Customer Privacy Policy

Applicable To: All customers and visitors to DMI websites

Approval Date: 8/3/2016

AUTHORIZED DOCUMENTS ARE PUBLISHED ONLINE ONLY. VERIFY ANY COPY AGAINST THE ONLINE SYSTEM BEFORE USE.

Overview

This policy describes how Digital Management, LLC (DMI), and its successors, subsidiaries, affiliates, divisions, and groups (collectively “DMI”), collect, use, and disclose certain personal information or personal data that it receives from users in both the United States and the European Union (EU). In particular, DMI recognizes that the EU has established strict protections regarding the handling of EU user’s personal information, and DMI therefore has elected to adhere to the U.S.-EU Safe Harbor Privacy Principles with respect to the personal information that it receives.

DMI is committed to protecting the privacy and security of its online and offline visitors by maintaining the highest standards of confidentiality and security for all data collected from (i) website visitors, (ii) clients, (iii) subcontractors, (iv) business partners, and (v) end users (collectively “users”). This privacy policy describes what personal information DMI collects and how it is used, stored, and safeguarded.

This privacy policy applies to all visitors to the DMI corporate website and affiliated websites (www.dminc.com, www.kalvin.com, www.goldengekko.com), and information collected through service platforms and offline through other means. The use of personal information collected through DMI’s service shall be limited to the purpose of providing the service for which the user has engaged DMI.

If you have questions or concerns regarding DMI’s privacy policy or practices, contact us at privacy@dminc.com.

Policy

The following subsections detail the customer privacy policies.

Collecting Information

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

NOTE: DMI will not knowingly collect or use personal information from children younger than 13 years of age without parental consent.

  • 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 information 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 information typically found on a resume. Personal information collected from a resume may be aggregated with information from third parties when verifying the veracity of the personal information provided.
  • Public Forums and Blog Comment: Users may provide personal information 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 on DMI websites which may contain personal information. We do obtain users 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 information about users of clients, subcontractors, and business partners. 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.

Using Information

The Personal Information users provide to DMI may be used for the following purposes:

  • To evaluate the quality of DMI products
  • To provide users with information about services that may be of interest
  • To contact users
  • To help DMI conduct recruitment-related activities, evaluate a user’s interest in employment, and contact a user regarding possible employment with DMI
  • To deliver or provide products or services to the user
  • To respond to requests
  • For asset or helpdesk management
  • To access and provision mobile devices
  • To establish or maintain client and business relationships
  • To provide access to Internet or application-based activities
  • To provide data usage metrics
  • To conduct other activities as necessary or appropriate in connection with the servicing and development of the business relationship

Preventing Marketing Communication

If users do not want DMI to use their personal information data to distribute marketing communication, users can exercise the right to prevent such processing by selecting/clearing (as applicable) certain check boxes on the web pages and/or forms on which DMI collects user personal information for this purpose. Also, to the extent that users receive marketing communications from DMI, and wish to unsubscribe or otherwise stop receiving such communications, users can do so from the unsubscribe link on the email itself, or use the DMI Unsubscribe Page.

Accessing Collected Information

If users would like to have access to the Personal Information that DMI retains to correct inaccuracies or request removal of Personal Information from the blog, testimonials, or community forums, users may contact DMI at privacy@dminc.com. DMI will respond with an acknowledgement to the user’s access requests within 30 days.

In some cases, DMI may not be able to remove users Personal Information. In such cases, DMI will inform users of the inability to do so, and why.

For users with an existing relationship with one of DMI’s clients, and with whom DMI has no direct relationship, refer to the client’s website and contact the client with any such requests. DMI will cooperate as appropriate with requests from clients to assist with such responses. If the client requests that DMI remove the data, DMI will respond with an acknowledgement to the request within 30 days.

Sharing Information

DMI may share user’s Personal Information with third parties in the following scenarios:

  • When users provide personal information in connection with a job search, it is maintained in a database that is managed by a third party service provider. DMI’s service provider is authorized to use the information only in connection with hosting, managing, and maintaining DMI’s resume database.
  • DMI may provide personal information to companies that provide services on DMI’s behalf. Such companies may include a payment processor or customer service provider. These companies are authorized to use personal information in order to provide such services to DMI.
  • DMI shares personal information as required by law, such as to comply with a subpoena, or similar legal process; and when DMI believes, in good faith, that disclosure is necessary to protect DMI’s rights, protect user’s safety or the safety of others, investigate fraud, or respond to a government request.
  • If DMI is involved in a merger, acquisition, or sale of all or a portion of DMI’s assets, users will be notified via email or prominent notice of any change or ownership or uses of personal information, as well as any choices users may have regarding personal information.
  • To any third party, with user’s prior consent to do so.
  • DMI shares personal information within DMI’s family of companies. DMI has central sales functions that cross-sell different services to individual clients. Client’s names and POCs could be shared among the different DMI companies, or from the different DMI companies to this central sales organization for lead generation. Sometimes company names and POCs are shared for cross marketing purposes as well. Customer data used to support operations, either technical data, device, or employee data, will only be used by the operation center supporting that customer, and is not shared with any other business or function within DMI.

DMI will share users personal information only in ways described in this privacy policy. DMI does not sell personal information to third parties.

Collecting Non-Personal Information

The non-personal information that DMI automatically collects may be used for the following purposes:

  • Log Files: DMI gathers non-personal information automatically and stores it in log files. This non-personal information includes Internet Protocol (IP) address, browser type, language, country, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. DMI uses this information, which does not personally identify users, to analyze trends, administer the site, track users’ movements around the site, and gather demographic information about the user base as a whole.
  • 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 does not link this automatically-collected data to users’ personal information.

Using Tracking Technologies

Technologies, such as cookies, beacons, tags, and scripts, are used by DMI and partners. These technologies are used to improve website navigation, and allow DMI to see which pages were viewed most, and to track and target the interest of users to enhance their experience. Third parties may use tracking technologies to analyze trends, track users’ movements around the site, and to gather demographic information about our user base as a whole. DMI may receive reports based on the use of these technologies by these companies on an individual, as well as aggregated, basis.

DMI’s policy regarding the use of cookies is as follows:

  • Managing Cookies: Users can manage cookies by using features and functions available on most Internet browsers. For example, most browsers allow users to choose what cookies can be placed on a computer, and to delete or disable cookies. Users can find instructions for managing cookie controls on websites for particular browsers. Below are links for popular browsers:

NOTE: Disabling cookies may prevent the use of specific features on DMI sites and other websites, such as maintaining an online account.

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.

Cookies associated with the Adobe Flash Player may be removed by managing settings with Adobe. To learn more about flash cookies, including how to delete or prevent placement of flash cookies, visit: http://www.adobe.com/products/flashplayer/security/

Behavioral Advertising

DMI partners with a third party to either display advertising on the website or to manage advertising on other sites. A third party partner may use technologies such as cookies or clear gifs to gather information about user activities on those sites in order to provide targeted advertising.

NOTE: Although users may choose to opt-out of targeted ads, generic ads will still appear.

Third Party Cookies
The use of cookies by third parties is not covered by DMI’s privacy policy. DMI does not have access or control over these cookies.

Clear GIFs (Web Beacons/Web Bugs)
DMI, and/or its third-party tracking utility partner, employs a software technology called clear graphic interchange format (GIF) files (i.e., Web Beacons/Web Bugs) that help to better manage content on a site by providing information on effective content. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded invisibly on websites and are about the size of the period at the end of this sentence. DMI does not tie the information gathered by clear GIFs to users’ personal information.

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 DMIs site, and to read the privacy statements of each and every website that collects personal information.

CAUTION: This privacy policy applies only to information collected by DMI websites.

Some of DMI’s websites provide employees with access to personnel and benefits information. These sites may provide more detailed privacy or disclaimer notices, or are subject to the DMI Employee Privacy Policy which takes priority over this policy. These websites include:

Protecting Personal Information

DMI has global hosting centers that store and process personal information in various locations in Europe and the United States. DMI takes reasonable precautions to protect personal information 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 information reliable for its intended use, accurate, current, and complete. When DMI collects sensitive personal information on websites or through services, DMI encrypts the transmission of that information using Secure Sockets Layer (SSL) technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, DMI cannot guarantee its absolute security.

Retaining Personal Information

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

DMI will retain and use personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

DMI will retain personal information processed on behalf of clients for as long as needed to provide services to the clients. DMI will retain and use this personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

Modifying the Privacy Policy

DMI may update this privacy policy to reflect changes to information practices. If DMI makes any material changes, DMI will notify users by email (sent to the e-mail address specified in the account) or by means of a notice on this website prior to the change becoming effective. DMI encourages users to periodically review this page for the latest information on privacy practices.

Adhering to the Safe Harbor Framework

DMI complies with the U.S.-EU Safe Harbor framework and the U.S.-Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EU member countries and Switzerland. DMI adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

To learn more about the Safe Harbor program, and to view DMI’s certification, visit http://www.export.gov/safeharbor/.

Contact DMI

For questions or suggestions regarding DMI’s privacy policy, contact DMI by email at: privacy@dminc.com or by mail to:
DMI
6550 Rock Spring Drive
7th Floor
Bethesda, MD 20817

Quality Oversight

Quality assurance (QA) representatives are responsible for performing independent reviews and/or audits of DMI’s adherence to the privacy policy. Corporate Quality Assurance (CQA) is responsible for maintaining this policy. Suggestions for improvement may be submitted to CQA at QA@dminc.com.

Definitions of Acronyms and Terms

The following table defines terms related to this policy.

Acronyms and Terms

Term Definition
CQA Corporate Quality Assurance
DMI Digital Management, LLC
EU European Union
GIF Graphic Interchange Format
HTML Hypertext Markup Language
IP Internet Protocol
ISP Internet Service Provider
LSO Local Storage Object
POC Point Of Contact
QA Quality Assurance
SSL Secure Sockets Layer