Privacy & Anti-Bribery Policy

Last updated: 05/16/2022

Data Gumbo is committed to safeguarding the privacy of client information. We know that security is a paramount concern, and accordingly, we use multiple levels of security to protect client data. This policy describes the types of information that may be collected from clients and other users of our website and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy is divided into the following sections:

  1. General website user information
  2. Private information about our clients
  3. Legal Disclaimer
  4. Proprietary Data
  5. Cookies⁠ — What are they and how are they used?
  6. Cookies⁠ — What happens if you disable cookies from this site or a Data Gumbo system?
  7. How can clients access, update or delete their information?
  8. What security procedures are in place to protect the privacy, loss, misuse or alteration of client data?
  9. Contract Variance
  10. Disclosure of information
  11. Children under the age of 13
  12. Policy Consent
  13. Data Protection Officer
  14. Anti-Bribery and Corruption (ABC) & Sanction Review Compliance Policy

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this website or its related services, you agree to this privacy policy. This policy may change from time to time (as described below). Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

It is our policy to post any changes we make to our privacy policy on this page [with a notice that the privacy policy has been updated on the website home page]. The date the privacy policy was last modified is identified at the top of the page. You are responsible for periodically visiting our website and this privacy policy to check for any changes.


This website and Data Gumbo applications use information gathering tools including cookies and other similar technology. If you do not consent, please do not use them. Data Gumbo logs certain information from the browser sessions of its website users when they visit the Data Gumbo website. This information includes a user’s domain name and IP address, browser version, operating system, information collected through cookies or other tracking technologies, the URL the user came from, the pages the user visits within the Data Gumbo website, and the URL to which the user goes upon leaving the website. This information is used in an aggregate form only, to monitor website performance, audience size, utilization of features and services, traffic trends, and browser versions.


Private information about our clients must be gathered to set up the client’s account within their company’s Data Gumbo node. General information such as names, mailing address, phone numbers, email address, and IP address are required to enable transactions between participant companies’ nodes on the Data Gumbo network. This information is used strictly within the domain of the Data Gumbo system, and for Data Gumbo related communication. Except as described in Section 8, “Disclosure of information,” below, Data Gumbo will not make its client data available to any other company or individual without your prior consent. Data Gumbo may also use client contact information for billing purposes, newsletters, notification of Data Gumbo service updates, and other business-related communication.

Non-registered customers may on occasion submit personal information on an online form to request product information, or to enroll in a seminar. This information is treated with the same guidelines as we treat our client data.

Fundamentally, we try to treat your personally identifiable and other sensitive data the same way we would want our service providers to treat our data.


Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website. We may also may also be required to disclose personal information if Data Gumbo merges with or is acquired by a third party.


Data Gumbo is a customer centered Application Service Provider. We recognize that customer data including but not limited to Invoices, Joint-interest Billings, production data, and proof-of-delivery information that resides on our database servers is the proprietary property of our customers and/or their data providers, and we commit that we will not compromise this entrusted data or resell it to a third party. In addition, we recognize and share the concerns of our customers about the potential of data mining of this proprietary data, and we will not perform data studies comparing the specific performance of any individual identified customers without the express written consent of the customers identified.

We reserve the right to show “aggregate” statistics of total throughput by product on our website for marketing, industry study groups, and capital raising events. Efforts will be made to assure that individual companies will not be recognizable in these aggregate statistics. Data Gumbo also reserves the right to use data where companies have given explicit permission.


A cookie is a piece of textual data stored on the user’s device that can be used within and across browsing sessions. There are two types of cookies – session cookies and persistent cookies. Session cookies are automatically removed once a user closes the browser. Persistent cookies are small text files stored on the device for an extended period of time, such as remembering that a user prefers that a page section expanded or collapsed. While persistent cookies are used to improve the user’s experience of the website, Data Gumbo does not expose personal or business data through its use of them. You can choose to manage the cookies we use by adjusting your internet browser settings at any time.


Preventing cookies is likely to impact your user experience and could stop you from using certain services provided in this website or another Data Gumbo application.

If you choose to disable cookies, we cannot guarantee how the operation of this website or another Data Gumbo application will perform during your visit. It will also affect our ability to improve our products, making changes to address your user preferences.

CAUTION: Clicking this button will erase information about you and require you to fill out forms that you have previously filled out in the past or otherwise degrade your user experience.



Registered customers each have their own User ID and password, and each user must sign on with the correct ID and password to enter the Data Gumbo system. Passwords are encrypted and cannot be accessed. The company’s administrator maintains each user’s profile information. Users only see information authorized for their use. The company’s administrator also sets up each user within the system, sometimes with the assistance of Data Gumbo support personnel. Users that do not have administrative rights may only access their own profile information. Contact your company’s administrator to clarify which rights you have within the system. A detailed discussion of this topic is available to registered users within the online help documentation.

Due to the financial nature of many of the documents stored in the Data Gumbo system, companies restrict access to their information by default, and must positively grant access to users, smart contracts, ledgers and counterparties for that data.  Since the data composes financial records, whether a user can request deletion of the data is governed by the financial laws of the jurisdiction the corporate node operates in.  While access to this data can be limited to authorized personnel and 3rd parties such as auditors or regulators, it cannot be destroyed until the end of records retention periods required by local law. You can submit a specific request regarding your personal information processed by Data Gumbo here or via phone by calling 1-888-914-9661 PIN 907290.


Data Gumbo employs state-of-the art methods to protect your proprietary assets including data encryption, virus protection, regular data back-up, redundant systems, firewall and physical site security. While these features together provide privacy and security for your proprietary data, we cannot guarantee the privacy and security of any information you disclose online. You acknowledge that you are aware of security and privacy limitations, including but not limited to (1) the possible limitations of security, privacy and authentication measures and features in this system; and (2) that data or information on the Site (a) may be subject to eavesdropping, sniffing, spoofing, forgery, spamming, “impostering”, tampering, breaking passwords, harassment, fraud, electronic trespassing, hacking, nuking, system contamination (including, without limitation, viruses, worms and Trojan horses) causing unauthorized, damaging or harmful access and/or retrieval of information, or (b) may be subject to other security or privacy hazards, or (c) may not reach its destination, or (d) may reach an erroneous address or recipient. Transaction security must be safeguarded in three stages to ensure the protection of client data, (1) Data Gumbo data storage, (2) data transmission, and (3) client data storage.

  • Data Gumbo data storage — To provide secure storage, documents and files are stored on servers located off-site at our Colocation Data Center. The servers are protected around the clock every day of the week by dedicated security professionals who monitor the physical infrastructure. Data is backed up regularly and archived for client access. Backup tapes are stored in a secure location off-site from the Colocation Data Center.

  • Data transmission⁠ — To ensure secure transmission, we support multiple data transport types that encrypt your data before transmission to our servers. We support the latest AES and RSA specifications for data encryption.

  • Client data storage⁠ — Data Gumbo ensures the data integrity throughout the life-cycle of the transaction. Copies of transaction data stored in the corporate nodes (blocks in a distributed ledger) are individually and collectively encrypted and cannot be altered without invalidating the records. Altering local copies of a ledger will not affect other copies of the ledger in Data Gumbo or other company nodes and will identify that data as compromised. However, after the data is removed from Data Gumbo nodes and ledgers and imported into a client’s back-office accounting system, the client assumes responsibility for that information.


All legally binding contracts between Data Gumbo Corporation and a client will supersede this policy in the event of a discrepancy between this policy and such contracts. Additional restrictions related to privacy and security may also be in effect, according to the content of each client’s specific contract.


We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy—
to our subsidiaries and affiliates;

  • to advisors, contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

  • to a buyer or other successor in the event of 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 information held by us about our clients or website users is among the assets transferred;

  • to fulfill the purpose for which you provide it;

  • for any other purpose disclosed by us when you provide the information; or
    with your consent.

We may also disclose personal information

  • to comply with any court order, law or legal process, including to respond to any government or regulatory request;

  • to enforce or apply our terms of use or terms of sale and other agreements, including for billing and collection purposes;

  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Data Gumbo, our customers or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


Our website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this website or on or through any of its features or register on the website, make any purchases through the website, use any interactive or public comment feature of this website or provide any information about yourself to us, including your name, address, telephone number, email address or other personal information. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at


By using this website or another Data Gumbo application, you agree to this Privacy Policy. This policy appears in its completed form and supersedes any earlier version.


Questions regarding this policy should be directed to


All trademarks, service marks, logos and trade names, whether registered or unregistered, are proprietary to Data Gumbo or to other companies where so indicated. You may not reproduce, download or otherwise use any such trademarks, service marks, logos or trade names without the prior written consent of the appropriate owner thereof.


Data Gumbo and its subsidiaries and affiliates are committed to conducting business fairly, honourably,
with integrity, and in compliance with the law in all jurisdictions where it operates.

This document ("Data Gumbo's Anti-Bribery and Corruption (“ABC”) & Sanction Review Compliance Policy") explains Data Gumbo's policy on the prevention of bribery.

Accordingly, Data Gumbo is committed to, and will obey, all relevant anti-bribery and corruption statutes and laws wherever it operates. Data Gumbo will never knowingly or intentionally engage in, facilitate, or condone bribery in any form, and has procedures and controls in place to ensure that it makes good on that promise.