Privacy Policy

Last updated: January 26, 2022

This Privacy Policy describes Our policies and procedures on the collection, use, transfer, storage, and disclosure (“Processing”) of Your Personal Data when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the Processing of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Template.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. The words “include” and “including” shall not be interpreted as limitations.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Delino.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to the United States of America.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Device Information means information or data disclosed by a user’s Device, such as Internet Protocol (IP) or Media Access Control (MAC) address, or other host-specific persistent static identifiers that consistently link to a particular person or small, well-defined group of people.
  • Personal Data is any information that, on its own or in conjunction with any other information, can be used to identify an individual.
  • Service means the contract risk review service offered by Company, including the Website.
  • Service Provider means any natural or legal person who Processes the data on behalf of the Company. It refers to third-party companies or individuals employed or otherwise engaged by the Company to facilitate the Service, to promote the Service on behalf of Company, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Delino, accessible from
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

How We Collect Personal Data

You may give us Personal Data by:

  • Interacting with Our Website. This usually occurs when You visit Our Website. The type of Personal Data collected includes Your Device Information;
  • Using Our Services. This usually occurs when You submit a request to join Our beta or live Service, log in to our Service, complete Our onboarding questionnaire, or submit contracts, insurance information, and other supporting materials. The types of Personal Data collected includes Your First name and Last Name, Email address, Username and password, Address Information, Telephone Numbers, Fax Numbers, Work Details, and Insurance Details.
  • Paying for Services. This usually occurs when You subscribe to and/or pay for our Services using a third party payment processor integrated with our Website or Services.
  • Corresponding with Us. This usually occurs when You email Us or apply to join Our beta or live Service. We ask You to disclose only as much information as is necessary for You to submit Your question/suggestion/comment, and for Us to provide You with our Services or respond to Your question/suggestion/comment.

Types of Data We Collect

Personal Data

While using Our Service, We may ask You to provide Us with, and/or You may voluntarily or inadvertently provide, certain Personal Data that can be used to contact or identify You. Personal Data may include, but is not limited to:

  • First name and Last name
  • Email address
  • Address information, such as Street Address, State, Province, ZIP/Postal code, City, or country
  • Device Information
  • Telephone Numbers, including personal, business, and cell numbers
  • Fax Numbers
  • Work Details, such as employer, company name, address, and colleagues
  • Insurance Details
  • Usage Data

Usage Data & Device Information

Usage Data and Device Information are collected automatically when using the Website.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Website by or through a mobile device, We may collect certain Device Information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
  • Web Beacons.Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You request cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain Our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, performance, and administration of the purchase contract for the services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, updates, contracted services, or related products, including third party products and services, when necessary or reasonable for their implementation.
  • To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about, and that third parties offer but which are similar or related to the Services, unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing and Your experience.

We may share Your Personal Data in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to develop, perform, and manage the Services, and to perform Our obligation of any other contract You have with Us. This may include disclosure to Service Providers to monitor and analyze the use of our Service and to contact You.
  • For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, perform and maintain the Services for You and other users, and enforce our legal agreements and policies.

The Company will also retain Usage Data and Device Information for internal analysis purposes.

Transfer of Your Personal Data

Your information, including Personal Data, is Processed at the Company's operating offices and in any other places where the parties involved in the Processing (including Our Service Providers) are located. This means that Your information may be transferred to (and maintained on or by) third parties (such as Service Providers), computers, servers, and/or devices (i) located outside of Your state, province, country or other governmental jurisdiction; (ii) in jurisdictions where the data protection laws may differ than those from Your jurisdiction; and (iii) that are not owned or controlled by Us

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that Processing.

The Company will take all reasonably commercial steps to ensure that Your data is treated securely and in accordance with this Privacy Policy. No transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation (including contractual obligations)
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We may also provide You with links and offers for third party products and Services related to Your use of the Services. If You click on a third-party link, You will be directed to that third party's site. Third party sites are not governed by or subject to this Privacy Policy. The third party’s use of Your data is subject to the third party’s privacy policy (if any) and the laws applicable to the third party. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us:

  • By email:

Information for Residents of California

This section provides additional information about the Personal Data We collect and/or Process about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”). If You are not located in the State of California, U.S.A, the following policies do not apply, and the foregoing sections of the Privacy Policy control.

The California Consumer Privacy Act (“CCPA”)

The following subsections to this Privacy Policy apply to Our Processing of personal Data of California consumers (as the terms "personal information" and "consumer" are defined under the CCPA) (collectively, "Consumers," "You," or "Your"). Any capitalized terms or other terms not defined herein have the same meaning ascribed to them in the Privacy Policy or, if not defined herein, the CCPA. To the extent of any conflict between this Privacy Policy and the CCPA, the CCPA shall control only with respect to Consumers and their Personal Data.

Personal Information We May Collect

The table below shows the types of personal information that OHA has collected during the past twelve (12) months, the sources of the information, and the business or commercial purposes for which We may use that information. For all types of personal information collected, We disclose data to our service providers and other third parties to help Us accomplish the business purposes described below. The examples given in each category are illustrative only, and are not exhaustive.

For more details about the Personal Data We have collected over the last 12 months, please see the section “Types of Data We Collect” above. We collect this Personal Data for the commercial purposes described in the section “Use of Your Personal Data” above, and will only share information You share with Us for the purposes enumerated in that section. We do not sell (within the meaning of the CCPA) the Personal Data We collect.

Your CCPA Rights

Access. No more than twice (2 times) per every twelve (12) months, and upon appropriate verification, You may request access to any Personal Data We have collected and maintained about You over the preceding twelve (12) month period. You may also request information regarding the use and disclosure of any Personal Data We have collected and maintained about You.

Deletion. Subject to certain exceptions, You have the right to request that We delete Personal Data collected and maintained about You. We will delete Your Personal Data once Your request has been verified and We have determined that applicable law requires Us to delete that information. Your request to delete Your Personal Data may be denied if it is necessary for Us to retain Your information under one or more of the exceptions listed in the CCPA. A record of Your deletion request may be kept to comply with legal obligations.

Exercising Your Rights

To exercise Your rights to access and deletion, please submit a request to Us by emailing Us at

Consumers have a right to receive non-discriminatory treatment in the exercise of their CCPA rights.

Verifying Your Request

Only You, or a person that You authorize to act on Your behalf, may make a request related to Your Personal Data. In exercising Your rights of access to and/or deletion of Your Personal Data, Your request must be verified before We can respond to the exercise.

Verifying Your request will require You to provide sufficient information for Us to reasonably verify that: (i) You are the person about whom We collected Personal Data or a person authorized to act on Your behalf (e.g., previous transactions of person to whom request relates); and (ii) applicable law requires Us to comply with Your request.

We reserve the right to charge a reasonable fee or refuse to act on a request if the request is excessive, repetitive, or manifestly unfounded.

Consumers have a right to receive non-discriminatory treatment in the exercise of their CCPA rights.

Your California Privacy Rights under the "Shine the Light" Law

Section 1798.83 of the California Civil Code (a separate law from the CCPA) provides that residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If You would like to submit a request pursuant to this law, please contact Us via email at with the subject line “CA Civil Code”.

Do Not Track

We currently do not respond to any Do Not Track signals or similar signals.

Contacting Us

If You have any questions regarding our CCPA privacy practices, please contact Us via email at with the subject line, "CCPA Policy".