PRIVACY STATEMENT

Effective date: 11/30/2022

DTIS has created and adopted this Privacy Statement to demonstrate our firm commitment to your privacy.

This Privacy Statement describes how DTIS, as a data controller, collects, uses, processes, and shares the personal information that we collect from you directly or via a third party, or that you provide to us through  www.DTIS.com and www.daontis.com (collectively, the “Services”). 

We encourage you to read this Privacy Statement carefully to understand our use of your Data in connection with our Services (defined below).  

We reserve the right to modify this Privacy Statement at any time. If we make any changes we will post those changes here and update the “Effective Date” at the top of this Privacy Statement. Each time you use the Services the current Privacy Statement will apply and you should review it each time you access or use the Services.

Generally speaking, “personal information” is any data that can be used to identify or contact you. However, while this Privacy Statement broadly addresses all types of personal information that we may collect, some of the data we describe below may not be considered personal information according to the data protection laws of the jurisdiction in which you reside. Therefore, you should understand that certain parts of this Privacy Statement will not apply to you depending on the laws of the jurisdiction in which you reside.

This Privacy Statement applies to the processing of personal information collected by DTIS when you: 

·  Visit our website or other online services;

·  Visit our branded social media pages; 

·  Visit our offices; 

·  Receive communication from us or otherwise communicate with us via email, phone calls or text ;

·  Register for, attend or take part in one of our events or webinars; or  

·  Act or work as a service provider or supplier to us to the extent DTIS acts as a data controller of your personal information (collectively the “Services”)

Any additional information you provide to us is voluntary. Please be aware that you can choose whether to provide us with the types of information described below.

The personal information we collect directly from you includes identifiers, professional or employment-related information, commercial information and internet activity information, among others. We collect such information in the following situations:

Information you provide to us when accessing, visiting or using the Services. When you visit our website or our offices, engage with us as a vendor or customer, or otherwise access or use the Services, we collect information you provide to us as a controller, including, but not limited to:

• Registration information. By registering on the Services, we will collect any information that you make available to us. For example, we may collect your name, physical address, social security number, and date of birth, and e-mail address.
• Third party information.  We may receive information about you from third parties that you have authorized to share such information with us. For example, if you link your social media account with our Services, we may receive information about you from your social media account.
• Communications with us. When you communicate with us in any way, such as e-mail or telephone, we will receive your contact information and any other information you choose to provide to us.
• If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival;
• If you visit our offices or attend an event, due to the COVID-19 pandemic, you may be required to provide information regarding your health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, vaccination status, testing results, and recent travel history; and
• If you are a supplier or service provider to DTIS (or work for a supplier or service provider), you may also be required to provide us with personal information such as your contact details and payment and billing information.
• If you are a client or potential client of DTIS, you may provide us with certain data where we, and not the business or other organization you represent, is the data controller, such as business contact information.
• If you provide us or our affiliates with any personal information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement.

In the event you choose not to provide us with the minimum amount of data necessary we may not be able to complete your request and you may be denied access to our services or officers. 

We may also collect information about you from other sources from publicly available information.  We may combine this information with personal information provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The personal information we collect from other sources may include identifiers, professional or employment-related information, education information and commercial information we collect such personal information from the following sources:

·  Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion, determining eligibility and verifying contact information; and

·  Another individual at your organization who may provide us with your personal information, which may include personal information to the extent you consent to providing it and sharing it, for the purposes of obtaining services and pertaining to our vendors.

Information about your use of the Services. We collect information about you passively when you visit the Services. We will combine this information with information you give to us and information we collect about you. Examples of the types of information we collect include, but are not limited to:

• Third-party plugins. We may have integrated third-party plugins in the Services, and the use of such third-party plugins results in data collection by both DTIS and the relevant third-party. For example, the Services may feature a Facebook “Like” button and other widgets, such as the “Share” button or interactive mini-programs. If you use or interact with a third-party plugin, then both the third-party company and DTIS will collect information about your access and use of the Services. Please see section 6 for further information.
• Cookies and similar tracking technologies. We use both first-party and third-party cookies, and other similar tracking technologies on the Services. A cookie is a small data file that is stored on your device and collects information such as your IP address or information about your use of and/or activities on the Services (for example, what pages you visited or on which part of our Services you spent the most time).  We may also use pixels, such as to track opening of emails. Please see section 6 below for more information.
• Log data. We collect log data about your use of the Services, which may include your IP address, IP data and the time of your access or use of the Services, page views, the referring URLs, and any other information about your activities on the Services.
• Accessing and using the Services in any other way. When you use or access the Services, we may collect information such as search terms, interactions with other users, and any other activities on the Services.

These types of passive collection may include tracking of a device across time and third-party services.  Some browsers have so-called “do not track” signals, but different browsers have different default settings and there is not an industry consensus as to what these mean.  Accordingly, we do not look for or address these signals.

Generally, we collect your personal information for the purposes of providing you with and improving upon the Services and our legitimate business interests, as set out below. If we identify any new purposes outside of the stated purposes listed below, we will update this Privacy Statement or provide you with notification as required by applicable law.

We collect and process your personal information (including, where legally permissible, special categories of personal information) for the following purposes. Where required by law, we obtain your consent to use and process your personal information for the below purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) consent (b) performance of a contract or (c) complying with a legal obligation or (d) legitimate interest) to collect and process your personal information, as further detailed below.

• Providing and promoting our website and online services (including necessary functionality): We process your personal information to perform our contract with you for the use of our website and online  services and to fulfill our obligations under the applicable terms of use and service; if we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to operate and administer our website and online services and to provide you with content you access and request (e.g., to download content from our website);
• Promoting the security of our Services: We process your personal information by tracking use of our website and other Services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the Services, , systems and applications and the security of DTIS generally, and in protecting our rights and the rights of others;
• Managing user registrations for Support: If you have registered for a customer support account with us, we process your personal information by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
• Marketing: We may contact you to market our services based on our legitimate interest of promoting our services. 
• Handling contact and user support requests: If you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone, we process your personal information to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Managing event registrations and attendance: We process your personal information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you or to perform our contract with you or where we receive your consent;
• Contract fulfillment: We may process your personal information for the purposes of fulfilling our contract with you.  We do this where it is necessary for the performance of the relevant contract;
• Employment application:  We may process your personal information for the purpose of your application for employment with the company and we do this on the basis that it is necessary to take steps for entering into a contract with you or for the performance of our contract with you.  
• Developing and improving our Services: We process your personal information to analyze trends and to track your usage of and interactions with our Services to the extent it is necessary for our legitimate interest in developing and improving our Services and providing our users with more relevant content and service offerings, or where we seek your consent;
• Assessing and improving user experience: We process device and usage data which in some cases may be associated with your personal information, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering or Services, or where we seek your consent; 
• Registering and hosting visitors to the office or at events: We process your personal information for security, health, and safety reasons, to register visitors and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices, staff and visitors and our confidential information against unauthorized access. In addition, certain health data (which may include special categories of personal information) may be processed for office visits and at events during the COVID-19 pandemic to ensure the safety and security of our visitors and employees (where legally permitted) with your consent or where necessary for reasons of public interest in the area of public health;
• Sending communications: We will process your personal information, or device and usage data, which in some cases may be associated with your personal information, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions, news or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent; 
• Compliance with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
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We will share your personal information with third parties only in the ways that are described in this Privacy Statement.

• Third parties authorized by you. We will disclose your personal information to a third party with your authorization.
• Third-party service providers. We may provide your personal information to companies that provide services to help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us, based on our instructions and in compliance with this Privacy Statement and any other appropriate confidentiality and security measures.
• Professional Advisors We may share your personal information with professional advisors acting as service providers , processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking , legal, insurance and accounting services and to the extent that we are legally obliged to share or have a legitimate interest in sharing your personal information; 
• Compliance with legal obligations. We may also disclose your personal information as required by law, such as: to comply with a subpoena or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights; to protect your safety or the safety of others; to investigate fraud; or, to respond to a government request. Where possible and legally permissible, we will consult you in advance of any such disclosure. We will reject any third-party requests for personal information that are not legally binding.
• Business transaction. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may disclose your personal information to a third party involved in the transaction as permitted by applicable law.
• Affiliated businesses. DTIS may share your personal information with affiliates to provide the services including access to the Services and to improve or develop the Services.
• Third-party plugins. Your interactions with third-party plugins are governed by the privacy policy of the company providing the third-party plugin. DTIS is not responsible for the privacy and security practices of such third parties, and it is your choice to use such third-party plugins. We encourage you to read the privacy policy of any third party you interact with on or through the Services.  

·  Protection and safety of DTIS and others. We are committed to providing a safe environment on the Services. DTIS may disclose your personal information for purposes of: fraud prevention and detection; protecting the rights, property, and safety of DTIS, you, or others; and, enforcing or applying our Terms of Use and other agreements.

·  Cookies. Please see below

We may also share anonymous or de-identified usage data the purpose of helping DTIS in such analysis and improvements to show trends about the general use of our services. 

Generally, we use cookies, web beacons, pixels and tags to: optimize and improve the Services; identify your device; distinguish you from other visitors; record your IP address to understand your use of the Services; provide user authentication; monitor and maintain information about your use of the Services; identify the name of the Services from which you linked to the Services; and, to conduct fraud prevention and management services.

COOKIES. A cookie is a small text file that is stored on a computer or device when you visit the Services. If you reject our cookies and/or similar tracking technologies, you may still use the Services, but your ability to use some or all of the Services, such as contests or surveys, will be limited. We use both session ID cookies and persistent cookies. A “session ID” cookie expires when you end your session (i.e., close your browser). We use session cookies to make it easier for you to navigate the Services. A “persistent” cookie remains on your hard drive which means that when you end your session and return to the same web Services later, the cookie information is still available. We may set a persistent cookie to store your passwords so you don’t have to enter it more than once. Persistent cookies may also enable us to track and target the interests of our users to enhance their experience on the Services. We may use the following types of cookies:

• Strictly Necessary Cookies. These cookies are essential because they enable you to move around the Services and use certain features on the Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some content cannot be provided.
• Performance/Analytics Cookies. These cookies collect information about how you use the Services. For example, a performance/analytics cookie will collect information about which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is used to improve how the Services works.
• Functionality Cookies. These cookies allow us to remember the choices you make and to tailor the Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username.

·  Targeting/Advertising Cookies. These cookies are used to provide advertisements that are more appealing to you and your interests, and to help measure the effectiveness of an advertising campaign. For example, a targeting/advertising cookie can remember that you have visited the Services, and it may share this information with other organisations, such as advertisers. This means that after you have visited the Services, you may see advertisements about our products and services elsewhere on the Internet.

·  Third-Party Cookies.  Cookies from third-party providers that fall into one of the above categories, who may use information about your visits to other websites and online services to target advertisements for products and services available from DTIS. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s privacy policy for more information on how they use cookies. One way to do that is to download and use the Ghostery browser plug-in: www.ghostery.com/ghostery-browser-extension.  We are not responsible for the completeness or accuracy of these third-party notices or the effectiveness of their opt-outs or other features or functionality.

WEB BEACONS / GIFS. Web beacons, or “clear gifs,” are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive or device, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We and our third-party service providers may employ web beacons for the reasons stated above (under “Cookies”), but primarily to help us better manage content on the Services by informing us which content is effective.

Below we describe how you can manage first-party or third-party cookies.

Our Cookies (or, “First-Party Cookies”). You can use the browser with which you are viewing the Services to enable, disable, or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please be advised that if you set your browser to disable cookies, you may not be able to access parts of the Services or the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

Third-Party Cookies. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to http://www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising entities or only receive advertising provided by specific advertising entities.  We are not responsible for the completeness or accuracy of these third party notices or the effectiveness of their opt-outs or other features or functionality.

We will retain your personal information only for as long as necessary for the purposes of providing access to the Services and related services to you, to comply with our legal obligations, resolve disputes, and enforce our agreements.

The Services have security measures in place to protect against the loss, misuse and alteration of the personal information under our control. DTIS will endeavour to use appropriate security measures including firewalls and monitoring.

However, no data transmission over the Internet or storage of data can be guaranteed as 100% secure, thus we cannot ensure or warrant the security of any personal information you transmit to or store with us, and you transfer and store such data at your own risk. You are also responsible for the security of your personal information by taking precautionary measures, such as keeping any account password confidential and using secure wireless connections.

You may disable cookies through your browser settings, but DTIS does not change the way it responds to a “Do-Not-Track” signal.

Our Services include links to, and plug-ins for, other websites and online services whose privacy practices may differ from those of DTIS. If you submit personal information to any of those third-party services, your information is governed by their privacy policies. We encourage you to be aware when you leave the Services and carefully read the privacy policy of any third-party services you visit. 

If you wish to request access to, rectification, erasure or restriction of your personal information, or object to the processing of your personal information, please email us at cscenter@dtis.com. We will respond to reasonable requests in accordance with relevant data protection laws.

You may have certain rights relating to your personal information, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

·  Access your personal information held by us;

·  Know more about how we process your personal information;

·  Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;

·  Erase or delete your personal information;

·  Restrict our processing of your personal information;

·  Transfer your personal information to another controller, to the extent possible;

·  Object to any processing of your personal information;

·  Opt-out of certain disclosures of your personal information to third parties;

·  Not be discriminated against for exercising your rights described above; 

·  Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); and

·  Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

·  Where we process your personal information for direct marketing purposes you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection 

·  Please note that Automated Decision-Making currently does not take place on our Web Services or any of the processing included in this notice.  

13. WHO ARE WE?

Services are provided by Digital Trusted Identity Services, LLC.

Complaints:

We hope you are satisfied with our use of your data. However, you have a right to complain by email to cscenter@dtis.com.

14. CONTACT US

If you have any questions about this Privacy Statement, our data handling practices, or your dealings with our Services, you can contact us at: cscenter@dtis.com.

Digital Trusted Identity Services, LLC

10201 Fairfax Boulevard, Suite 470

Fairfax, Virginia 22030