How We Handle Your Privacy
Effective Date: March 28, 2022
- What information do we collect about you?
- What is our lawful basis for processing Personal Information?
- How do we use the Personal Information we collect about you?
- Do we share your information with third parties?
- What Other Information about you do we collect?
- How do we collect, use and disclose Other Information about you?
- What choices do you have to opt-out?
- How do we secure your Personal Information on the Services?
- How can you access, update, correct or delete your Personal Information?
- What is the retention period for the Personal Information collected?
- Who may use the Services?
- How can you contact us?
1. What information do we collect about you?
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We and our service providers may collect and combine Personal Information about you from a variety of sources, including through the Services. For example, we collect Personal Information when you sign up for newsletters, marketing emails and other commercial electronic messages (e.g., on upcoming promotions, new products, etc.), register an account to access the Services, correspond with us, make a purchase, or otherwise access our Services. The term “Personal Information” does not apply to de-identified, anonymized, and aggregated information or data that may be derived from Personal Information, that cannot be reasonably connected with any individual, (“De-identified Data”). We hold all rights in and may use De-identified Information for our own purposes in any manner and without attribution or compensation to any person. We generally use De-Identified Information for various purposes, including, for example, to prepare aggregated trend reports on how our digital content is used and perform market research, so we can improve our Services.
We generally collect the following types of Personal Information:
- Your Name
- Role and/or title at your company
- Email address
- Telephone number
- Mobile phone number
- Postal/zip code, state/province, and country
- Username and password (related to your account)
- Information related to customer satisfaction surveys, customer requests, or queries
2. What is our lawful basis for processing Personal Information?
When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy, or by clicking “I Accept” or similar language online or through a mobile application, we will process your Personal Information for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Personal Information is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Personal Information has been fulfilled and after we no longer have a legal obligation to keep that Personal Information.
In all cases, we will comply with applicable law and we will cease processing your Personal Information after the legal right, obligation, or other lawful basis expires.
3. How do we use the Personal Information we collect about you?
The Personal Information we collect from you helps us provide our Services, personalize your experience with us and our communications to you, and improve your experience with our Services. You may choose not to provide us with certain requested information, but then you might not be able to take advantage of some of our Service features or we may not be able to provide you with the Services.
We and our service providers use the Personal Information collected above for purposes including:
Providing the functionality of the Services and fulfilling your requests, including:
- Presenting the Services and its contents to you.
- Opening and arranging access to your registered account.
- Responding to your inquiries and fulfilling your requests for example when you contact us via one of our online contact forms or chat lines.
- Processing your order or other transactions, including warranty and product registration, claim, or request, and providing related customer service.
- Allowing you to send messages to another person if you choose to do so.
- Fulfilling any other purpose for which you provide Personal Information.
- In any other way we may describe when you provide the Personal Information.
- For any other purpose with your consent.
- We will engage in these activities to manage our contractual relationship with you, and/or to take steps at your request prior to entering into a contract, and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you advertising and marketing-related emails with information about our Services, new products and other news about our company. If you do not want to receive additional marketing emails, click the “unsubscribe” link included in each of these emails.
- To facilitate the social sharing functionality that you choose to use.
Analyzing of Personal Information for business reporting and providing personalized services.
- To better understand you, so that we can personalize your experiences when using our Services and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
Allowing you to participate in sweepstakes, contests or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
Otherwise accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
- For enhancing, improving, modifying, and developing our products and Services.
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
- For carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection.
4. Do we share your information with third parties?
We do not sell, rent, or trade your Personal Information to unrelated third parties. We do share Personal Information with our affiliates and third-party service providers in order to perform tasks on our behalf such as the following:
- Facilitating your purchase
- Assisting in servicing our products
- Helping you exchange products
- Providing and improving our communications with you
- Responding to requests to our investor relations
- Improving our products and Services, including through analytics
We may share your Personal Information if we are ever merged with or acquired by another company, or if we acquire another business entity or are involved in a corporate reorganization or other change of control, or if we sell our assets or the assets of our affiliate or subsidiary, or are involved in a restructuring, reorganization, dissolution or other sale or transfer of assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding.
We may share certain information that is not Personal Information (including certain Other Information or De-Identified Information) with third parties, including as follows: aggregate data about our sales, customers, traffic patterns, and other related Services information with third parties, as described in “How do we use the Personal Information we collect about you?”.
5. What Other Information about you do we collect?
As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain Other Information about your equipment, browsing actions, and usage patterns. Some Other Information may be Personal Information.
“Other Information” includes: browser type and version, operating system, IP address, GPS coordinates or other location information, Internet service provider used to access our Services, links used to arrive at our Services and the IP address from which you arrived, web pages requested and viewed, time spent on our Services, technical information about the device used (such as screen size, cookie support by the device and how images may appear), the App usage data, additional information collected through cookies, pixel tags, and other technologies.
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. Please note that we may convert Other Information to De-Identified Information as well and use such De-Identified Information as detailed above.
6. How do we collect, use and disclose Other Information about you?
We and our service providers collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), IP address, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type you are using.
We use this information to deliver a better service and to ensure that the Services function properly, including by estimating our audience size and usage patterns, diagnosing server problems, and storing information about your preferences so that we can customize the Services to your individual interests and recognize you when you return to the Services.
Through your use of our App: When you download and use our App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Physical Location Information: Our Services and emails use your IP address to determine the postal code where you are located when you open the email. This allows us to tailor content to you. The specificity of the location can vary depending on the device used to open our emails. Your email program may allow you to prevent the pixel tags or images in the emails you receive from us from downloading, which will also prevent our service provider from accessing your location information. You can also unsubscribe from receiving our emails, by sending an email to email@example.com.
We may also use pixel tags (also known as web beacons, web bugs, and clear GIFs) in providing the Services. A pixel tag is a nearly invisible pixel-sized graphic image on a webpage or in an email message. We use these technologies to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, measure which parts of the Services are most visited or used, and compile statistics about usage of the Services and response rates.
We also gather statistical information about the use of the Services in order to continually improve their design and functionality, to improve and better transact business, to understand how Services are used, measure which parts of the Services are most visited or used, monitoring the number of visitors to the Services, and assist us with resolving questions regarding the Services.
We additionally use Other Information gathered through technology for identifying and addressing difficulties visitors may experience in accessing our Services.
To the extent we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in “How do we use the Personal Information we collect about you?”.
7. What choices do you have to opt-out?
We give you choices about the information we collect and how we communicate with you and use and disclose your information.
Email: You may opt out of our marketing emails by following the instructions listed in the email that you received. However, even if you opt-out you may still receive non-marketing emails, such as order confirmations, changes to service or customer service communications.
Postal Marketing: If you no longer want to receive marketing materials from us via regular postal mail, please contact us at info@projectdado. com and tell us that you want to be removed from our postal mailing list, including the postal address you wish to have removed.
We will try to comply with your request(s) as soon as reasonably practicable.
8. How do we secure your information on the Services?
We designed our applications to accept traffic only from Web browsers that permit communication through Secure Socket Layer (SSL) technology, which encrypts your information while it is being transmitted to us. While we implement the above security measures on the Site, we do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, and you should be aware that 100% security is therefore not always possible. We also have implemented other reasonable technical, organizational, and physical measures designed to protect the Personal Information in our custody or control from unauthorized access, use, modification, and disclosure.
9. How can you access, update, correct or delete your Personal Information?
You can review and change your Personal Information by logging into the Services and visiting your account profile page. If you would like to delete Personal Information previously provided to us, you can do this by emailing us at firstname.lastname@example.org or calling us at our toll-free number: (866) 704-7210. If you request that we delete your Personal Information, this may require us to also delete your user account, which may partially or wholly prevent us from providing the Services to you. You may delete information in your account by logging in as described above.
Please note that we may need to retain certain Personal Information to fulfill a lawful basis as described in Section 2 and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
11. What is the retention period for the Personal Information collected?
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
We have a lawful basis to retain your Personal Information as described in Section 2; or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in the future.
12. Who may use the Services?
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under eighteen (18).
Our Services are based in the United States, and, regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Please note that any information we obtain about you will be stored in accordance with United States privacy laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage and processing of your Personal Information to and in the United States.
14. California Consumer Privacy Rights
California has adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020 and the California Privacy Rights Act (“CPRA”), parts of which took effect on January 1, 2022. We comply with the requirements of the CCPA and CPRA to the extent they apply to us.
If you are a California resident and we qualify as a “business” under the terms of that law, you will have the following rights:
- You have the right to request that we disclose the categories and the specific items of Personal Information about you that we collect, use, disclose, and/or sell and that Personal Information about you that we have collected, used, disclosed, and/or sold during the 12 months prior to your request.
- You have the right to have the Personal Information we collect about you deleted. We use a two-step process to verify your identity and to have the information deleted. Your rights to have Personal Information deleted are subject to several exceptions, specifically the Personal Information that is necessary for us to:
- complete your transaction;
- provide you a good or service;
- perform a contract between us and you;
- protect your security and prosecute those responsible for breaching it;
- fix our system in the case of a bug;
- protect the free speech rights of you or other users;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- comply with a legal obligation; or
- make other internal and lawful uses of the information that are compatible with the context in which you provided it.
- You have the right to correct any Personal Information we process that is inaccurate.
- You have the right to request portability of your Personal Information to the extent such request is possible.
- You have the right to not be subject to a decision based solely on automated processing, including profiling, known as Automatic Decision Making. Please note that we currently do not employ any Automatic Decision-Making processes in providing the Services.
- You have the right to opt-out of us sharing (as defined in the CPRA) your Personal Information, including for direct marketing purposes, subject to certain legal exceptions.
- You have the right to limit use, disclosure, and restrict sensitive personal information (as defined in the CPRA).
- You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the CCPA, which means that we will not take any action to hurt or punish you for exercising your rights under the CCPA.
To make any request under the CCPA/CPRA please send an email for Data Request to email@example.com or call us using our toll-free number: (866) 704-7210. Please provide your name, email address, telephone number, and any other requested information to reasonably verify your identity. We will respond to your request within 10 business days after receipt of your request, and will then take action to verify your identity and fulfill your request, as required by the CCPA/CPRA.
We will provide you with a CSV copy of your stored data within 45 days of your request, assuming we are able to verify your identity in that period and so long as you provide a correct email address for successful correspondence.
You may designate an authorized agent to make a request under the CCPA/CPRA on your behalf by writing us at firstname.lastname@example.org or by calling us using our toll-free number: (866) 704-7210. Upon receipt of your request, we will provide you with the information you will need to designate that agent.
Note that we are not allowed by law to at any time disclose your Social Security number, driver’s license number, or another government-issued identification number, financial account number, any health insurance or medical identification number, or any account password or security questions or answers without your consent.
We have listed the specific and general categories of information we have collected, disclosed, or sold in the last 12 months in the sections above. Those sections also list the specific and general categories of Personal Information we have disclosed to third parties for our business purposes.
We do not sell your Personal Information.
We do not sell the Personal Information of minors under 16 years of age.
For more information, please direct your questions to us at email@example.com or call us using our toll-free number: (866) 704-7210.
15. How can you contact us?