Effective Date: June 5, 2018
- use, and
Personal Information (defined below) we obtain through the provisioning of our service, your communications with us, or from third parties. It also describes the choices available to you regarding the use of, your access to, and how to update, correct and retrieve your personal information in accordance with Art. 7 of the General Data Protection Regulation (GDPR).
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized such that it does not allow a third party to easily identify a specific individual.
OUR SERVICE COLLECTS YOUR INFORMATION
In accordance with Art. 4 of the GDPR, We collect Personal Information when you choose to provide it to us including when you:
View or respond to an email from Digital Reach. When using Our Service, you may provide us with Personal Information, such as your name, DOB, phone number, email address, and shipping address.
Submit Information to Our Service. We collect information you submit to Our Service. For example, when you post a review of a email received on Digital Reach on Our Service or refer a friend to Digital Reach using Our Service, Our Service will collect the information in your submission to Our Service, including any Personal Information. If you choose to submit content to any public area of Our Service, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Communicate with Us. We may also collect Personal Information from you when you communicate with us. For example, you may send us Personal Information by writing an email to us or subscribing to a Digital Reach mailing. If you contact us, we may keep a record of that correspondence.
Take a Survey. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. For example, you may be asked to provide contact information as well as information about your height, weight, gender or date of birth.
Information You Provide About a Third Party. If you choose to use our referral service to tell a friend about Digital Reach, we may collect your friend’s Personal Information, such as name and email address. We will automatically send your friend a one-time email inviting him or her to receive a Digital Reach email. We store your friend’s information in order to send this one-time email and to track the success of our referral program.
Passive Collection. Our Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this data to analyze trends in the aggregate and administer Our Service. Non-personal information that we passively collect may be combined with other information about you, including Personal Information.
Information Provided by Third Parties. Digital Reach may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. Information is collected from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you.
HOW DIGITAL REACH USES YOUR INFORMATION
We use Personal Information to facilitate and improve our services and communicate with you in accordance with Art 13 of GDPR,
Internal and Service-Related Usage. We use and retain information, including Personal Information, to improve and facilitate our services. We may also use such data to help us deliver targeted advertising to consumers that is displayed on both Digital Reach websites and unaffiliated websites, to analyze interactions with and performance of our Site, to measure the effectiveness of advertising on behalf of our advertising partners, and to identify the audience most likely to respond to an advertisement. We may also use data from third parties (such as data vendors) pursuant to their own privacy policies, and enhance information (including Personal Information) that we have collected with such third-party data. We believe that the use of such information is helpful to providing users with better services. However, if you would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Choice.”
Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
Marketing. We may use information about you, including Personal Information, to send you information about Digital Reach services.
Non-Personal Information. We may use anonymized, aggregated or other data that is not Personal Information for any purpose, including marketing. These uses may include but are not limited to analyzing interactions with and performance of Our Service, enabling us to improve our Site and services, and sharing such information with our business partners, affiliates, or any other third party. Similarly, we may enhance any such anonymized and aggregated data collected via our Site with other information collected from our business partners.
DIGITAL REACH MAY DISCLOSE YOUR INFORMATION
We may share your information:
- with our third-party service providers;
- to comply with legal obligations;
- to protect and defend our rights and property; and
- with your permission.
We Use Vendors and Service Providers. We may share Personal Information with our vendors and service providers who perform services on our behalf. These third parties are authorized to use your Personal Information only as necessary to provide these services to us.
- Providing customer services including fulfilling orders, delivering packages, and communicating with you about your order
- Payment processing
- Sending, evaluating, and improving marketing communications
- Fulfilling subscription services, including delivery
- Conducting research and analysis
- Measuring and improving the performance of Our Service
- Verifying your identity and preventing fraud
- Developing and improving the Digital Reach site and services
- Registering your Account
- Detecting, preventing and remediating fraud or other potentially prohibited or illegal activities
Displaying to Other Users. The content you post to Our Service may be displayed on Our Service. Other users of Our Service may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing. If you are in the United States and make a receive using Our Service, information collected from you may be made available to select third parties who offer emails or services that may be of interest to you. If you prefer that we not share your information with such third parties, send an email to firstname.lastname@example.org within thirty (30) days of receipt of your email. Note that if it has been more than thirty (30) days since you received your email, your opt-out may not apply to marketing initiatives that are already underway.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order, government request, or subpoena. We may also access, preserve, and disclose your Personal Information, other account information, and content if we believe in good faith that disclosure is necessary to protect yours’, ours’ or others’ rights, property, or safety, or investigate fraud.
We may also disclose your Personal Information with your permission.
Upon request, Digital Reach will provide you with information about whether we hold any of your Personal Information. If you would like to access, update, correct, or delete any information that you have provided to us through your use of Our Service, you may contact us at email@example.com, We will respond to your request within a reasonable timeframe. We reserve the right to save transaction data as is necessary to comply with legal obligations or for purposes of standard business operations.
CHOICE; RIGHTS OF DATA SUBJECT
In accordance with GDPR and relevant Articles, Digital Reach wishes to ensure that users of it’s services understand their rights.
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
To manage our advertising on other sites, we engage third party advertising partners. These third-party partners may use technologies such as cookies to gather information about your activities on Our Service and other sites in order to provide you advertising based upon your browsing activities and interests. Certain of our third-party advertising partners participate in self-regulatory organizations, and those organizations operate websites that give you the ability to opt-out of receiving targeted ads from those partners. You can access these websites, and also learn more about targeted advertising and privacy, at Network Advertising or AboutAds. You can also choose not to be included in Google Analytics here.
To be clear, whether you are opting out by adjusting your browser/device settings or by using a website established by a self-regulatory group, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this policy.
If you would like to opt-out of Digital Reach sharing your information with third parties (such as data vendors) for non-Digital Reach related marketing purposes or for any other purpose, send an email to firstname.lastname@example.org. In accordance with section 12.3 of the GDPR, we will respond back within 30 days.
THIRD PARTY SITES AND SOCIAL MEDIA PLATFORMS
Our Service may contain links to other websites and other websites may reference or link to our Site. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Our Service also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
SECURITY OF YOUR INFORMATION
By using Our Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of Our Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on Our Service or sending an e-mail to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please email us at email@example.com
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of Our Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
By using Our Service, you will transfer data to the United States.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally in accordance with Art. 6 of GDPR.
EU-U.S. PRIVACY SHIELD
Digital Reach intends on participating in and certifying its compliance with the EU-US Privacy Shield Framework. Digital Reach is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Under the Privacy Shield Framework, Digital Reach is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. Digital Reach complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Digital Reach is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Digital Reach may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.