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Last updated: September 14, 2017


DTO Holdings LLC (“DTO” or “we” or “us” or “our”) respects the privacy of the users (“user” or “you”) of its website, (the “Website”). The following privacy policy (“Privacy Policy”) is designed to inform you about the types of information that DTO may gather about you or collect from you in connection with your use of the Website and/or Services (as defined below). It also is intended to explain the conditions under which DTO uses and discloses that information, and your rights in relation to that information.  This Privacy Policy is part of, and incorporated into, the Terms and Conditions and your access to and use of the Website, and the products and services available through the Website (collectively, the “Services”), is subject to and conditioned on your acceptance of and compliance with the Terms.


The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing the Website from other jurisdictions, particularly regions with laws or regulations governing personal data collection, use and disclosure that differ from United States law, please be advised that you are transferring your personal information to us in the United States, and by using the Website and our Services, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your access to and use of the Website and Services and your agreements with us. If your use of the Website and/or Services would be unlawful in your jurisdiction, please do not use the Website or Services.






  • General


“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


A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. The Website uses cookies to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchases. DTO also uses Web Cookies to track the pages that users visit during each Website session, both to help DTO improve users’ experiences and to help DTO understand how the Website and Services are being used. As with other Non-Personally-Identifying Information gathered from users of the Website and Services, DTO analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help DTO, its partners and others better understand how the Website and Services are being used. USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.


  • 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.  


  • Analytics


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.







  • 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.


  • Business Transfers; Bankruptcy. DTO reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of DTO’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it.


  • 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.




DTO may provide links to other websites that may be of interest to our users. However, we are not responsible for the privacy practices employed by those websites, nor are we responsible for the information or content they contain. This Privacy Policy applies solely to information collected by us through the Website and Services; thus when you use a link to go from our website to another third-party website, this Privacy Policy is no longer in effect. We encourage users to read and consider the privacy policies of these other websites before using them. 




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.




We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. Your continued use of the Website and Services after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly. 




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.




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.




If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:


DTO Holdings LLC

320 7th Avenue #142

Brooklyn, New York 11215

Attn: Privacy Officer