Introduction

At DigiRu LLC (the “Company” or “We”), we respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit any of our Websites, including, but not limited to, digiru.com, ______ (our “Websites”), access our software platforms, access any of our mobile applications or otherwise utilize any of our services (collectively the “DigiRu Services”).  This policy also outlines the process for collecting, using, maintaining, protecting and disclosing that information.

This website is not intended for children under the age of 16, and we do not knowingly collect data relating to children.  Please contact us immediately if you believe we may have information related to any child so that we may delete this information.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This privacy notice supplements the other notices and is not intended to override them.

This policy applies to information we collect:

• On our Websites.
• In e-mail, text and other electronic messages between you and our Websites.
• Through our mobile and desktop applications, which provide dedicated non-browser-based interaction between you and our Websites.
• When you interact with our advertising and applications on third-party Websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other websites operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, your choice is not to use our Websites or the DigiRu Services.  By accessing or using these Websites and/or the DigiRu Services, you agree to this privacy policy.  This policy may change from time to time.  If we make any material changes, we will notify you by posting the revised Privacy Policy on our Websites.  Your continued use of our Websites and/or the DigiRu Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Data Privacy Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice.  If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full legal name:          DigiRu LLC

Data Privacy Officer: _______________

Email address:            privacy@DigiRu.com

Postal address:            DigiRu LLC

Attn: Data Privacy Officer

3575 Koger Boulevard, Suite 400

Duluth, GA 30096

Children Under the Age of 16

Neither the Websites nor the DigiRu Services are intended for children under 16 years of age.  No one under age 16 may provide any personal information to or on the Websites.  We do not knowingly collect personal information from children under 16.  If you are under 16, do not use or provide any information on our Websites or on or through any of its features/register on the Websites, make any purchases through the Websites, use any of the interactive or public comment features of our Websites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.  If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 16, please contact us via our contact us link.

Information We Collect About You and How We Collect It

The data we collect about you.

We collect several types of information from and about users of our Websites.  For the purposes of this Privacy Policy, Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, gender or date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect on or through our Websites may include:

• Information that you provide by filling in forms on our Websites.  This includes information provided at the time of registering to use our Websites, creating an account, subscribing to our service, posting material or requesting further information or services. We may also ask you for information when you report a problem with our Websites.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites.
• Your search queries on the Websites.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Websites or transmitted to other users of the Websites or third parties (collectively, “User Contributions“).  Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions.  Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Websites, including traffic data, location data, and other communication data and the resources that you access and use on the Websites.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party Websites or other online services (behavioral tracking).  The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.  It helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Websites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).  A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Websites.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
• Flash Cookies.  Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Websites.  Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons.  Pages of our Websites may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related Websites statistics (for example, recording the popularity of certain Websites content and verifying system and server integrity).

We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

Third-party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Websites are served by third-parties, including advertisers, ad networks and servers, content providers and application providers.  These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Websites and other online services.  They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Websites and its contents to you.
• To provide you with information, products or services that you request from us.
• To provide you with information about our services
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Websites or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Websites.
• In any other way we may describe when you provide the information.
• To fulfill any purpose for which you provide it.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.  Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Specific Purposes for the Use of Your Data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

[Table]

 

Marketing and Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the DigiRu group of companies for marketing purposes.

 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, customer service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  For more information about the cookies we use, please see digiru.com/cookiepolicy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@DigiRu.com.  You may also write to us at DigiRu LLC, Attn: Legal 3575 Koger Blvd., Suite 400, Duluth, GA 30096.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or that you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of DigiRu’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by DigiRu about our Websites users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to these disclosures.  We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.  For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Websites, we will transmit the contents of that e-mail and your e-mail address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DigiRu, our customers or others.  This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising.  You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Websites.  If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s Websites.

Accessing and Correcting Your Information

You may send us an e-mail via our contact link to request access to, correct or delete any personal information that you have provided to us.  We cannot delete your personal information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Websites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Websites users.  Proper access and use of information provided on the Websites, including User Contributions, is governed by our terms of use.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data based on our instructions and they are subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The safety and security of your information also depends on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page.  If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Websites home page.  The date the privacy policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Websites and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us via our Contact Us link.  You may email our Data Protection Officer at privacy@DigiRu.com.  You may also write to us at DigiRu LLC, Attn: Legal 3575 Koger Blvd., Suite 400, Duluth, GA 30096.