Privacy Policy

Portfolio DAM LLC · 36 The Fenway, Boston, MA USA 02215 · Effective April 27, 2026

OVERVIEW#

Portfolio DAM LLC ("Portfolio DAM," "we," "our," or "us") provides enterprise digital asset management software that is deployed within customer-controlled environments, as well as a public website located at portfoliodam.com (the "Website").

This Privacy Policy describes how we collect, use, and protect personal information in connection with:

• our Website, and
• our business operations (including customer relationships, billing, and support)

Portfolio DAM does not host or control customer content stored within the Portfolio DAM software when deployed on customer-managed infrastructure.

ROLES AND SCOPE#

Website and Business Operations#

Portfolio DAM acts as a data controller for personal data collected through the Website and in the course of managing customer and prospect relationships.

Portfolio DAM Software (On-Premises Deployment)#

Customers deploy and operate the software within their own infrastructure.

• The customer is the data controller of all data processed within the software.
• Portfolio DAM acts as a service provider / processor only when providing support under customer direction.

CATEGORIES OF PERSONAL DATA#

A. Website Data#

We may collect:

• Name
• Email address
• Company name
• Phone number
• Inquiry details

We may also collect technical data:

• IP address
• Browser type
• Device information
• Pages visited
• Date/time of access

B. Customer Relationship and Business Data#

We maintain business contact and account information in internal systems such as CRM, billing, and support platforms, including:

• Name
• Business email
• Company name
• Job title
• Phone number
• Billing and contract information
• Communication records (emails, support tickets)

C. Portfolio DAM Software Data (Customer-Controlled)#

Portfolio DAM does not collect or control data stored within the software when deployed on customer systems. This may include:

• media assets (images, video, audio)
• metadata
• user accounts
• logs and audit data

All such data is controlled by the customer.

PURPOSES OF PROCESSING#

We use Website and business data to:

• respond to inquiries
• provide product information
• manage contracts and subscriptions
• deliver customer support
• send service-related communications (e.g., renewals)
• improve Website performance

We do not use customer data within the software for our own purposes.

LEGAL BASES (GDPR / UK GDPR)#

Where applicable, we rely on:

• Legitimate interests (business operations and communication)
• Contractual necessity (customer relationships)
• Consent (marketing communications where required)

SHARING OF INFORMATION#

We do not sell personal data. We may share Website and business data with service providers, including:

• CRM systems
• billing providers
• email and communication platforms
• support tools

These providers process data only on our behalf. Customer data within the software:

• remains within the customer's environment
• is not accessed except at customer request for support

INTERNATIONAL DATA TRANSFERS#

Customer-controlled software data remains within the customer's chosen infrastructure. Website and business data may be processed in the United States or other jurisdictions, subject to appropriate safeguards where required by law.

DATA RETENTION#

We retain Website and business data only as long as necessary for:

• contractual obligations
• legal requirements
• legitimate business purposes

Customer data retention is determined solely by the customer.

SECURITY#

We implement reasonable administrative, technical, and organizational safeguards. The Portfolio DAM software supports:

• authentication controls
• role-based access
• audit logging
• HTTPS encryption

Security of deployed systems is the responsibility of the customer environment.

YOUR RIGHTS#

Depending on your jurisdiction, you may have rights including:

• access
• correction
• deletion
• restriction
• objection
• data portability

Requests related to data in the software must be directed to the customer controlling that system.

CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)#

California residents may:

• request access to personal data
• request deletion
• opt out of sale (we do not sell data)

We do not sell or share personal data for cross-context behavioral advertising.

CHILDREN'S PRIVACY#

Our services are not intended for individuals under 13.

CHANGES#

We may update this policy periodically.

CONTACT#

Portfolio DAM LLC
36 The Fenway
Boston, MA 02215
support@portfoliodam.com

Owner: Operations Manager · Effective April 27, 2026 · Review cycle: annually