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.
“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.
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
(c) individuals that access our Website (“Website Users”)
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.
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.
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.
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.
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;
(c) a prospective seller or buyer of our business and their advisors;
(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.
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.
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).
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:
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.
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.