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PRIVACY POLICY

Hodgman Enterprises dba Direct Connection (DirectConnectionMail.com) has created this Privacy Policy in order to demonstrate our commitment to privacy to our customers and users of this website. This Privacy Policy governs the manner in which DirectConnectionMail.com uses, maintains and discloses information collected from its customers and users of its website.

 

Key Terms:

  • We, us, our: DirectConnectionMail.com or Hodgman Enterprises dba Direct Connection

  • Data Protection Officer: Data Protection Officer of Hodgman Enterprises dba Direct Connection (dcmnotice@directconnectionmail.com)

  • Personal information: Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.

  • Sensitive personal information: Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.

  • Biometric Information: An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

Children

DirectConnectionMail.com does not knowingly collect personal information from customers under 18. DirectConnectionMail.com understands, however, that parents, guardians, or other adults often register our products for family use, including use by minors. Because some information is collected electronically, it may appear to be that of the registered DirectConnectionMail.com customer, and will be treated as such by this Privacy Policy. If we learn that a customer under the age of 18 has submitted personal information to DirectConnectionMail.com we will attempt to delete the information as soon as possible.

 

Information We Collect

DirectConnectionMail.com may request or collect personal information from online users in a variety of ways, including through online forms for ordering products and services, and other instances where users are invited to volunteer such information. The data we collect is information that identifies you personally. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:

 

  • Your name

  • Gender

  • Date of Birth

  • Postal address

  • E-mail address

  • Telephone number

  • Credit card information

  • Other billing information

 

We save this information so that it can be available to you to be used for such purposes as customer authentication.

 

You can modify your personal information at any time by logging in to your account at DirectConnectionMail.com and navigating to My Account -> Personal Data.

 

To delete your account in its entirety, please navigate to My Account and follow the instructions under “Delete Account.” For more information on managing your account see the help section in your DirectConnectionMail.com account. DirectConnectionMail.com may also collect information about how users access the website using a tracking ID unique to each user through the use of cookies.

 

What are Cookies?

A cookie is a piece of data stored on the user's computer tied to information about the user. We may use both session ID cookies and persistent cookies. Third parties may also be placing and reading cookies on your browser, or using web beacons to collect information in the course of advertising being services on our website. For session ID cookies, once you close your browser or log out, the cookie terminates and is erased. A persistent cookie is a small text file stored on your computer’s hard drive for an extended period of time. Your browser’s help file contains information and instructions for removing persistent cookies. Session ID cookies may be used by DirectConnectionMail.com to track user preferences while the user is visiting the website. They also help to minimize load times and save on server processing. Persistent cookies may be used by DirectConnectionMail.com to store whether, for example, you want your password remembered or not, and other information. Cookies used on the DirectConnectionMail.com website do not contain personally identifiable information.

 

Log Files

Like most standard websites, we use log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. However, none of the information stored in our log files, including but not limited to IP addresses, is linked to personally identifiable information.

 

How We Use and Share this Information

DirectConnectionMail.com may use the personally identifiable information collected by DirectConnectionMail.com to contact customers regarding products and services offered by DirectConnectionMail.com and, to the extent the user has agreed to it, by its trusted affiliates, independent contractors and business partners. We may also use this information and share it with trusted third parties for research purposes regarding the effectiveness of our website services, marketing, advertising and sales efforts, and to create links between two or more customer devices. DirectConnectionMail.com will not share this information with a third party for a third party’s marketing purposes unless you specifically authorize such information sharing. DirectConnectionMail.com does not sell or rent your contact information to third parties.

 

Furthermore, DirectConnectionMail.com may use this information collected by DirectConnectionMail.com for:

 

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

  • Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes;

  • Debugging to identify and repair errors that impair existing intended functionality;

  • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with;

  • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, customer account authentication, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider; Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer; Undertaking internal research for technological development and demonstration;

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;

  • For our group companies, including centralizing file data, facilitating the provision of our services, or protecting our rights, privacy, safety or property, or the property of our affiliates, you or others, in connection with a sale or a business transaction;

  • To comply with our legal and regulatory obligations, public authority, government and law enforcement agencies;

  • For the performance of our contract with you or to take steps at your request before entering into a contract;

  • For our legitimate interests or those of a third party;

  • Where you have given consent.

 

Third party cookies and tracking

We allow third-party companies to serve ads and/or collect certain anonymous information when you visit our website. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third-party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit network advertising.

 

Disclosure of Information

DirectConnectionMail.com may disclose your personal information as it deems necessary, in DirectConnectionMail.com’s sole discretion, to:

(a) comply with legal process or other legal requirements, including but not limited to responding to civil or criminal subpoenas, search warrants, national security letters, court orders, or other requests for information from law enforcement officials;

(b) protect and defend the rights or property of DirectConnectionMail.com or its officers, agents, affiliates, licensees, and customers; or

(c) carry out its obligations under or enforce this Agreement or to assign its rights under this Agreement.

DirectConnectionMail.com may from time to time use third-party technology and/or engage third parties, including its own subsidiaries and affiliated companies, to preserve, analyze or otherwise store or process data received by DirectConnectionMail.com from its customers. Such third-party service providers are required to treat all such data with the same degree of care as DirectConnectionMail.com and are prohibited from disclosing such data to any other person or party, except as otherwise provided for in this Privacy Policy.

DIRECTCONNECTIONMAIL.COM RESERVES THE RIGHT (SUBJECT TO APPLICABLE LOCAL LAW), IN ITS SOLE DISCRETION, TO MONITOR YOUR ACCOUNT, INCLUDING BUT NOT LIMITED TO THE USE OF A USER'S MAIN ACCOUNT AND ANY SUB-ACCOUNTS, FOR THE PURPOSE OF INVESTIGATING VIOLATIONS OF THIS AGREEMENT OR TO ASSIST WITH CRIMINAL OR CIVIL INVESTIGATIONS.

DirectConnectionMail.com may also disclose aggregate, anonymous data based on information collected from users to trusted third parties, investors, and potential partners. In such cases, only statistical information will be disclosed and personally identifiable data will be kept confidential. In case DirectConnectionMail.com is sold, the information collected from users may be transferred to the new owners.

 

We may also collect information from the following categories of sources:

  • Publicly accessible sources (e.g., property records);

  • Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);

  • Cookies on our website;

  • Automated information collection;

  • Our IT systems, including:

  • Door entry systems and reception logs;

  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

 

Special Offers and Updates

On rare occasions, it is necessary to send out a strictly service-related announcement, if, for instance, our service is temporarily suspended for maintenance. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

 

Maintenance of Information

The information provided to DirectConnectionMail.com is saved indefinitely and may be stored on one or more databases directly or indirectly maintained by DirectConnectionMail.com. Direct Connection employs industry-standard security measures to protect the confidentiality of the information. While we cannot guarantee that loss, misuse or alteration of data will not occur, we make every effort to prevent such occurrences.

 

Your Responsibility

You are responsible for the security of your Customer ID and passwords. Make sure you keep them in a safe place and do not share them with others. Always remember to log out after your session ends to ensure that others cannot access your private personal information. You should take this precaution even if you are not using a public computer, such as at a library or internet café, but even when using your private computer in your home.

 

Your California Privacy Rights

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

 

  • The categories of personal information we have collected about you, including sensitive personal information;

  • The categories of sources from which the personal information is collected;

  • Our business or commercial purpose for collecting, selling, or sharing personal information;

  • The categories of third parties to whom we disclose personal information, if any; and

  • The specific pieces of personal information we have collected about you.

 

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

  • Provide the personal information to you more than twice in a 12-month period.

 

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

 

  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and

  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

 

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

 

To opt-out of the sale or sharing of your personal information click here.

 

Right to Limit Use of Sensitive Personal Information:

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;

 

To perform the following services:

  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;

  • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;

  • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and as authorized by further regulations

 

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

 

To limit the use of your sensitive personal information click here.

 

Right to Deletion: Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

 

  • Delete your personal information from our records;

  • Direct any service providers or contractors to delete your personal information from their records.

  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

 

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;

  • Debug to identify and repair errors that impair existing intended functionality;

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

  • Comply with the California Electronic Communications Privacy Act;

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us

  • Comply with an existing legal obligation; or

  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

 

Right of Correction:

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

 

 

Protection Against Retaliation:

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

 

  • Deny goods or services to you;

  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Provide a different level or quality of goods or services to you; or

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

 

How to Exercise Your Rights

 

The exercise of these rights and the access to the information provided will not lead to any discriminatory treatment, nor will it negatively affect the service. You may only make a personal information request twice in a 12-month period. We will respond within 45 days of receiving a personal information request.

 

In addition to the above mentioned and in response to the requirements of CCPA, it is our aim to extend the transparency of the information collected and shared with third parties, which is why on pages related to data protection, such as the "Privacy Policy" and/or "Data Collection", the information referred to encompasses the data processing of the past twelve months.

 

You can find more information or exercise your rights under CCPA here: Do not sell my personal information.

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