Public Privacy Policy

Information Collected

We collect personal information when you interact with our Services. Personal information is data that can be used to identify you directly or indirectly or to contact you including, but not limited to, your name, mailing address, email address, and telephone number. This policy does not apply to anonymized information as it cannot be used to identify you. The types of personal information that we may collect about you include, but are not limited to, information you provide to us, information from third parties, and information collected automatically about your use of our Services.

• Information You Directly and Voluntarily Provide to Us
• Communications. If you communicate or correspond with us by email, through postal mail, via telephone or through other forms of communication, including our customer service center, we may collect the information you provide as part of those communications. For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of DMS publications, or other services; or to keep a record of your complaint, accommodation request, and similar purposes. We have a legitimate interest in processing the personal information of those who communicate voluntarily with us so that we can provide our Services.

• Information We Automatically Collect. As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your device (computer, tablet, smart phone) and your activities, including:
• • If you access the Services through a computer, we will automatically collect information such as your browser type and version, computer and connection information, IP address, mobile device advertising identifier, Media Access Control (MAC) address pages you have visited, type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution, Internet service provider or mobile carrier’s name, connection speed and connection type, date stamp, URL of the last webpage visited before visiting our Platform, and URL of the first page visited after leaving our Platform, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, comments made, search history, type of service requested, purchases made, and information collected through cookies, pixel tags, and other technologies. For more information on the tracking technology we use, please see our Cookie Notice, which describes the cookies used on our Sites and provides information on how users can control the information they process.
  • If you access the Services through a mobile device, we may also be able to identify the location of your mobile device. We use your location information (if shared) to identify the geographic locations from which our content is accessed so that we can better understand what content topics may be most relevant in that region, and to our members generally, and to develop resources around those content topics. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

• Information from Third Parties.
• • We may receive personal information about individuals from third parties.
  • When you interact with our Services on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform, and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Sites through social media channels or when you connect the Site to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

• Information You Post on the Sites.
• • If you post information on public areas of the Sites, that information may be collected and used by us, other users of the Sites, and the public generally.

Why We Collect Your Information

We will only use your information as described in this Notice or as disclosed to you prior to such processing taking place.

To Provide and Maintain our Services.

• We will use your personal information to provide information or deliver Services that you request and to allow you to participate in interactive features of our Sites and Services when you choose to do so.

To Provide Customer Support or Respond to You.

• We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes, or issues. Without your personal information, we cannot respond to you.

To Advise You of Other Services.

• From time to time, subject to the applicable law, we may share your personal information with third parties or partners. You may opt out of having your personal information shared with third parties. If you choose to limit the use of your personal information, certain features or Services may not be available to you.

To Personalize Your Experience.

• We may also use your personal information to tailor your experience at our Sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to these preferences. We may also use this information to help us understand your needs and interests, and to better tailor our products and services to meet your needs.

To Send You Marketing and Promotional Emails.

• We may use your personal information we collect from you and third-party sources to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, to deliver targeted and relevant advertising and marketing to you, and to promote our Services. Our marketing will be conducted in accordance with your advertising / marketing preferences and as permitted by applicable law.

For Research and Development.

• We may use your information to gather analysis or valuable information so that we can improve our Services and to detect, prevent and address technical issues. We may also use your information to monitor the usage of our Site including without limitation search terms entered, pages visited and documents viewed.

For Security Reasons.

• We may use personal information to help monitor, prevent, and detect fraud, enhance security, monitor and verify identity or access, or security risks.

Other Legitimate Business Purpose.

• We may use your personal information when it is necessary for other legitimate purposes such as protecting our confidential and proprietary information.

How We Share Your Information

Except as set forth in this Privacy Policy or when specifically agreed to by you, we take care to allow your personal information to be accessed only by those who really need access in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. In general, we do not share your information with a third party for their independent use unless: (i) you request or authorize it, (ii) it is required by law, or (iii) it is in connection with a co-sponsored event. We may share personal information in the following circumstances:

Service Providers.

• We may share your information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with advertising, hosting, data analytics, information technology and infrastructure, email delivery, auditing, exam-testing, training providers and other related activities, vendors or third parties who deliver or provide goods and services or otherwise act on our behalf of or at our direction. Our service providers are given only the information they need to perform their designated functions and are prohibited from using the information we provide them for their own purposes.

Compliance with Laws or Regulatory Body.

• We may disclose your information to government authorities or third parties if: (i) required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order; (ii) we believe disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (iii) to exercise, establish or defend our legal rights.

Business Transfers.

• We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization, or similar event. We will inform any buyer that your information shall only be used in accordance with this Privacy Policy

Information Security.

We take reasonable measures to protect any personal information we may hold in order to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. In some areas of our platforms, we may use encryption technologies to enhance data privacy and help prevent loss, misuse, or alteration of the information under DMS’s control.

We cannot guarantee, however, that all information will remain secure. The Internet by its nature is a public forum. We encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your login ID and password from thirdparty access, and for selecting passwords that are secure.

Data Retention

We will retain the personal information we collect from you where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, legal, accounting or other purposes). You can request deletion of your personal information at any time (see “Your Privacy Rights and Choices” section for further information) and we will consider your request in accordance with applicable laws

When we have no justifiable business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your Choices and Privacy Rights

Listed below are choices we provide you in relation to the processing of your personal information. Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the time they access our Services, please see section 9, for more information about your choices and rights.

Marketing Communications.

• If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe link” provided in such communications. Please note that even though you have opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, and you cannot opt out from receiving these messages.

Access and Correction.

• You have the right to review and correct personal information that we have collected from you. You may exercise this right by contacting us as indicated in the “Contact Us” section. In your request, please make clear what information you would like to have changed. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request as soon as reasonably practicable. We reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or taking the action requested.

Children

We do not knowingly collect personal information data from persons under the age of 16. If you are a parent of a child under 16, and you believe that your child has provided us with information about him or herself, please contact us via the information in the Contact section below.

Changes to this Notice

We may need to update this Privacy Policy from time to time to reflect changes in our business practices, data collection practices or organization. If we make a change that we believe materially affects how we process your personal information, we will provide notice of such change on this Site or via email, at the email address we have on file for you. After such notice, your continued use of our Services will be subject to the then-current Privacy Policy. We encourage you to look for updates and changes to this Privacy Policy by checking the “Effective Date” located at the top of the new Privacy Policy.

Contact Information

If you have any questions or concerns about this Privacy Policy, please visit us at “Contact Us Today” or write to us at Direct Marketing Solutions, Privacy Officer, 8534 NE Alderwood Road, Portland, Oregon 97220-1347, USA.