressly refers to Customers or Users, the provisions of this Privacy Policy are addressed to both Users and Customers (collectively referred to as “you“, “your“).

 

  1. The controller of your data is:

 

 Valutico, Inc.

2035 Sunset Lake Road, Suite B-2

Newark, DE 19702, USA

(“we“, “us“)

info@valutico.com

 

  1. How do we process your data?

 

  1. Business relationship with Customers

 

We process data of our Customers (in particular contact data, billing data) to fulfill our obligations arising from the contractual relationship with the Customers, namely the provision of services to Customers and Users, in particular SaaS solutions with regard to business valuation (Art 6 para 1 lit b GDPR). We further process Customers’ data to fulfill legal obligations (e.g. tax obligations; Art 6 para 1 lit c GDPR) and/or to protect legitimate interests, unless the interests of the Customers in the confidentiality of their data prevail (Art 6 para 1 lit f GDPR).

 

  1. Registration / Provision of Services

 

Our Services are generally offered via our website (SaaS, web applications). If no login is required, only data according to 2.d) is processed.

 

If Services are accessible via user accounts subject to your prior login, your name, email address and passwords are processed. Additionally, within the user account also other data such as your contact information as well as information regarding the valuation reports or regarding other queries performed within the service is processed.

 

The aforementioned data is processed for the purpose of operating and providing our Services.

 

As regards Customers, the processing of data in the context of registration for a user account or the provision of services is based on Art 6 para 1 lit b GDPR.

 

As regards Users, the processing of data in the context of registration for a user account or the provision of services is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to fulfill the contract with our Customers and to grant Users access to our services.

 

  1. Estimate

 

If you use our service Estimate available at https://my.valutico.com, you may generate limited business valuation reports. In this case, your contact details will be obtained so that the valuation report can be sent to you by email.

 

With your consent, the valuation  report will also be sent to experts in the field of business valuation (e.g. tax and business advisors) and you agree to potentially be contacted by them (by email or phone) and be presented an offer for further consulting services by them. You can withdraw your consent that your data may be shared with experts at any time for effect in the future by sending an email to customer-success@valutico.com.

 

The data processing for the creation of the report and sending to you is based on the performance of the contract pursuant to Art 6 para 1 lit b GDPR. The transfer of your contact data to experts is based on your explicit consent according to Art 6 para 1 lit a GDPR.

 

  1. Cookies and Tracking

 

In the course of using our services and or visiting our website, we collect the following data from you, in particular for the purposes of quality assurance and further development of our services and website: date, time and duration of use of the services / website, IP address, system data on the device and operation system used as well as data with regard to your browsing behavior and search operations conducted. We collect this data automatically with cookies and tracking tools provided by third-party providers on the basis of your consent pursuant to Art 6 para 1 lit a GDPR (or in connection with applicable US state privacy laws, including the California Consumer Privacy Act (CCPA) where applicable, in the case of so-called “persistent” cookies, which are stored on your end device).

 

You can reject the storage of individual cookies or the use of tracking tools (via configuration in the cookie banner) or revoke the storage or use of tracking tools in the browser settings at a later time. When cookies are stored or tracking tools are used on the basis of your voluntary consent, your data is sometimes transmitted to recipients in third countries outside the EEA, in particular to the USA. The USA has not been certified by the European Court of Justice as having an adequate level of data protection; in particular, there is a risk that data may be viewed by US authorities for control and monitoring purposes. By giving your consent, you agree that cookies and tracking tools from third-party providers in the USA or from other insecure third countries may be used and accept a possible lower level of data protection (Art 49 para 1 lit a GDPR).

 

Cookies that are absolutely necessary for the structure or functioning of our services or website (technically necessary cookies) cannot be deactivated. In these cases, the data processing is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to be able to provide the services and the website in a correspondingly functional manner.

 

  1. Contact / Request

 

When you contact us via email or through other contact options offered, the data provided by you will be processed in order to handle and respond to the respective request, in particular: name, email or phone number, any data provided in the text or conversation.

 

We process data to administrate the Customers’ contact requests in the context of (pre)contractual relationships pursuant to Art 6 para 1 lit b GDPR.

 

We process data to administrate the Users’ contact requests in the context of our legitimate interest to provide User support and to fulfill our contracts with Customers according to Art 6 para 1 lit f GDPR.

 

  1. Newsletter

 

If you subscribe to our newsletter, we process the data you voluntarily provide, in particular your name and email address, in order to send you up-to-date information on our products, events and other relevant news at regular intervals.

 

The data processing is based on your explicit consent according to Art 6 para 1 lit a GDPR and, where applicable, in compliance with the CAN-SPAM Act and applicable US state laws governing electronic marketing communications. You can withdraw your consent at any time with effect for the future (by email to customer-success@valutico.com) or via the “unsubscribe button” in the respective newsletter email. Your data will be stored until your valid withdrawal.

 

  1. Testimonials

 

If you give us your explicit consent, we will process your name and if possible your photo in the context of evaluations of our company (testimonials) and publish them on our homepage, in (print) publications and on other social media sites.

 

You are aware that such information can be accessed on the internet by any person. Despite all technical precautions, it cannot be ruled out that such persons may use this information or pass it on to other persons.

 

You can withdraw your consent to the use of your testimonial at any time by e-mail to customer-success@valutico.com with effect for the future.

 

  1. Interaction Metadata for AI Features

When you use our AI Features (including DoneDiligence), we collect, use and analyse Interaction Metadata to train, develop or improve the AI Features or other aspects of our Services.

“Interaction Metadata” means anonymised and aggregated data regarding how Users interact with the AI Features, which may include:

(a) navigation patterns (such as clicks, page views, and feature usage);

(b) questionnaire structures and templates (but not the specific content or data entered);

(c) query types and categories (but not the actual queries or their results);

(d) selection of valuation methods, peers, or analytical approaches; and

(e) usage frequency and timing patterns.

We ensure that any Interaction Metadata:

(a) is de-identified so that it does not identify you, your organization, or any other person;

(b) is aggregated with data across multiple customers;

(c) excludes any queries, patterns or data points that are unique to you or any specific User; and

(d) does not contain, reflect or enable the reconstruction of any Customer Data, Inputs or Outputs.

Interaction Metadata, as processed in accordance with the safeguards above, does not constitute Customer Data or Confidential Information.

The processing of Interaction Metadata is based on our legitimate interest pursuant to Art 6 para 1 lit f GDPR to improve and develop our Services and AI Features for the benefit of all Users.

 

  1. Storage Duration

 

  1. Users

 

If Users have created an account with one of our services, we generally store User data for the duration of the Users’ active account, unless there are mandatory provisions for the further retention of certain data or for our defense of legal claims.

 

If, in addition, User data is processed on the basis of the Users’ consent, we store User data until the Users withdraws their consent.

 

Cookies that are stored on the Users’ end device are stored for a maximum period of 14 months.

 

  1. Customers

 

We store data within the scope of business relationships with Customers for the duration of the active contractual relationships as well as beyond that in accordance with the statutory retention and documentation obligations (e.g. in accordance with applicable US federal and state retention and documentation obligations, including IRS recordkeeping requirements and applicable US commercial and tax laws). Further storage of Customers’ data is possible in particular for the defense of our legal claims.

 

  1. Who will your data be shared with?

 

Your data will be communicated to the following recipients in the course of processing for the above purposes:

 

  • Service providers (in particular IT providers)
  • Company subsidiaries, insofar as necessary for the provision of our services
  • Experts in the field of business valuation when using Estimate product (only upon your consent)
  • Banks, tax consultants, auditors for our internal accounting and financial processes
  • In case of occasion to legal representatives, notaries, courts and administrative authorities

 

  1. Transfer to third countries

 

If the above-mentioned recipients of your data are located outside the EEA and the country in question has not been determined by decision of the EU Commission to have an adequate level of data protection, we will ensure that the transfer is made on the basis of standard contractual clauses or otherwise in accordance with Art 46, 47 or 49 of the GDPR.

 

  1. What rights do you have?

 

Right to information

 

As long as we process your data, you have the right to information about the purposes of processing, the categories of data, the origin and the recipients of your data and the duration of storage.

 

Rectification and erasure of data

 

If we process inaccurate or incomplete data, you have the right to rectification of such data. If your data is processed unlawfully, you may also request us to erase your data. You may also request the erasure of your data if your data is processed unlawfully, subject to legal obligations preventing the erasure of your data.

 

Limitation of processing

 

You may request us to limit the processing of your data in certain cases.

 

Data portability

 

You have the right to receive the data, which you have provided to us, in a structured, commonly used and machine-readable format. You have the right to direct transmission of those data to another controller as far as this is technically feasible.

 

Right to object

 

You have the right to object, on grounds relating to your particular situation, at any time to processing of data concerning you. If you object to processing of your data, we shall cease to process this data unless our legitimate interests to processing your data prevail. Where data are processed for direct marketing purposes, you shall have the right to object at any time to processing of data concerning you. In this case, we will cease the processing of your data for marketing purposes immediately.

 

Withdrawal of consent

 

You have the right to withdraw your consent to process your data (where such processing is based on Art 6 para 1 lit a GDPR) at any time. This does not affect the lawfulness of the data processing carried out up to this point.

 

Complaint

 

You have the right to lodge a complaint with the supervisory authority, if you believe that the processing of your data violates data protection law or your rights to protection of your data have been infringed. In the United States, you may lodge a complaint with the Federal Trade Commission (FTC) at www.ftc.gov. If you are a California resident, you may also contact the California Privacy Protection Agency (CPPA) at www.cppa.ca.gov. Other applicable state privacy authorities may also have jurisdiction depending on your state of residence.