Last updated: September 14th, 2021
Deel, Inc. ("Deel", "us", "we", or "our") operates the www.letsdeel.com website (the “Site”) and provides an international payroll service (the "Service"), which is available through the Site.
While accessing our Site and/or using our Service, we collect and store certain information about you. Some of this information can be used on its own or in combination with other information with other information to identify you ("Personal Information"). Below is a list of types of Personal Information that we may collect and use when you apply for, or use any of our products or services.
|Type of personal information||Description|
|Contact||Your name, addresses, e-mail addresses, phone numbers and other ways in which to contact you|
|Payment||Payment card number, expiration date, security code and billing address.|
|Transactional||Details about the transactions you carry out and the payments to and from your accounts with us|
|Contractual||Details about the products or services we provide to you|
|Locational||Data we get about where you are. This may come from your mobile phone or the place where you connect a computer to the internet. It may also include locations where you used your card.|
|Behavioral||Details about how you use our Services and Site|
|Technical||Details on the devices and technology you use|
|Communications||What we learn about you from communications between us.|
|Public and third-party records||Details about you that are in public records and information about you that is publicly available on the internet. We also collect information about you which we receive from other companies, such as (without limitation) credit reference or fraud protection agencies (see below for more information).|
|Usage data||Other data about how you use our products and services|
|Documentary data||Details about you that are stored in documents in different formats, or copies of them. This could include things like (without limitation) your passport, driver’s licence, photographs or birth certificate.|
|Consents||Any permissions, consents or preferences that you give us|
Where we collect personal information
We may collect personal information about you or your businesses from any of these sources:
- Payment and transaction data
- Profile and usage data (including, without limitation, your security details, app or your website browser settings, marketing choices and data from the devices you use to connect to our Platform so we can provide you with our products or services).
- Companies and business partners that introduce you to us
- Our service partners, such as PSP partners as defined in Deel’s terms
- Our third-party vendors, including (without limitation) those that help us authenticate your identity
- Social networks and other technology providers (for instance, when you click on one of our Facebook or Google adverts)
- Fraud prevention agencies
- Other financial services companies (to fulfil a payment or other service as part of a contract [which they have] with you, or to help prevent, detect and prosecute unlawful acts, money laundering, and fraudulent behaviour)
- Public information sources such as (without limitation) Companies House
- Third-party agents, suppliers, sub-contractors and advisers
- Market researchers
- Firms providing data services
- Government, law enforcement agencies, authorities and regulatory bodies to help Deel comply with its legal obligations;
Below is a list of the ways that we may use your personal information and our reasons for doing so:
|What we use your personal information for||Our reasons|
|Improving our business|
|Marketing and events-related communications|
|Managing our operations|
|Crime prevention and managing risks|
We may contact you with newsletters and other marketing information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional or administrative messages related to the Service even after you have opted out of receiving marketing communications.
Information Sharing with Third Parties
We will only share your information with the third parties listed below for the purposes described above in the “Use of Your Information” Section, unless otherwise noted at the point of collection:
- Third-party agents, partners, and service providers who are only permitted to use your information as we allow which may include contacting you on your behalf, and are required under law or contract to keep your personal information confidential. Information is shared to help us provide the Service.
- Government agencies and taxing authorities, as required to provide the Service, including but not limited to the Internal Revenue Service, state and local tax agencies, and state and federal regulatory agencies.
- Insurance carriers and other third parties, as needed to carry out the Benefits Service
- Banking and financial institutions.
- Certain parties as necessary to respond in good faith to legal process where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
- Legal and financial advisors and auditors
- we may share business or personal information with credit bureaus, and we may share information with certain companies, banks and organizations for purposes such as fraud prevention or determining eligibility for the Service;
- if you participate in a referral program, the referral email and referral link sent to any Referred Leads may include your first name;
- if there is a sale of Deel (including, without limitation, a merger, stock acquisition, sale of assets or reorganization), or in the event that Deel liquidates or dissolves, we may sell, transfer or otherwise share some or all of our assets, which could include your information, to the acquirer;
- we may share de-identified personal information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data;
- from time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics; and
- we may share your information with certain other third parties with whom you, your Client, or your Client’s accountant partner expressly authorize us to share your information
How long we keep your personal information
We will keep your personal information as long as you are a User of Deel.
We may keep your personal information for up to 10 years after you stop being a customer. The reasons we may do this are:
- To respond to a question or complaint, or to show whether we gave you fair treatment
- To study customer data as part of our own research
- To comply with legal rules that apply to us about keeping records. For example, the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 require us to retain certain data for a minimum of 5 and a maximum of 10 years.
- We may also keep your data for longer than 10 years if certain laws mean that we cannot delete it for legal, regulatory or technical reasons.
The security of your Personal Information is important to us. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. You are also a key stakeholder in making sure that your Personal Information is protected. If you become aware of any breach of security or privacy, please contact us immediately.
Link To Other Sites
We do not knowingly collect Personal Information from Children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verifiable parental consent, we will take steps to remove that information from our servers.
California Privacy Rights
This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).
California residents that have an established business relationship with us can request a notice disclosing the categories of Personal Information we have shared with third parties during the preceding calendar year for the third parties’ direct marketing purposes. To make such a request from us, if entitled, please use the contact information listed below.
Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
- Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
- Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place. As described in Advertising, we do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and Service that you do not wish such operators to track certain of your online activities over time and/or across different websites. We do not support Do Not Track requests at this time.
To submit a request to exercise any of the rights described above, you may contact Deel at firstname.lastname@example.org We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.
If you have questions or concerns regarding privacy using our Service, please contact us at: email@example.com
FOR EU RESIDENTS:
We collect, process, use and are responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR) which applies across the European Union and EEA (including in the UK), and the Data Protection Act 2018 (together with the DPA).
For individuals residing in the EU please contact our EU Representative with any requests you may have either by emailing firstname.lastname@example.org or addressing it to the Head of Data Privacy Manager Service, Bouaziz & Partners, 45 Quai de la Seine, 75019, Paris, France.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
When transferring data from the European Union, the European Economic Area, and Switzerland, Deel relies upon a variety of legal mechanisms, including contracts with our Users.
Deel commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Deel is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance — free of charge to you. We ask that you first submit any such complaints directly to us via email@example.com If you aren't satisfied with our response, please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield. In the event your concern still isn't addressed by JAMS, you may be entitled to binding arbitration under Privacy Shield and its principles.
Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, Deel will provide individuals access to personal data about them. Deel also will take reasonable steps to enable individuals to correct, amend, or delete personal data that is demonstrated to be inaccurate.
Deel is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Deel complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
Under applicable EU regulation, as of May 25, 2018 you may have some or all of the following rights in respect of your personal information:
- to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
- to rectify inaccurate personal information;
- to erase your personal information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
- to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim;
- to challenge processing which we have justified on the basis of our legitimate interest;
- to object to decisions which are based solely on automated processing or profiling;
- to obtain a portable copy of your personal information, or to have a copy transferred to a third party controller; or
- to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. You also have the right to withdraw your consent to the processing of your information at any time. We may ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.