EFFECTIVE DATE: July 9, 2019
dtx respects your privacy and recognizes your need for appropriate protection and management of the personal information you share with us. We obtain and use your data collected through your use of our Site and Services consistent with the following principles to ensure we treat your personal information in a way that is ethical and privacy-conscious.
By using the Site or the Services, you are accepting and consenting to the use of your information as described in this policy.
1. What Information We Collect
The information we gather enables us to personalize, improve and continue to operate our Site and the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your personal information. We collect the following types of information from our users.
Information You Provide to Us:
When you contact us through the Site, we may request you provide your name, email address, phone number and address so we understand more about you and can communicate with you about the information you have requested.
IP Address Information and Other Information Collected Automatically:
dtx automatically receives and records information from your web browser when you interact with the Site or use the Services. This information includes, but is not limited to: (i) the IP address and location derived from the IP address; (ii) the referring websites or services; (iii) the time and date of each access; (iv) device settings, such as browser type, operating system, and language; (v) cookies, as described below, and mobile advertising identifiers and (v) information about sharing of dtx’s QR codes through third party providers, such as through social media. This information may be used for Service functionality, to help us understand how you access a website, to fight spam/malware, to facilitate collection of data concerning your interaction with the Services or the Site and for other similar purposes.
Metrics and Performance Statistics:
dtx may collect and track metrics and performance statistics relating to your use of the Services and the Site, and dtx may use these metrics and statistics to generate analytics. This information may include, but is not limited to: (i) the IP address and physical location of the devices accessing the URLs provided through the Services; (ii) the referring websites or services; (iii) the time and date of each access and the amount of time spent on certain sections of the Site. These metrics and analytics may be used by dtx and its partners to improve their websites and services and to conduct market research.
We also use third-party services such as Google Analytics in order to track your activity on our website. The information we collect through these third-party services includes your IP address, your device type and operating system, your Internet browser, your location, the pages on our website you have visited, the actions you’ve performed on these pages. We use such information to better understand your needs and improve our platform accordingly, and also to send you marketing messages that are relevant and match your interests. You can prevent your data from being used by Google Analytics on websites by installing the Google Analytics opt-out browser add-on here.
2. How We Collect and Use Personal Information
We collect personal information you choose to provide to us, such as email address/usernames.
As discussed above, our web servers may automatically collect non-personally identifiable information, including the web page from which a visitor enters our Site, which pages a visitor visits on our Site, and on some Site, how much time a visitor spends on each page, and from what location a user accesses content through our Services. We aggregate this information and use it to evaluate and improve our Site and Services and use the information for market research purposes, including for our third party sponsors/partners.
Our primary goals in collecting information from and about you are to:
· provide you with the all features and functions of the Site and the Services;
· provide you with superior service and with information targeted to your interests;
· provide you with a smooth, efficient, and personalized experience while using our Site and/or Services;
· to provide you with marketing and promotional information that we believe may be of interest to you;
· operate our Site and provide the Services;
· process and complete any transactions;
· verify individual identity;
· respond to inquiries, questions and comments and provide customer and technical support;
· provide access to certain functionalities of our Services;
· personalize and improve the Services and develop new products and services;
· communicate with our current and prospective customers concerning our services;
· measure interest and engagement in our Site and Services;
· monitor and analyze usage and trends of the Site and Services;
· provide services to our customers to allow them to understand how you interact with our Services and to help detect, deter and prevent malicious, fraudulent or unlawful activity;
· comply with any legal obligations; and
We may also use non-personally identifiable information on an aggregated and anonymous basis to analyze your behavior and to help us understand how you use our Site and Services and to measure interest in the various pages. We may use this information to gather statistical information, improve the content of our Site, to make our Site easier to use, to provide information and statistics to our sponsors/partners, and to customize our advertising.
We may also use information relating to use of the Site and the Services on an anonymous and aggregate basis for research purposes, for marketing and promotional purposes, and to develop new products or service. When your information is used for such purposes it will be used anonymously and will not be tied to your personally identifiable information.
We may use personal information to communicate with you about the Site or the Services and for customer service purposes.
3. How We Protect Your Information
We use reasonable technological and physical safeguards to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted industry standard to protect the information submitted to us, both during transmission and once we receive it. We urge you to keep any password for use of the Services and/or Site in a safe place and not to divulge it to anyone. Also remember to sign off your account and close your browser window when you have finished your visit to the Site or your use of the Services.
4. How Long We Keep Your Personal Information
In general, we will only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law. However, we may continue to store anonymous or anonymized information, such as Site visits, without identifiers, in order to improve our services.
5. Sharing Your Personal Information
We may share your information with third parties as follows:
· With Service Providers: We may use other companies to perform services including, without limitation, facilitating some aspects of our Site or Services such as sending emails, and fulfilling customer service requests. These other companies may be supplied with or have access to your information solely for the purpose of providing these services to you on our behalf.
· With Business Partners: We may share information with the businesses with which we partner to offer you certain products, services, and promotions which may be of interest to you. If you have consented to receive marketing messages, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes or providing your information to others. In addition, we may share your information with our partners on an anonymous and aggregate basis.
· Legal Proceedings: In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law;
· Compliance: When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Site’ terms and conditions or other agreements or policies.
· Corporate Transaction: Such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy. We will endeavor to contact you in the event of any of these transactions, but we do not promise to do so.
We require these organizations to agree to provide the same level of protection for personal information as is provided for under this Policy. In addition, we require any organization processing the personal information of individuals from the EEA and Switzerland to only process the personal information for limited and specified purposes consistent with your consent, or other legal basis for processing, provide the same level of protection for personal information as is required by the Privacy Shield Principles; and notify dtx and cease processing personal information (or take other reasonable and appropriate remedial steps) if the organization determines that it cannot meet its obligation to provide the same level of protection for personal information as is required by the Privacy Shield Principles.
6. Marketing Messages Opt-Out
If you would like to opt out of receiving promotional emails from dtx, please contact firstname.lastname@example.org. You may also opt out of receiving emails and other messages from dtx by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as communications regarding Services you have requested
7. Special Notice for California Residents
If you reside in California and you have provided us with personal information, you may request information about our disclosures of certain categories of your personal information (if any) to third parties for their direct marketing purposes. Such requests must be submitted to us at email@example.com. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties (if any) for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this paragraph.
8. Use of Site by Children
The Site is not directed at and should not be used by children under the age of 16. If we learn that we have collected the personal data of a child under the age of 16, we will take reasonable steps to delete the personal data.
9. Links to Third Party Sites
10. Visiting Our Site From Outside the United States
If you are visiting our Site from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
11. Data Originating from the European Economic Area (EEA) and Switzerland
The Legal Basis for Using European Personal Information
When we collect information about you through our Site or through your use of our Services, the legal basis on which we process your personal information is our legitimate interests, namely, to:
▪ provide merchants and others with our services;
▪ provide communications, marketing, and advertising to you;
▪ provide reporting and analytics;
▪ provide troubleshooting, support services, or to answer questions; and improve our services and the Site.
When we process personal information to pursue these legitimate interests, we do so where we believe the nature of the processing, the information being processed, and the technical and organizational measures employed to protect that information can help mitigate the risks to you.
12. Dispute Resolution for EEA and Swiss Individuals
dtx has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. dtx conducts an annual self-assessment of its Personal Information practices to verify that the attestations and assertions dtx makes about its Privacy Shield privacy practices are true and that dtx’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
If you wish to file a complaint concerning dtx’s processing of your personal information, please contact dtx’s Privacy Team at the address at the bottom of this Policy. In compliance with the Privacy Shield Principles, dtx commits to resolve complaints from EU and Swiss individuals about our collection or use of your personal information.
EU and Swiss individuals who are unable to resolve their complaint with dtx’s Privacy Team may pursue recourse with JAMS, an alternative dispute resolution provider located in the United States, under the JAMS EU-US and Swiss-US Privacy Shield. The services of JAMS are provided at no cost to you. For more information and/or to file a complaint, please visit: https://www.jamsadr.com/eu-us-privacy-shield. dtx is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) to ensure compliance with the EU-US and Swiss-US Privacy Shield principles outlined in this policy.
If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
13. Your Choices and Rights
You have several choices regarding the use and disclosure of your information.
Information You Provide: With respect to the collection of your information, if you do not want your personal information collected, please do not submit it to us. However, if you choose not to provide the information we request, you may be unable to use certain content on our Site. If you have already submitted information and would like to review, correct or remove it from our records, please contact us.
Cookies: If you wish to disable cookies, you can set your browser not to accept cookies. You can find out how to do so here: aboutcookies.org. Please note though that if you turn off cookies, there may be some features and functions of our Site that will not be available to you and some pages may not display properly.
Rights for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
o to service providers, affiliates, agents and/or business partners dtx has retained to perform services on its behalf;
o if it is required to do so by law or legal process, including disclosure to law enforcement or other government authorities if required by lawful order;
o when dtx believes disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; or
o in the event it sells or transfers all or a portion of its business or assets (including in the event of a divestiture, merger, consolidation, liquidation or bankruptcy). Should such a sale or transfer occur, dtx will use reasonable efforts to direct the transferee to use the personal information in a manner that is consistent with this Privacy Shield Policy.
▪ Find out if we use your personal information, to access your personal information, and receive copies of your personal information.
▪ Withdraw your consent to the processing of your personal information at any time without penalty.
▪ Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
▪ Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
▪ If you believe your personal information is inaccurate, unlawful, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to instruct us to restrict the processing of your data pending our investigation and/or verification of your claim.
▪ Request your personal information be deleted or restricted under certain circumstances. For example, if dtx is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent.
If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal information, please contact us at firstname.lastname@example.org.
14. Updates and Changes to this Policy
To improve the services it can offer you, dtx may opt to expand its capabilities for obtaining information about users in the future. dtx will update this privacy statement continually to ensure that you are aware of developments in this area. We will post those changes here so that you will always know what information we collect online on through ours Site and Services, how we use it, and what choices you have. Please be sure to check this page before proceeding to use our Site or using the Services.
15. Questions or Feedback
the dtx company
Attn: Privacy Team
45 Grand St.
New York, NY 10013