Privacy Policy

DualBirdInc., as data controller, ("DualBird","we" or "us") present this privacy policy, as may be amended from time to time (the "Privacy Policy") in order to provide our website visitors ("Visitor(s)", "you"or "your") with information about DualBird’s privacy and data protection practices in relation to Personal Data (as defined below) that is collected, used and/or otherwise processed by DualBird and/or third parties acting on its behalf, through its website www.dualbird.io (the "Website").

Please note that this Privacy Policy supplements our Terms of Use.

If you have questions or concerns regarding this Privacy Policy, please contact us at legal@dualbird.io.

Please see our full Privacy Policy below in order to better understand our practices in detail.

1. Types of Personal Data We Collect and Process

Definition. When we use the term “Personal Data” in this Privacy Policy, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable natural person, particular person, consumer or household.

Collection of PersonalData – General Provisions. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Data when you use the Website and apply for a job position, and the provision of it is solely based on your free will. In particular, when you apply for a job position you agree that DualBird will use it to assess your suitability for the position to which you have applied. You understand that without providing the Personal Data described in this PrivacyPolicy, DualBird may not be able to operate the Website and provide you with its related services, including to the extent applicable, to review your application and provide you with a response regarding your job application. We do not collect, use, or sell Personal Data for the purpose of training large language models.

Personal Data Collection. When you fill in the forms available on the Website and provide us with your Personal Data by email as a result of an opening published on our Website, we collect and process the following categories of Personal Data:

Types of Personal Data	Included Personal Data
Identification data or identifier	full name
Contact details	work email address and phone number
Business data	company name
Personal Data relating to your job application	CV, position you are applying for, current position, training, professional experience, any other information provided in connection with your job application.
Any information you decide to add when you send us a message	Date, hour and subject matter of the request

The provision of certain types of Personal Data may be necessary or optional, depending on your requests. Mandatory data will be marked as such at the moment of collection of your Personal Data. If you refuse to provide mandatory data, DualBird may not be able to process your request (e.g., reply to your contact request).

2. Purposes and EU Legal Basis

We process the Personal Data described in section 1 above for the following purposes:

Purposes	Use of Personal Data	Legal Basis (for EEA Visitors only)
Managing your contact request ('Contact Us' form)	to answer your questions and inquiries to contact you if necessary	Legitimate interest of DualBird in managing contact and demo requests sent to it
Managing your demo request ('Joint Waitlist' form)	to schedule a demonstration of our product with our staff to potentially purchase our product	To take steps at the request of the data subject prior to entering into a contract
Managing your job application	to review and assess your job application to schedule an interview if your application is successful	To take steps at the request of the data subject prior to entering into a contract
Managing any litigation	to take action against any identified security breach, manage any dispute or litigation to seek advice from lawyers, auditors, and other professional advisers	Legitimate interest of DualBird in defending our rights and interests
Complying with legal and regulatory obligations	to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities to process your requests to exercise your rights to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights	Legal obligations to which DualBird is subject

3. With Whom Do We Share Personal Data?

We may share your Personal Data with third parties as detailed below:

Service Providers, including data storage providers, and human resources management platform.	We share Personal Data with selected third-party companies we engage to perform services on our behalf. We only provide such service providers with Personal Data so they can perform their required functions on our behalf.
Governmental, Administrative or Judiciary Authorities	We will disclose or allow government and law enforcement officials access to certain Personal Data, exclusively in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Corporate Transactions	We may share Personal Data in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Lawyers and Interested Parties	We will share Personal Data exclusively in case of the management of possible disputes and other legal matters where appropriate, including with respect to the Website; to establish, protect, or exercise our legal rights; as required to enforce agreements; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights.

Data collected automatically:

In addition to the Personal Data you provide directly to us, we also collect information from you automatically as you use our Website via cookies, pixels, web beacons, and similar tracking technologies. However, if you are located in the EU or UK, these trackers won’t deploy (i.e. collect your information) unless you provide your consent. To the extent the EU or UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you. To the extent the EU or UK data protection laws apply to placement of non-essential cookies on the Website, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by visiting Your Privacy Choices.

We use essential, performance, marketing, and analytics cookies to automatically collect certain internet and other electronic network activity information when you interact with the Website. This includes things like Internet Protocol address (e.g. IP address), location, device type, browser type, browser version, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We use this information to: (i) track you within the Website; (ii) enhance user experience; (iii) conduct analytics to improve the Website; (iv) prevent fraudulent use of the Website; (v) diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse; and (vi) market to you more effectively across different web pages and social media platforms based on your browsing habits and history.

If you are located in the EU or UK, these trackers won’t deploy (i.e. collect your information) unless you provide your consent. In the US, such third-party marketing and analytics cookies may be considered a sale or disclosure for targeted advertising purposes under state data privacy laws. To opt out, please visit Your Privacy Choices. In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent. Please note, if you opt out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out of each browser or device that you use.

Particular third-party analytics/advertising cookies to note on our Website include:

Google Analytics. We use Google Analytics to collect information on your use of the Website for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there (for more information about how Google collects and uses the information see here). Google Analytics also receives information about you from applications you have downloaded or services that you use that partner with Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here. You can also adjust your Ad Settings or change settings in your Google My Activity if you are signed into your Google Account. To opt out, please visit Your Privacy Choices.
HubSpot. We use HubSpot Analytics to recognize and count the number of people who visit our Website, as well as collect information on how users engage and interact with our Website. To collect this information, HubSpot Analytics installs cookies on your browser or reads cookies that are already there. We do not combine the information collected through the use of HubSpot Analytics with personal data. For more information on HubSpot Analytics, please see HubSpot’s Privacy Policy. You can disable cookies through your individual browser settings. Please note that if you disable cookies, some of our Website features may not function properly or at all. To opt out, please visit Your Privacy Choices.

We deidentify and/or aggregate the data we collect and use and share it, in deidentified and/or aggregated form, for benchmarking purposes, advertising, and internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

4. Cross-Border Data Transfers

We store, process, maintain or transfer the Personal Data to various sites worldwide. Where specific laws or regulations relating to Personal Data transfer apply to us, we will endeavor to ensure that the Personal Data is protected and transferred in a manner consistent with legal requirements.

EEA Transfers. When we transfer Personal Data from within the European Economic Area ("EEA") to countries or international organizations that are based outside the EEA, the transfer takes place on the basis of an adequacy decision by the European Commission, or in the absence of an adequacy decision, other legally permitted safeguards under the General Data Protection Regulation (GDPR), such as standard contractual clauses.

Israeli Transfers. When we transfer Personal Data from the State of Israel to a third country outside Israel, the transfer takes place on the basis of a country declared as offering equivalent level of protection by the Israeli Privacy Protection Authority; any another approved transfer mechanism under the Israeli regulations, including consent to transfer your Personal Data to other jurisdictions, understanding that in some countries the level of protection may be lower than in Israel.

5. Data Retention

We retain Personal Data for as long as a Visitor is using our Website and until we have processed Visitor’s request and job application. Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal and regulatory requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

If you have any questions about data retention, please contact us by e-mail at legal@dualbird.io.

6. Data Security

We endeavor to maintain appropriate technical and organizational measures compliant with industry standards to protect Personal Data in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, harm to the integrity, disclosure or use. However, although we make every effort to protect the Personal Data which you provide to us or we generate, we cannot completely ensure the security of any Personal Data you transmit to us over the internet or guarantee that this Personal Data will not be accessed, disclosed, altered, or destroyed.

If you have found a vulnerability or would like to report a security incident, you may send an email at legal@dualbird.io.

7. Your Rights Regarding your Personal Data

General Provisions. Please note that under certain circumstances and depending on your jurisdiction, you are entitled to specific rights regarding your Personal Data (subject to some exceptions). In most cases, you can exercise such rights free of charge. When you ask us to exercise any of your rights under this Privacy Policy and the applicable privacy and data protection laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of Personal Data that you request to access. Applicable privacy and data protection laws in your jurisdiction may provide you with different or additional rights related to the Personal Data we collect from you, which may also apply. Please note that you can deliver your request by contacting us at legal@dualbird.io.

Data Rights for Israeli Visitors. If you are based in Israel, you are entitled to request us to: (i) review and access your Personal Data that we process; (ii) update, amendment, and deletion of Personal Data which is incomplete, incorrect, outdated or unclear.

EEA Visitors. If you are based in the EEA, you have the following rights: (i) to access your Personal Data in order to obtain clear, transparent and understandable information on how we process your Personal Data and on your rights, as well as a copy of your Personal Data; (ii) to rectify your Personal Data in case your Personal Data is obsolete, inaccurate or incomplete; (iii) to object the processing of your Personal Data when the processing is based on DualBird’s legitimate interest. We will no longer process your Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g., legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims; (iv) in certain circumstances under GDPR, you have the right to restrict the processing of some of your Personal Data during a limited period of time; (v) to withdraw your consent when it has been obtained and processing is based on consent; (vi) in certain circumstances under GDPR, you have the right to request data portability, meaning that you can receive the Personal Data originally provided by you in a structured and commonly used format or that you can request the transfer of the Personal Data you provided to another data controller; (vii) in certain circumstances under GDPR, you have the right to delete your Personal Data (also known as the right to be forgotten); (viii) if applicable, not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning you or similarly significantly affects you and if automated processing is used; (ix) to lodge a complaint with your national data protection authority. If you have a complaint about how we use your Personal Data, we will always prefer you to contact us first. If you are unsure which data protection authority to contact, please contact us at legal@dualbird.io.

Connecticut and Texas Visitors. Residents of Connecticut and Texas are entitled to certain rights under their respective state’s comprehensive data privacy law. If you are a resident of one of these states, you are entitled to the following rights:

Right to Access. You have the right to request: (i) what Personal Data we have collected, used, disclosed, and sold about you, as well as whether we derived any inferences about you using your Personal Data or whether we process your Personal Data for purposes of profiling to make a decision that produces any legal or similarly significant effect on you, and (ii) a list of the third parties to which we have disclosed or sold your Personal Data. This right is subject to certain exceptions, for example, if providing you with this information reveals any of our trade secrets, we may deny this request.
Right to Deletion. You have the right to request the deletion of your Personal Data that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
Right to Correct. You have the right to correct inaccurate Personal Data that we collect or maintain.
Right to Opt Out. You have the right to opt out of the processing of your Personal Data for the purposes of: (i) targeted advertising; (ii) profiling in furtherance of any automated decision that produces any legal or similarly significant effect; and (iii) the sale of your Personal Data to third parties. We do not have actual knowledge that we sell, profile, or process for purposes of targeted advertising the Personal Data of individuals under the age of 18 without their affirmative consent.
Right to Data Portability. You have the right to request that we transfer your Personal Data to another organization or give it to you. If you exercise this right, we will provide a copy of your Personal Data in a portable and, to the extent technically feasible, readily useable format that allows you to transmit the data to another organization.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment in the processing of your Personal Data if you choose to exercise your privacy rights. Such discriminatory treatment may include but is not limited to: (i) the denial of goods or services, (ii) being charged a different price or rate, or (iii) receiving a different level of quality in goods or services.
Right to Appeal. You have the right to appeal our refusal to take action in response to your request to exercise your other rights. To appeal our refusal, please email us at legal@dualbird.io subject line: “Appeal My Consumer Request.” We will review the appeal and notify you of our response. If you are a concerned with our response as a result of your appeal, you may submit a complaint to the applicable state regulator, as follows:
- For Connecticut residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the Connecticut Attorney General here.
- For Texas residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the Texas Attorney General here.

If you are a resident of Connecticut or Texas and wish to exercise your privacy rights, you may submit a request by emailing us at legal@dualbird.io. To opt out of the sale of your data through cookies or the processing of your Personal Data for purposes of targeted advertising, please visit Your Privacy Choices . If the browser or extension that you (or your authorized agent) are using supports Global Privacy Control (GPC) (see here for more information), you may utilize the GPC opt out preference signal to instruct us to not sell or share any of your Personal Data collected online. The GPC opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. Please note that you must opt out of each device and each browser.

When submitting a request to know/access, correct, or delete your personal information, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for know/access, correction, or deletion requests with the information provided, we may ask you to provide additional information.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

8. Children

The Website is not intended for use by minors (an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 18, and with respect to the US, under the age of 13). If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will endeavor to delete such Personal Data from our systems.

9. Social Media Widgets

Our Website includes social media feature, i.e., LinkedIn™ button. This feature will collect your IP address and which page you are visiting on our Website.

Social media feature is hosted by a third-party. Your interactions with this feature are governed by the privacy policy and terms of use of the social media platform providing it.

10. Changes to This Privacy Policy

This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new or updated privacy policy in our Website. If we make changes that materially affect your privacy rights, we will notify you by prominent posting in our Website and/or via email, and obtain your consent, if required. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy. The new or updated privacy policy will be effective from the date mentioned at the top page of the new privacy policy. We strongly encourage you to review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

11. Contact Information and Data Controller Details

If you have any questions about this Privacy Policy, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Data, please contact us as follows:

By email: legal@dualbird.io

By Mail: Dualbird Inc.West Park 1500 LLC 116 Flanders Road Westborough, MA 01581