EFFECTIVE DATE: September 16, 2019
1. What Information We Collect
You may provide the following types of information to us:
Contact information, such as name, username, email address, phone number and address;
Information about your purchases;
Payment details, such as payment card number;
Information about your interests and preferences;
Precise geolocation information, and other details about your browser or device;
Information about your use of our QR codes (described here);
Other information about your interactions with Brands and other partners;
Other information about your interactions with our Sites and Services.
You share some of that information with us using the information collection technology described below. We also may use that technology to collect information about you automatically.
We may also receive personal information from Brands, service providers, and data partners, as well as from publicly available sources such as websites.
Cookies and other Information Collection Technology:
These technologies help:
Display personalized content;
Facilitate online marketing;
Remember your settings on the pages you visit so that we can display your preferred content the next time you visit;
Perform analytics, measure traffic and usage trends, and better understand the demographics of users;
Diagnose and fix technology problems;
Plan for and enhance our business; and
For example, in some cases, we assist with the collection of information by advertising services provided by third parties. We and ad services may track your online activities over time by collecting information through automated means such as cookies, and we or they may use this information to show you ads that are tailored to your individual interests or characteristics, your prior visits to certain websites, or other information we or they know, infer, or have collected from people like you.
To learn more about interest-based advertising generally, or to opt out of targeted, interest-based ads by some of our current ad service partners, visit aboutads.info/choices from each browser you use.
You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page from each browser. Google also allows you to install a Google Analytics Opt-out Browser Add-on for each browser.
If you replace, change, upgrade or reset your browser or device, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.
Here’s an example of a QR code:
When you point the camera on any modern phone or tablet at a QR code, you’ll either be given an option to take some action, or your device will automatically take that action. For example, when you point the camera at the QR code above, you’ll see the option to open visit a webpage. Some QR codes can do other things, like download some content or install an app.
2. How We Use Personal Information
We use personal information:
To provide our Services to Brands, users, and others;
To improve our Services and create new ones;
To respond to questions, concerns, or customer service inquiries, and to otherwise fulfill individuals’ requests;
To send information about our current and future Services (or the offerings of Brands), including marketing communications by phone, email, online display advertising, and other channels;
To analyze market conditions and use of our Services;
To customize the content and advertising individuals see on our Sites, across the Internet, and elsewhere;
To enforce the legal terms that govern our business relationships;
To detect and take measures against fraud, cybersecurity violations and other risks;
To comply with law and legal process and protect rights, safety and property; and
For other purposes requested or permitted by Brands, users or other relevant individuals, as appropriate.
3. Protection of Information
Our security measures include various technological and physical safeguards. We urge you to use a unique password for each of the Services, to keep them in a safe place and not to divulge them to anyone. Also remember to sign off your account and close your browser window when you have finished your visit to the Sites or your other use of the Services. However, no security method is perfect, and even if you take those steps, we cannot guarantee that any data will remain secure.
4. How Long We Keep Your Personal Information
In general, we will retain your information in identifiable form for the time necessary to realize our legitimate business purposes and to comply with the law. Information may persist in copies made for backup and business continuity purposes for longer than original copies.
5. Sharing Your Personal Information
We may share your information with third parties as follows:
With Brands: We share information with Brands. For example, when we collect information about you in the context of your relationship with (or interaction with) a Brand, we may share that information with the Brand. We may also share personal information with Brands in other situations.
With Service Providers: We may share your information with companies that provide services to us, including, without limitation, facilitating some aspects of our Site or Services such as sending emails and fulfilling customer service requests.
With Business Partners: We may share information with businesses with which we partner to offer you certain products, services, and promotions which may be of interest to you.
Legal Proceedings: We share information when we believe disclosure is appropriate due 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: We share information 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 Services’ terms and conditions or other agreements or policies.
Corporate Transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, a bankruptcy, or other significant corporate event.
6. Marketing Messages Opt-Out
If you would like to opt out of receiving promotional emails from dtx, please contact email@example.com or follow 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. Use of Services by Children
Our Services are not directed at and should not be used by children under the age of 16. If we learn that we have collected the personal information of a child under the age of 16, we will delete it or take other steps if required under applicable law.
8. Links to Third Party Web Sites
9. International Data Transfers
10. Legal Basis for Processing Personal Information
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your personal information. To the extent those laws apply, our legal grounds for processing personal information are as follows:
To honor our contractual commitments to an individual: Some of our processing of personal information is done to meet our contractual obligations to the individuals to whom the personal information relate, or to take steps at their request in anticipation of entering into a contract with them. For example, when an individual purchases something from us, we may process their payment information on this basis.
Consent: Where required by law, and in some other cases, we process personal information on the basis of consent. For example, some of our direct marketing activities happen on the basis of opt-in consent, such as sending marketing emails to individuals who have requested them.
Legitimate interests: In many cases, we handle personal information on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
Some marketing activities, including, in some cases, direct marketing such as via email;
Protecting Brands, users, personnel and property;
Analyzing and improving our business and Services; and
Managing legal issues.
We may also process personal information for the same legitimate interests of Brands and other business partners.
Legal compliance: We need to use and disclose personal information in certain ways to comply with our legal obligations.
Where we process personal information solely on behalf of a Brand, the Brand is responsible for maintaining a legal basis for the processing.
11. Your Choices and Rights
Depending on which laws apply to particular situations, residents of the European Economic Area and some other jurisdictions have certain additional legal rights to do the following with personal information we handle:
obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
update, correct or delete the information;
object to the use or disclosure of the information;
withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information); and
obtain a restriction on the use of the information.
For example, individuals whose personal information is subject to the General Data Protection Regulation (GDPR) have a right to opt out of our handling of their personal information for direct marketing purposes.
Many of the rights described above are subject to limitations or exceptions under applicable law.
13. Updates and Changes to this Policy
14. Questions or Feedback
the dtx company
Attn: Privacy Team
45 Grand St.
New York, NY 10013