Last updated on November 23rd, 202o.
A quick summary: this document explains:
- what information we and our partners collect when you use DDM’s services;
- where that information is stored and how it is protected;
- how we use that information;
- how long we retain that information; and
- your rights in relation to that information.
- About Us. We are Digital Development Management, Inc. (incorporated and registered in the state of Delaware) of 16192 Coastal Highway, Lewes, Delaware, 19958-9776, County of Sussex, United States of America as well as the DDM group of companies (“DDM”).
2. WHAT INFORMATION IS COVERED?
- What information might we collect from you? When you sign up for, download or use the DDM Services then we will collect certain information from you. The information that we collect varies depending on the particular DDM Services used, but this may include:
- Technical Details. When you use or access the DDM Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any device identifier; your operating system, browser type or other software; and your hardware or other technical details.
- Your Activities. When you use or access the DDM Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences and time spent on the DDM Services.
- Your Communications. If you contact us (e.g. via email or call for customer support) or post on areas of the DDM Services, we may collect and maintain a record of your contact details and the content of your communications.
- Newsletter. If you sign up to a newsletter, you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable DDM Services and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.
3. WHERE IS YOUR INFORMATION STORED?
We will store your information in Europe where possible. We will do our best to keep this information secure. No information security system is perfect so please remember to be careful.
All information we hold is stored on our secure servers which we own or license from appropriate third parties. We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.
4. HOW IS YOUR INFORMATION USED?
We will use your information to run, maintain and improve the DDM Services as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may share information with partners in order to run our services.
- How might your information be used? We may use the information above in order to (for example):
- Perform our agreement with you: provide the DDM Services to you, including: to carry out our obligations arising from any contracts between you and us; allow you to participate in interactive features of the DDM Services when you choose to do so; and provide you communication systems.
- For our legitimate commercial interests: monitor the performance of the DDM Services; provide the DDM Services; ensure that the DDM Services are presented in the most effective manner for you and your device(s); enforce our Terms of Service and other policies; notify you about changes to the DDM Services; provide, maintain, protect and improve the DDM Services; and to protect DDM and DDM Services users.
- Comply with our legal obligations: where we are required to do so by law; and comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
- Based on consent: provide you with marketing information about products or services that you request from us or which we feel may interest you where you have asked us to do so.
- Will we ever share any of your information with other parties?
- We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
- We may engage third party service providers in the course of providing the DDM Services to you (e.g. data storage, server hosting, customer and technical support, analytics, etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
- We may share your information within the DDM company group for the purpose of providing the DDM Services.
5. HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?
You have the option to share your own personal information with other parties, in which case it will be governed by those parties’ own privacy policies – make sure to take a look at them.
6. DATA RETENTION
We retain your information for as long as needed to provide the DDM Services to you or longer where permitted by law.
How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all DDM Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records and enforce our agreements.
7. YOUR RIGHTS
You have rights about how your personal information is used, which can vary depending on where you live. If you have any questions, please contact us at email@example.com.
- What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the new GDPR) you have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain DDM Services may no longer function properly or be completely unavailable to you (even services that you have paid to use).
- Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Digital Development Management, Inc. at PO Box 180, Northampton, MA 01061, United States of America. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.
- Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact: firstname.lastname@example.org.