Perla Website Privacy Policy

1. What is this document and why should you read it?

This privacy notice explains how and why Perla, Inc. (also referred to as “Perla”, “we”, “our” and “us”) uses personal data about individual users of our website www.goperla.com (the “Website”) and those that access our services through APIs and through third-parties, including website users, buyers and/or Advisors (whether prospective, current or past) (together, “you”).

You should read this notice so that you know what we are doing with your personal data.

2. Our data protection responsibilities

“Personal data” is any information that relates to an identifiable natural person. Your name, address and contact details are examples of your personal data, if they identify you.

The term “process” means any activity relating to personal data, including collection, storage, use and transmission.

Whether you are a buyer, a professional or just a website user (or a combination of those) Perla is a “controller” of your personal data. This means that we make decisions about how and why we process your personal data and are responsible for making sure it is used in accordance with data protection laws.

3. What types of personal data do we collect and where do we get it from?

If you are reviewing this then you will fall into at least one of the following categories of individuals about whom we process personal data:

(a) prospective, current or past customers of Perla who register an account and/or place a buyer request (also known as a “match request”) (“Buyers”);

(b) current or past individuals who register as an Advisor on Perla to provide a service to Buyers, (“Advisors”); and/or

Accordingly, we will collect and process different types of personal data about you depending on which of these categories are relevant to you. The different types of personal data that we collect and the sources we collect it from are summarized below.

4. Personal Data Categories

Depending on how you use our Website and services, we will collect different types of personal data about you. For example, this might include things like your name, contact details, details about your business, our correspondence with you, records of your transactions with us, and how you use our services. We need these details to provide our services to you. We have set out more specific details on the categories of personal data we collect and process on Buyers, Advisors and Website Users in Table 1.

We obtain this personal data from a number of different sources. For example, this could be from you, our Website, your business website as well as third party sources such as social media. More details of the sources from which we obtain personal data about on Buyers, Advisors, and Website Users can be found in Table 1.

Table 1

Category	Types of Personal Data	Collected from
Buyers	Basic Data Communication Data Lead Data Website Data Geolocation Data Analytics Data	You Our Website (including any cookies) Your device Third party sources, including social media, search engines, online maps, online marketplaces, online customer review sites and directories
Advisors	Basic Data Communication Data Account Data Professional Data Website Data Geolocation Data Analytics Data	You LinkedIn Your employer Our Website Your device Your website Third party sources, including social media, search engines, online maps, online marketplaces, online customer review sites and directories
Website Users	Basic Data Communication Data Website Data Geolocation Data Analytics Data	You Our Website (including any cookies) Your device

5. How we use personal data and why?

We process your personal data for particular purposes, which are relevant to your relationship and engagement with us. We are required by law to always have a “lawful basis” for processing your personal data.

We use the personal data we collect for a number of different reasons, including to provide our services to you or with you, to communicate with you, to verify your identity, to make sure our website and services are functioning properly and provide the best services for you, to keep accurate records and for legal reasons.

We rely on a number of different lawful grounds or ‘bases’ in order to process your personal data. These include that we have your consent to the processing, we need to process your personal data to enter into or perform a contract with you, we need to process your personal data to comply with our legal obligations, and/or the processing is necessary for our legitimate interests (or the legitimate interests of a third party).

More details on the purposes for which we process personal data on Buyers, Advisors and Website Users, and the lawful bases we rely on, can be found In Table 2.

Table 2

Purposes of processing	Your consent	Contract performance	Legitimate interests (user or a third party)
	Lawful basis
a) Corresponding with you, responding to your requests, enquiries and/or complaints			(to respond to you in relation to such matters)
b) Confirming and processing leads that you may make with us			(to process your orders)
c) Confirming and processing credit purchases that you may make with us			(to process your orders)
d) Sending you service information (including direct marketing)	(direct marketing)	(service updates)	(to keep you updated on requests with other helpful updates and direct marketing in other cases)
Background and Identity Check Information
e) Performing ID, background and verification checks			(to ensure that the contacts details of Buyer/Professionals are verified)
Website Information
f) Ensure and improve the operation and performance of the Website			(to ensure the Website functions correctly and improve its functionality for the benefit of Website users)
g) To identify your approximate geographical location			(to provide relevant services to you and to optimize your experience)
h) To monitor and analyze use of our services			(to provide relevant services to you and to optimize your experience)
i) To facilitate set up and use of your account			(to grant you access to your account where you can securely and easily access information relevant to you)
Buyers and Professionals
j) To deal with your request for a service			(to fulfill our contractual obligation where you represent your employer or organization)
k) To recommend suggested searches to you			(to encourage you to use our services)
l) To understand and analyze how users engage with and use our services			(to personalize and improve your experience and to better understand your needs and interests)
m) To take payment from you or the business you represent or to receive services from you or the business you represent, to deal with any complaints			(to perform the contract where you represent your employer or organization)
n) To share feedback and statistics on Professionals with potential Buyers			(to provide guidance for potential Buyers selecting Professionals)
o) To enable Professionals to provide their services through our website and otherwise to Buyers who have submitted leads to us			(to enable Professionals to provide their services)
p) To onboard you as a Buyer and/or Professional (which may also include background and verification checks as referred to above)			(to be able to offer you services and, where applicable, enter into a contract where you represent your employer or organization)
All categories
q) Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity			(to protect our business, other buyers and the public from fraud and crime, and to enable us to deal with legal claims)
r) Complying with requests, orders and instructions from law enforcement agencies, regulators, any court, parties to proceedings or otherwise deal with obligations required by law or regulators and to ensure good governance and compliance			(where not binding but good governance and in the public interest)
s) For our general record-keeping and relationship management			(where you represent your employer or organization)
t) To keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws
u) Managing the proposed sale, restructuring or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organization			(to sell any part of our business)
v) Resolving any complaints from or disputes with you			(to try and resolve any complaint or dispute you might raise with us and to deal with legal claims)

It is important that you are aware that we have indicated that our processing of your personal data is either (i) necessary for us to comply with a legal obligation; or (ii) necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it, and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract with you or the provision of our services.

We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymized data cannot be linked back to you. We may use it to conduct research and analysis, including to produce statistical research and reports. For example, to help us understand and improve the use of our Website.

6. Who do we share your personal data with and why?

We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve our services (including but not limited to Buyer/Professional verification, data storage, maintenance services, database management, web analytics, payment processing, and improvement of our services). These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions necessary functions.

We may also share your information with third parties, who then use your personal data for their own purposes. For example, to process payments from you or where you choose to access our services through such an application. These organizations will also use your personal data for their own, separate purposes (also as a “controller”) – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.

In certain circumstances, where necessary for the purposes set out in Table 3 below, we will also disclose your personal data to:

(a) consultants and professional advisors including legal advisors, auditors and accountants;

(b) business partners and joint ventures;

(d) insurers;

(e) courts, court-appointed persons/entities, receivers and liquidators;

(f) third parties where necessary to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others;

(g) healthcare association partner you used to access our services; and

(g) to governmental departments, local government, statutory and regulatory bodies.

Table 3 – Data Categories

Category	Types of Personal Data
Basic Data	Basic contact information and identity information
Communication Data	Communications we may have with you or other information which you may voluntarily provide, including images, videos or documents you may upload as part of a Perla request Your contact/marketing preferences
Account Data	Perla profile and details Usernames, passwords and other log-in information Activity history and referral data Analysis we may undertake on account usage from time to time Billing details, including card details and billing address
Perla Data	Your draft, actual and suggested search request(s) and any responses received Feedback on Perla usage for Buyers and feedback, comments and ratings of Professionals/Sellers
Website Data	Information about your device, which may include the device’s IP address, browser type, browsing history, preferences, identification numbers, your mobile carrier, date and time stamps and other interactions with the service Questions raised with us Information you provide us when you visit our Website
Geolocation Data	Your device and/or the information you give us might tell us your approximate geographical location
Analytics Data	Information to monitor and analyze use of our services, for example for our service’s technical administration, to increase our service’s functionality and user-friendliness, and to verify users have the authorization needed to process their requests
Professional Data	Details about the service(s) you or your employer provide Payment records and bank account details Perla profile Perla analysis we may undertake from time to time Account details and activity history User names, passwords and other log-in information

7. Where is your personal data transferred to?

When we share personal data about you, as set out above, this may include a transfer of your personal data to recipients outside the US. If any disclosures of personal data mean that your personal data will be transferred outside the US, we will only make that transfer in accordance with our obligations under applicable data protection laws.

8. How long do we keep your personal data for?

We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which we are processing it for (including as necessary to comply with our legal or regulatory obligations, resolve disputes, and enforce our agreements).

9. What are your rights in relation to your personal data and how can you exercise them?

For California Residents: You Have the Right to Obtain a Copy of Your Personal Information, Access Your Account, or Have Your Personal Information Deleted.

Because many users tend to use our Site and Services on an ongoing basis and/or at different points of their lives, we retain your personal information for continued service and convenience purposes until you advise us not to do so.

However, you have the right to ask Perla for a reasonable description of what personal information we have about you, to access your account, or to have us delete your personal information from our database.

Specifically, you may use the following options to ask Perla to identify for you the personal information it has collected about you and to provide you with a copy of it within a reasonable time after receiving your request. You may also use the following options for accessing your account and for deleting your personal information from our database in keeping with this Privacy Policy.

Perla provides users the following options for accessing your personal information previously collected and used by Perla, accessing your account, or for processing a request to delete your personal information from our database:

Send us an e-mail at privacy@goperla.com and our Perla Customer Service Specialists will be happy to assist you;
For any services where you have an account, you may access your account on our site and change your debit card or credit card (if applicable), e-mail address, password and other information from the account settings or preferences page; or
You can send mail to the postal address listed in the next Section, providing us with your account information and letting us know which personal information you (1) wish to have us identify for you and/or provide you with a copy of, or (2) have deleted from our database.

If we receive a request from you for a description of your personal information or to provide you with a copy of it or delete it, we will (1) verify your request; (2) take reasonably timely steps to provide you with a description or copy of the requested information (if you have requested such a copy), to otherwise provide you with access to your account and personal information (if that is your request), or to delete your personal information from our database (if that is your request); and (3) inform any direct service providers with whom we do business to also delete the requested information.

In the event that you elect to exercise your rights under this Privacy Policy or applicable privacy laws, you will in no way be discriminated against for doing so by Perla; specifically, you will still be entitled to equal services and pricing terms from Perla as our other users.

10. General

We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We also encourage you to check this notice on a regular basis.

If you want more information about any of the subjects covered in this privacy notice or if you would like to discuss any issues or concerns with us, you can contact us at privacy@goperla.com.

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