DMI Privacy Policy

Last Updated: 9/24/2018

Overview

This Privacy Policy encompasses Digital Management Holdings, LLC, Digital Management, LLC, and Digital Mobile Innovations, LLC and its direct and indirect subsidiaries, including Digital Mobile Innovations Limited, DMI Innovations Private Limited, Digital Mobile Innovations SL, CW Professional Services LLC and CW Professional Services (Canada) ULC, collectively referred to in this policy document as “DMI,” we,” or “company.” This policy identifies how DMI collects, uses, process, shares, and protects Users’ Personal Data gathered through our websites and mobile applications (the “Services”). It also tells you about your rights and choices with respect to your information and how you can contact us if you have any questions or concerns.

Policy

This Privacy Policy does not apply to the processing of Personal Data DMI does on behalf of our customers. To learn more about the processing of your Personal Data in that context, please refer to the relevant customer’s privacy policy. The DMI Privacy Shield Notice supplements this Privacy Policy.

Personal Data Collected

For the purposes of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual who uses the Services (the “User”, or “you”). DMI obtains Personal Data relating to you from various sources described below.
Where applicable, DMI indicates whether and why you must provide DMI with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from the Services, if that information is necessary to provide you with the Services or if DMI is legally required to collect it.

Personal Data Provided by You

DMI collects Personal Data that Users provide to the DMI website including, but not limited to:

  • Personal contact details (name, phone number, email address, etc.)
  • Company Name
  • Title
  • Country
  • IP address
  • Screen and user name
  • Password
  • Device ID

Users may choose to provide Personal Data through DMI websites. The ways in which users may provide the Personal Data, and the types of data Users may submit, are as follows:

  • Contact DMI: If a User communicates with DMI through the “Contact Us” link on DMI websites, DMI may ask for information such as name, email address, and telephone number. This allows DMI to respond to User questions and comments.
  • Request Technical Support:If a User requests technical support online, DMI will ask for information necessary to complete the transaction, such as name, location, and information about computer hardware, software, and the nature of the problem the user is experiencing. DMI may retain non-Personal Data concerning technical issues to provide the user with continuing support. This information may be made available to technical specialists in order to improve service for similar technical issues encountered by end users.
  • Marketing Communications: DMI may ask Users for contact details, including phone number, email address, and company name when downloading whitepapers or viewing webinars.
  • Careers: Users may be able to submit a resume and other information online to apply for a job with DMI. DMI may ask Users to provide email address, residence, education, work experience, and other Personal Data typically found on a resume. DMI may aggregate Personal Data, collected from a resume, with information from third parties when verifying the veracity of the Personal Data provided.
  • Public Forums and Blog Comment: Users may provide Personal Data in DMI’s publicly accessible blog or community forums. Users should be aware that any information provided in these areas may be read, collected, and used by other users who access the blog or forums.
  • Testimonial: DMI posts customer testimonials, which may contain Personal Data, on DMI websites. DMI obtains User consent via email prior to posting the testimonial in order to post the users name along with the testimonial.
  • DMI as Services and Solutions Provider: DMI may obtain various types of Personal Data about Users. This may include:
  • Contact information (points of contact (POCs), addresses, phone and fax numbers, and email addresses)
  • Information about products and services ordered or provided
  • Financial and payment information
  • User ID, passwords, and information collected through Internet-based activities
  • Other transaction-related information
NOTE: DMI also collects business information such as legal name of the business, address, network, and storage system information.

Personal Data Collected via Automated Means

DMI also collects Personal Data automatically from your use of the Services:

  • When you use our Services, DMI and our third party service providers may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Services, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, country code or approximate location, operating system version, language preferences, referring URLs, and information about the usage of our Services. We may use this information, for example, to ensure that the Services function properly, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We work with analytics providers such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • We also work with third parties advertisers (collectively, “Advertisers”) who may also use cookies or other technologies to track your use of the Services. Advertisers also may use cookies to track your online activities across websites over time to provide interest-based advertising. Some of our Advertisers are members of the Network Advertising Initiative or the Digital Advertising Alliance. Please visit these organizations’ opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. Please visit your device’s settings or install an app blocker application (e.g., AppChoices) to learn more about how you may opt out of receiving personalized ads in mobile apps.
  • If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
  • Social Media Features: The DMI website includes social media features such as the Facebook “Like” button, and other widgets, such as the “Share-This” button or interactive mini-programs that run on the site. These features may collect a User’s IP address, which page being visited on the site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the DMI site. A user’s interactions with these features are governed by the privacy policy of the company providing it.
  • DMI uses Local Storage Objects (LSOs) such as hypertext markup language (HTML) 5 to store content and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML 5 LSOs.

Information Collected via Third Parties

  • Information from Other Sources: We may also obtain information, including Personal Data, from other third parties and sources other than the above. This information may include Google Analytics, LinkedIn, Facebook, Directory Listing, which have lead generation forms, publisher email or member databases, email list vendors and the like.
  • Publicly accessible sources: We may collect information about you, including Social Network Profiles from publicly accessible sources, such as name, gender, age, job title, job function, education, location, and interests.

How We Use Personal Data

The Personal Data that Users provide to DMI may be used to:

  • Operate, provide, and maintain the Services
  • Evaluate the quality of DMI products
  • Provide Users with information about services that may be of interest
  • Communications: DMI may send emails to an email address you provide to us (i) for customer service or technical support purposes; or (ii) to send you information about topics or content that we think may interest you or updates about the latest developments or features on the site. DMI also may send a newsletter to the email address you provide to us in the event that you subscribe to receive the newsletter.
  • Help DMI conduct recruitment-related activities, evaluate a User’s interest in employment, and contact a user regarding possible employment with DMI
  • Deliver or provide products or services to the User
  • Respond to requests
  • Establish or maintain client and business relationships
  • Provide access to Internet or application-based activities
  • Monitor and analyze usage of the Services and improve and enhance the Services
  • Conduct other activities as necessary or appropriate in connection with the servicing and development of the business relationship
  • To enforce DMI terms of service (https://dminc.com/termsofservice/), to defend our legal rights, to comply with our legal obligations and internal policies.
  • We may de-identify and aggregate information collected through the Services for statistical analysis and other lawful purpose.

If you are located in the European Economic Area (EEA), we only process your Personal Data based on a valid legal ground, including when:

  • You have consented to the use of your Personal Data, for example, to receive electronic marketing communications or to provide you with personalized advertising;
  • DMI needs your Personal Data to provide our services, including for account registration, to respond to your inquiries, or for customer support;
  • DMI has a legal obligation to use your Personal Data; or
  • DMI or a third party has a legitimate interest in using your Personal Data. In particular, DMI has a legitimate interest in using your Personal Data to personalize our services and provide you with tailored content, conduct business analytics, and otherwise improve the safety, security, and performance of our Services. DMI only relies on our or a third party’s legitimate interests to process your Personal Data when these interests are not overridden by your rights and interests.

Sharing Personal Data

DMI discloses information that we collect through the Services to third parties in the following circumstances:

  • To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, online advertising, auditing, and other services.
  • DMI may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you. For more information about our advertising and marketing practices and those of the third party advertising partners, please see the Personal Data Collected via Automated Means section above.
  • DMI may also disclose your Personal Data with your permission. We may seek your permission in various ways. For example, we may present you with an “opt-in” prompt when you register to use the Services or access certain content.
  • To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings). You may have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.
  • If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose.

Accessing Other Sites via Links

The DMI website contains links to other sites that are not owned or controlled by DMI. Users should be aware that DMI is not responsible for the privacy practices of such other sites. DMI encourages users to be aware when leaving DMI’s site, and to read the privacy statements of each and every website that collects Personal Data.

Security

DMI has global hosting centers that store and process Personal Data in various locations in Europe and the United States. DMI takes reasonable precautions to protect Personal Data in these centers and in other locations in the United States from loss, misuse, unauthorized access, disclosure, alteration, and destruction. DMI also makes reasonable efforts to keep Personal Data reliable for its intended use, accurate, current, and complete. When DMI collects Sensitive Personal Data on websites or through services, DMI encrypts the transmission of that information using Secure Sockets Layer (SSL) technology. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and therefore, DMI cannot guarantee its absolute security.

Retention

DMI will retain any Personal Data collected, as described in this policy, for a maximum of 5 years or as long as necessary to provide users with required services. If users wish to request that DMI no longer use Personal Data to provide services, contact DMI at privacy@dminc.com.

DMI will retain and use Personal Data as necessary to comply with legal obligations, resolve disputes, and enforce agreements. DMI will retain Personal Data processed on behalf of clients for as long as needed to provide services to the clients.  When determining the retention period, we take into account various criteria, such as the type of Services provided to the User, the nature and length of our relationship with the User, possible re-enrolment with the Services, the impact on the services we provide to the User if we delete certain Personal Data, mandatory retention periods provided by law, and any applicable statute of limitations.

Your Rights and Choices

Marketing Communications

If you decide at any time that you no longer wish to receive marketing communications from DMI, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at privacy@dminc.com. Please be aware that, even after you opt out from receiving commercial messages from us, you may continue to receive administrative messages from us regarding the Services.

Your Data Protection Rights (EEA)

In certain jurisdictions you have the right to request access and receive information about the Personal Data DMI maintains about you, to update and correct inaccuracies in your Personal Data, to restrict or object to the processing of your Personal Data, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Data to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

Where required by law, we obtain your consent for the processing of certain Personal Data collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the “Contact Us” section below.

Use of the Services by Children

The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services. If a parent or guardian becomes aware that their child has provided us with Personal Data, they should contact us at privacy@dminc.com, and we will take steps to immediately delete that information.

International Cross-Border Data Transfer

DMI is based in the United States. Personal Data that we collect may be transferred to, and stored at, any of our affiliates, partners, or service providers, which may be inside or outside the EEA and Switzerland, including the United States and India. If you are located in the EEA or Switzerland, we comply with applicable data protection laws when transferring your Personal Data outside of the EEA and Switzerland, including to the United States where we are headquartered.

To protect Personal Data transferred from the EEA or Switzerland to the U.S. we are certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. For transfers to other regions, we implement the EU Commission’s standard contractual clauses for the transfer of Personal Data to third countries. For more information about data transfers outside the EU, and to view a copy of the model contracts for the transfer of Personal Data to third countries, visit the EU Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu_en

Updates to This Privacy Policy

Digital Management, LLC, is the entity responsible for the processing of your Personal Data. If you have any questions about this Privacy Policy, or if you would like to exercise your rights to your Personal Data, you may contact us a.

Contact Us

Digital Management, LLC, is the entity responsible for the processing of your Personal Data. If you have any questions about this Privacy Policy, or if you would like to exercise your rights to your Personal Data, you may contact us at privacy@dminc.com or:

 

One Rock Spring Plaza
6550 Rock Spring Drive
7th Floor
Attn: DMI CISO/DPO
Bethesda MD 20817
USA