Privacy Policy

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Who we are

Our website address is: https://ddmsinc.com.

Commitment to Privacy

Your privacy is important to us. This privacy policy (“Privacy Policy”) is provided by de maximis Data Management Solutions, Inc. (“ddms”, “we”, “us,” or “our”) and aims to give you information on how ddms collects and processes your Personal Information (defined below) that we may gather and track when you use this Website (our “Site”) and sets forth our policies with respect to the collection, sharing, use (collectively, “processing”) and protection of Personal Information.

Scope of This Privacy Policy

This Privacy Policy covers the “Personal Information” we collect through our Site.

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you personally, either alone or in combination with other information available to us. Examples of Personal Information include your name, contact details, job applications, information you provide when you fill out a form to request information on our Site and information about the pages you have viewed and the path you have taken through our Site.

It does not apply to information collected by:

· Us offline or through any other means, including on any other Website operated by ddms or any third party (including our affiliates and subsidiaries); or

· Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Your Consent and other legal basis for using your Personal Information

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Agreements Governing Your Use of Password-Protected Areas of This Site

Our Site includes password protected areas, such as a customers-only area.

When you sign up to use password-protected area, you may be asked to agree to special terms governing your use of the password-protected area. In such cases, you will be asked to expressly consent to the special terms, for example, by checking a box or clicking on a button marked “I agree.” This type of agreement is known as a “click-through” agreement. If any of the

terms of the click-through agreement are different than the terms of this Privacy Policy, the terms of the click-through agreement will supplement or amend this Privacy Policy, but only with respect to the matters governed by the “click-through agreement.”

Information We Collect About You and How We Collect It

Information You Provide to Us

The information we collect on or through our Site may include:

· Information that you knowingly provide by filling in forms on our Site. The information we collect depends on how you use our Site. This includes information provided at the time of requesting further services through our Site. We may also ask you for information when you report a problem with our Site.

· Records and copies of your correspondence (including email addresses), if you contact us.

· Generally, our Site distinguish between information we need to provide you with a particular service or item or to fulfill your request (“mandatory fields”), and information that although useful is optional with respect to that particular product, service or your request. Please be aware that if you do not provide us with mandatory fields we may not be able to fulfill your request.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

· Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

· Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences, allowing us to customize our Site according to your individual interests.

· Speed up your searches.

· Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Instructions on your browser or at www.allaboutcookies.org or www.aboutcookies.org, or it located in the European Economic Area (EEA), by clicking here: www.youronelinechoices.eu/. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

· Cookie Settings on our Site. Below is a summary of the Cookie Settings on our Site. You can go to Cookie Settings on our Site to learn more and remove some ddms tracking cookies from your browser.

  • Necessary Cookies. These cookies are necessary for the Site to function and cannot be switched off in our systems.
  • Analytics Cookies. These cookies help us to understand how visitors engage with the Site. We may use a set of cookies to collect information and report Site usage statistics. In addition to reporting Site usage statistics, data collected may also be used, together with some of the advertising cookies described, to help show more relevant ads across the web and to measure interactions with the ads we show.
  • Advertisement. We use cookies to make our ads more engaging and valuable to site visitors. Some common applications of cookies are to select advertising based on what’s relevant to a user; to improve reporting on ad campaign performance; and to avoid showing ads the user has already seen.
  • Functionality. We use a set of cookies that are optional for the Site to function. They are usually only set in response to information provided to the Site to personalize and optimize your experience as well as remember your chat history.

· Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe.com.

· Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

  • Google Analytics. Our Site may use Google Analytics, which uses Web beacons to collect and store anonymous information about you, which may include the non-personally identifiable information described above. You can read Google Analytics’ privacy policy at http://www.google.com/analytics/learn/privacy.html and Google Analytics Terms of Use at http://www.google.com/analytics/tos.html
  • Our Site may use the “Demographics and Interest Reporting” feature of Google Analytics to analyze information regarding the interests and demographics of users of our websites. You can opt-out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at http://tools.google.com/dlpage/gaoptout?hl=en

Supplemental Information.

From time to time, we may supplement the information you give us with information from business partners, social media, or other sources. For example, we may obtain additional information to validate your address or information about your business. We may also supplement the information you give us with information we collect from you through other ddms Web sites, digital apps, or other channels. For example, if you are a ddms customer, we may supplement the information you provide online with information you provide in your other business dealings with ddms.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, on the Site are served by third-parties, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with Web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different Sites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

Generally, we use information that we collect about you or that you provide to us, including any Personal Information:

· To present our Site and its contents to you.

· To provide you with information, products, or services that you request from us.

· To provide you with effective customer service.

· To provide you with a personalized experience when you use or Site.

· To display personalized advertising when you visit our Site or a third party Website.

· To contact you with special offers and other information we believe will be of interest to you.

· To contact you with information and notices related to your use of our Site.

· To invite you to participate in surveys and provide feedback to us.

· To better understand your needs and interests.

· To improve the content, functionality, and usability of our Site.

· To improve our products and services.

· To improve our marketing and promotional efforts

· For any other purpose identified in an applicable Privacy Notice or other agreement between ddms and you.

· To fulfill any other purpose for which you provide it.

· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

· To notify you about changes to our Site or any products or services we offer or provide though it.

· To allow you to participate in interactive features on our Site.

· In any other way we may describe when you provide the information.

· For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this privacy policy:

· Within ddms. To our subsidiaries and affiliates where there is a “need to know” for the purposes set forth in this privacy policy.

· Our Service Providers. To our service providers, contractors and other third parties that perform services to support our business, for example, companies that provide Web site or digital app support or online advertising services to us.

· Business Transactions/Transfers. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of de maximis Data Management Solutions, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal

Information held by de maximis Data Management Solutions, Inc.’s about our Site users is among the assets transferred.

· Compliance With Laws and Protection of Our Rights and the Rights of Others. We may disclose Personal Information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

· As Described in a Privacy Notice. We reserve the right to disclose your Personal Information as described in any privacy notice posted on the Site or ddms digital app where you provide that information. By providing your Personal Information on that Site or ddms digital app you will be consenting to the disclosure of your Personal Information as described in that privacy notice.

· As Described in a Click-Through Agreement. We reserve the right to disclose your Personal Information as described in any click-through agreement to which you have agreed.

· To fulfill the purpose for which you provide it.

· For any other purpose disclosed by us when you provide the information.

· With your consent.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. In some circumstances, we give you choices about the ways we collect, use and disclose your Personal Information. If so, we may ask you to indicate your choices at the time we collect your Personal Information. You may be able to remove some ddms tracking cookies from your browser by changing the Cookie Settings on our Site. For more information see Cookie Settings on our Site.

  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own products or services, you can opt-out by unsubscribing to our promotional emails or by making your request at Contact Us and we will work to address your request as set forth under Accessing, Updating and Correcting Your Information.
  • If we have sent you a promotional email, you may also send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You may be able to opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s Site.

Accessing, Updating and Correcting Your Information

If you have created an account or a personal profile on one of our Sites, you may be able to access and update some or all of your Personal Information on your account settings or profile page. In most cases, however, you will need our help. If you wish to access, update or correct your Personal Information, please Contact Us. We will respond to you within a reasonable time and within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.

Your Rights

In some circumstances, you have a right to request the erasure of your Personal Information or for a restriction on its use, to object to its use, to receive it in a portable format or to have it transmitted to another organization. You may also request that we no longer send you direct marketing communications. If you wish to exercise any of these rights, please contact us using the contact details below.

Where you have the right under applicable law, you may complain to the relevant supervisory authority , if you think we have processed your Personal Information in a manner which is unlawful or breaches your rights. In additional to any other relevant supervisory authority, in the UK you may complain to the Information Commissioner’s Office (ICO) and in the EAA you may complain to a Data Protection Authority.

How Long Do We Retain Your Information?

We may keep your Personal Information for as long as is necessary for our business purposes, and in particular to protect ourselves in the event of a legal claim. After this period, your Personal Information will be deleted or, in some instances, anonymized. If you subsequently withdraw your consent and we have no other lawful basis to continue processing your Personal Information, we will delete your Personal Information.

Links to Third-Party Web Sites

This Site may also contain links to Web sites operated by other companies, including Websites operated by our third-party service providers, and unrelated third parties. This Privacy Policy does not apply to Personal Information collected on any of these other Web sites. When you access third-party Web sites through a link on one of our Sites, please take a few minutes to review the privacy policy posted on that site.

Children’s Privacy

Our Site and Services generally provide information solutions and, as such, our Services are intended for professionals and/or individuals over eighteen (18) years of age. We do not target

children and do not knowingly collect any Personal Information from children under the age of thirteen (13). When a user discloses Personal Information on our Site or Services, that user is representing to us that he or she is at least eighteen (18) years of age.

Data Security

Although we take commercially reasonable measures to protect the confidentiality, integrity and security of your Personal Information, we cannot guarantee the security of your Personal Information. For this reason, we urge users to take every precaution to protect their Personal Information while using the Internet.

Password Protection. Certain areas of our Site are password protected. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our Site using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our Site using a password assigned to you, even if the individual is not, in fact authorized by you. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on the Site.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

International transfers: Processing of Personal Information in Countries Outside of the United Kingdom and the European Economic Area (EAA)

ddms is an organization established in the United States. We have customers in the United States, UK and EAA, and we may transfer your Personal Information across national borders for the purposes described in this Privacy Policy. Our headquarters are in St. Paul, Minnesota in the United States of America. Your personal data may be processed in countries outside the United Kingdom and the European Economic Area (“Third Countries“), such as the United States, that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation and equivalent legislation adopted in the UK (“Data Protection Law“). We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and the Data Protection Law when it is processed in, or otherwise accessed from, Third Countries. Third Countries have different privacy laws and requirements, and some, including the United States, provide less legal protection for your Personal Information than others. Please know, however, that no matter where your Personal Information is collected, used, transferred or stored, if it was collected through our Sites, it will be processed in accordance with this Privacy Policy and any privacy notices or click-through agreements that apply to you.

With respect to Personal Information from an EEA country, please note that some of our service providers may be members of the EU-US Privacy Shield and (see https://www.privacyshield.gov/list). Alternatively, where necessary, it is our practice to

implement other means of providing appropriate safeguards for Personal Information transferred from the EEA, including the European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms.

BY USING THIS SITE, YOU ARE CONSENTING TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL INFORMATION IN OR TO THE UNITED STATES OR ANY OTHER COUNTRY IN THE WORLD.

WHERE YOU HAVE THE RIGHT UNDER APPLICABLE LAW, SUCH AS IN THE UK OR EEA, YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME BY CONTACTING US. PLEASE NOTE THAT IN THE EVENT THAT YOU WITHDRAW YOUR CONSENT, WE MAY STILL BE REQUIRED OR PERMITTED BY LAW TO COLLECT, USE AND DISCLOSE SOME OR ALL OF YOUR PERSONAL INFORMATION.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

Privacy Request Form

If you would like to request access to, correction of, or deletion of your personal data, please complete the form below.