Last updated: September 14, 2017
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be used to identify a specific person. “Personally-Identifying Information,” by contrast, is information, such as a name or email address that can be used to identify a specific person. Like most website operators, DTO gathers both types of information from users of the Website and our Services.
Non-Personally-Identifying Information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for DTO to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. DTO analyzes Non-Personally-Identifying Information gathered from users of the Website and Services to help DTO better understand how the Website and Services are being used. By identifying patterns and trends in usage, DTO is able to better design the Website and Services to improve users’ experiences, both in terms of content and ease of use. From time to time, DTO may also release the Non-Personally-Identifying Information gathered from Website and Services users in the aggregate, such as by publishing a report on trends in the usage of the Website and Services.
- Web Cookies
- Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. DTO may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique DTO may use to compile aggregated statistics about Website and Services usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
We may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how you interact with the Website and use the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
- Aggregated Non-Personally-Identifying Information
We may share aggregated Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising through the Website and Services and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop Website content and services that we hope you and other users will find of interest and to target content and advertising.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
BY REGISTERING WITH OR USING THE WEBSITE AND/OR SERVICES, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
- Website Registration
DTO may collect a range of Personally-Identifying Information from and about users of its Website and Services. Much of the Personally-Identifying Information collected by DTO is information provided by users themselves when (1) registering for our Services, (2) logging in with social network credentials, (3) participating in features of our Website and Services, or responding to offers or advertisements, (4) communicating with us, or (5) signing up to receive newsletters or email announcements. That information may include a user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, and other demographic or relevant information as determined by DTO from time to time. Users of the Website and Services are under no obligation to provide DTO with Personally-Identifying Information of any kind, although a user’s refusal to do so may limit the use of certain Website and/or Services features, including the ability to make purchases.
- DTO Communications
We may occasionally use your name and email address to send you notifications regarding new services that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the Website and/or Services. You may opt out of such emails at the time of registration, through your account settings or via an Unsubscribe option in the emails, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
- Company Disclosures
Company will disclose Personally-Identifying Information under the following circumstances:
- By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally-Identifying Information 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 DTO, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms and Conditions or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- Third-Party Service Providers. We may share your Personally-Identifying Information, with our authorized service providers, including without limitation, vendors, consultants and data processors, that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website and Services functionality and other features offered through the Website and/or the Services. For example, the credit or debit card information you provide in connection with your account is not stored by us, but is stored and used by our third-party credit card processor to process payments that you owe to us for services received by you. By submitting your credit or debit card information to us, you expressly consent to the sharing of such information with our third-party payment processor and acknowledge that such third party may store your credit and/or debit card information in connection with your use of our Services. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
- Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. We will deactivate or delete your account and contact information from our active databases as soon as practicable, in accordance with your account activity, our deactivation policy and applicable law. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, and to comply with legal requirements as is permitted by law. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
- General Use
DTO uses the Personally-Identifying Information we maintain about you, and other information we obtain from your current and past activities on the Website and Services to (1) process payments and to deliver the products that you have ordered; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to develop and display content and advertising tailored to your interests on the Website, Services and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our products and services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms and Conditions; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We are not responsible for third-party circumvention of any privacy settings or security measures.
You are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, notify us immediately.
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website or Services, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has registered with the Services or has otherwise transferred Personally-Identifying Information to the Services, please contact us using our contact information below to have that child's account terminated and information deleted.
CALIFORNIA PRIVACY RIGHTS
Under California’s "Shine The Light" law, California residents have the right to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. The Website does currently respond to DNT browser signals or mechanisms.
DTO Holdings LLC
320 7th Avenue #142
Brooklyn, New York 11215
Attn: Privacy Officer