• Collection and Use of Personal Information;
• Sharing of Personal Information;
• Access to Your Personal Information and Choices;
• Information About Minors;
• Security of Personal Information;
• California Privacy Rights;
• How to Contact Us.
1) Collection and Use of Personal Information
a) In relation to your use of the Services or your interactions with us, we collect and use certain personal information about you. Personal information is information about you through which you can be identified (including where you can be identified by combining the information with other information). Note that we may be required by law to collect certain personal information about you, or as a consequence of our contractual relationship with you. Failure to provide this personal data may prevent or delay the fulfillment of these obligations. We will inform you at the time your personal information is collected whether certain information is compulsory and the consequences of the failure to provide such information.
i) Information You Provide. We may collect your name, contact information, e-mail address, and any other information when you interact with us, including when you contact us or call us. We will use this information to contact you in order to answer your questions and requests and to inform you of our products and services and those of our affiliates, including personalized marketing communications. Our basis for processing this personal information is the performance of our contract with you and our legitimate interests in communicating with you. If you have applied for employment with the Company, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within the Company as well as other career development resources. Our basis for processing this personal information is the performance of our contract with you and our legitimate interests in evaluating your application materials and staying in touch with candidates.
ii) Information We Gather (e.g., Cookies). When you browse our Website, we or third parties such as online ad networks and those engaged in analytics (see “Third Party Cookies”, below) may collect information which can be used to identify your computer and its browser program or any mobile devices that you use to access the internet and their IP addresses, which we may use in order to infer your location. The information is collected by installing small text files called “Cookies” and other, similar information technology techniques (which are comprehensively referred to in this document as “Cookies”). In addition to other functions, when you subsequently visit the Website, the Cookies previously stored allow us to recognize your browser. Cookies may store unique identifiers, user preferences, or other information as described below. Our basis for processing this personal information is our legitimate interest in understanding how our Services are used, personalizing marketing communications (where applicable), and improving the Services.
iii) Information Obtained from Third Parties. In some cases, we may also receive certain categories of personal information from third parties. We will use this information to supplement information we may already have about you and to communicate with and inform you of our products and services and those of our affiliates. Our basis for processing this personal information is our legitimate interest in communicating with you and personalizing marketing communications (where applicable).
b) The Cookies installed by the Website are broken down as follows:
i) Company Cookies. These are strictly related to browsing the Website and guarantee normal use of it. Among other things, they make it possible to track your choices (the choice of language or size of typeface used), to recognize the computer or mobile device when a new connection is made and to manage a browsing session. They are also used for statistical purposes to improve the service and the use of the Website by its users as well as to generally measure the effectiveness of our Website. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent to the placement of cookies, or subsequently block cookies, some site features or functions may not function correctly, and you may not be able to access all or part of the content of our Website.
ii) Third Party Cookies. These are Cookies installed on the Website by third parties and include the following types of cookies:
• Google Analytics. We use Google Analytics cookies to allow us to see information on user website activities including, but not limited to, page views, source and time spent on our Website, traffic patterns, visit counts, and visit statistics. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
iii) Do Not Track. Some new browsers have a “Do Not Track” feature. When this feature is turned on, the Company treats this as if you had opted out of tracking your site visits through cookies which may affect your online experience on our website. To learn how to manage your browser-based settings and cookies, please visit:
• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer
c) Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
2) Sharing of Personal Information. The Company may share your personal information as follows:
a) Affiliates. The Company may share your personal information with our affiliates, including our subsidiaries, our parent company, and its subsidiaries (collectively, our “affiliates”). We may share information with our affiliates so that they can communicate with you and provide information to you about their products and services.
b) Third party or affiliated service providers. We may share your personal information with our service providers that perform services for us. For example, we may partner with companies to optimize services, or manage email communications and newsletters, etc.
c) Business Partners. Where we partner with third parties for various business purposes such as joint offerings, we may share your information with the third party consistent with the business relationship.
e) Business Transactions. In the event that we intend to sell or transfer ownership or control of any or all of our business, operations or services to a third party, we reserve the right to disclose your personal information to a potential buyer both before and after the purchase. In the event the sale does not go through, we will require the potential purchaser to not use or disclose your personal information in any manner whatsoever and to completely erase the same.
3) Access to Your Information and Choices
a) Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, deleted, restricted, or delivered to you or a third party in a usable electronic format (i.e., the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest.
b) Where we are using your personal information on the basis of your consent, and where applicable under local law, you may have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time. You also have the right to register a complaint to the appropriate data protection authority, where applicable.
• If you wish to exercise these rights, or to notify us of a change in your details, or if you have any questions about the content of this policy, please contact us at firstname.lastname@example.org or 212-929-0358 and request to speak to Dorilton Capital’s Privacy Officer or Legal Department.
• Please note that we may require additional information from you in order to honor your requests.
• You can limit the communications that the Company sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of promotional emails, we may still need to contact you with important information about your account, in accordance with applicable data protection laws (and for Canadian residents only, such will be in accordance with the Canadian anti-spam legislation). If you have any questions about your choices or if you need any assistance with opting-out, please contact us via email to email@example.com. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
4) Transfer of Personal Information Outside of Your Country
In some cases, your personal information may be disclosed, processed and stored outside your home country, including in the United States, that is not regarded as providing an adequate level of protection for personal information as the laws of your home country (for example, if you live in the European Union). If your information is transferred outside of your home country, we will take steps to put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. You may contact us about your information that may be transferred outside of your home country and the handling of your information by our service providers outside of your home country by contacting us at firstname.lastname@example.org.
6) No Information from Minors This Website is not directed to children under the age of 13. If you are a U.S. resident and under the age of 13 or a Canadian resident and you are a minor (persons under the age of majority in their province or territory of residence) (“Minor”), please do not attempt to register with us at this Website, or provide any personal information about yourself to us. If we learn that we have collected personal information from a Minor, we will promptly delete that information. If you believe we have collected personal information from a Minor, please contact us at email@example.com or 212-929-0358, and request to speak to Dorilton Capital’s Privacy Officer or Legal Department.
7) Security of Personal Information We will use physical, technical, and administrative security measures designed to protect your personal information against unauthorized access and provide for the ongoing integrity and confidentiality of your personal information. However, since the internet is not a 100% secure environment, we cannot warrant, guarantee, or ensure the security of any information you transmit to us. There is no guarantee that the information may not be accessed, disclosed, altered, or destroyed by a breach of our physical, technical, or administrative safeguards. We retain your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
• Comply with record retention requirements under applicable law;
• Defend or bring any existing or potential legal claims; and
• Resolve or otherwise address any complaints or queries relating to our Services or our business.
8) California Privacy Rights Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the consumer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2016 will receive information regarding 2015 sharing activities). To obtain this information, please send an email request to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and we may only include information on covered sharing in our response.