We respect your privacy and are committed to protecting it through compliance with this Privacy Policy (Policy). This Policy describes the types of information we may collect from you or that you may provide when you visit the Directplus.org website (Website or Service) and any of the products and services associated with it (collectively, Services), and our practices for collecting, using, maintaining, protecting, and disclosing that personal information, as well as the choices available to you regarding our use of your personal information and how you can access and update it.

This Policy is a legally binding agreement between you (you or user) and Direct+ (Direct+ or we). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms user, you, or your shall refer to that entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access or use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to activities of companies that we do not own or control, or individuals that we do not employ or manage.

Collection of Personal Information

You may access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. However, if you wish to utilize certain features offered on the Website, you may be asked to provide particular personal information (such as your name and email address).

We collect any information that you knowingly provide to us when creating a user account or filling out any form on the Website. This information may include account details (such as usernames, unique user IDs, passwords, etc.).

Some of the information we collect from you is directly through the Website and Services. However, we may also collect your personal information from other sources such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal information collected from other sources may include demographic information such as age and gender, device information such as IP addresses, location (e.g., city and state), and online behavioral data such as information about your usage of social media websites and page view information and search results and links.

You may choose not to provide us with your personal information, but you may not be able to access certain features of the Website. Users unsure about what information is mandatory can contact us.

Children`s Privacy

We do not knowingly collect any personal information from children under 18 years of age. If you are under 18 years old, please do not send any personal information through the Website and Services. If you have reason to believe that a child under 18 years of age has provided personal information to us through the Website and Services, please contact us to request removal of that child`s personal information from our services.

We encourage parents and legal guardians to monitor their children`s internet usage and to instruct their children never to provide personal information through the Website and Services without their permission. We also ask all parents and legal guardians who supervise children to take necessary precautions to ensure that their children never provide their personal information online without their permission.

Use and Processing of Collected Information

When managing personal information, we act as both a data controller and a data processor unless we have entered into a data processing agreement with you, in which case you will be the data controller and we will be the data processor.

Our role may also vary depending on the specific situation regarding personal information. When we require you to submit your personal information, which is necessary for ensuring your access to and use of the Website and Services, we act as a data controller. In such cases, we are the data controller as we determine the purposes and means of processing personal information.

When you submit personal information through the Website and Services, we act as a data processor. We are not the owner, controller, or decision-maker regarding the personal information submitted, and this personal information is processed only in accordance with your instructions. In such cases, the user providing personal information acts as a data controller.

In order to make the Website and Services available to you or to fulfill a legal commitment, we may need to collect and use certain personal information. If you do not provide the requested information, we may not be able to provide you with the requested products or services. Each piece of information we collect from you may be used for the following purposes:

• Creating and managing user accounts
• Operating and launching the website and services

Processing of your personal information is carried out depending on your interaction with the website and services, your location, and one of the following conditions: (1) You have given your consent for one or more specific purposes. (2) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations. (3) Processing is necessary for compliance with a legal obligation to which you are subject. (4) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us. (5) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Keep in mind that under certain laws, we may be allowed to continue processing information until you object to such processing. In any case, we would be happy to explain the specific legal basis for processing, especially whether providing personal information is a legal or contractual obligation or a necessary requirement to enter into a contract.

Information Management

You can delete specific personal information that we have about you. The personal information you can delete may change with changes to the website and services. However, when you delete personal information, an unmodified copy of the personal information may be retained in our records for the time necessary to fulfill our obligations to affiliated companies and partners and for the purposes described below.

Information Disclosure

Depending on the requested services or if necessary to complete any transaction or provide any service you have requested, we may share your information with affiliated companies, contract parties, and service providers that we rely on and collaborate with (collectively, Service Providers). We do not share any personally identifiable information with third parties, and we do not share any information with unrelated third parties.

Service Providers are not authorized to use or disclose your information unless it is necessary to perform their specified tasks, and we do not allow them to use or disclose any of the information provided to them for marketing purposes or other purposes.

Information Retention

We will retain your personal information for as long as necessary to comply with our legal obligations, enforce our agreements, and resolve disputes, unless a longer retention period is required or permitted by law.

We may use any collected, obtained, or aggregated data after updating or deleting your personal information, but not in a way that identifies you. Personal information will be deleted after the retention period ends. Therefore, the right to access, delete, correct, and transfer data is not executable after the expiration of the retention period.

Data Analysis

Our website and services may use third-party analytics tools that collect information through cookies, web beacons, or similar technologies to gather standard Internet activity data and use it. The collected information is used to generate statistical reports about user activity, such as the number of user visits to the website and services, the pages they visit, and the duration of visits, etc. We use the information obtained from these analytical tools to monitor and improve our performance. We do not use third-party analytics tools to track or collect personally identifiable information of our users, and we do not associate any collected statistical report information with any individual user.

Do Not Track Signals

Some browsers have a Do Not Track feature that signals to websites you visit that you do not want your online activity to be tracked. Tracking is not just the use or collection of information related to a website. For these purposes, tracking refers to the collection of personally identifiable information from consumers who use or visit a website or online service over time, particularly across different websites. The way browsers interact with the Do Not Track signal is not yet uniform. Therefore, websites and services have not yet set up to interpret or respond to Do Not Track signals sent by your browser. However, as detailed in this policy, we limit the use and collection of your personal information.

Advertisements

We may allow some third-party companies to help us identify advertisements that we believe may be of interest to users and assist us in collecting and using other data about user activities on the website. These companies may present advertisements that may use cookies.

Links to Other Resources

The website and services contain links to other resources that are not owned or controlled by us. Please note that we are not responsible for the privacy practices of other resources or third parties. We recommend that you be aware when leaving the website and services and read the privacy statement of any resource that may collect personal information.

Information Security

We protect the information you provide to us in a controlled and secure environment, protected from unauthorized access, use, or disclosure. We maintain administrative, technical, and physical safeguards to protect against unauthorized access, use, alteration, and disclosure of personal information. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your personal information, you acknowledge that: (1) there are security and privacy limitations of the Internet beyond our control; (2) the security, integrity, and privacy of all information and data exchanged between you and the website and services cannot be guaranteed; and (3) despite our best efforts, it is still possible for information and data to be viewed or tampered with during transmission by a third party.

Since the security of personal information is to some extent dependent on the security of the device you use to communicate with us, please take necessary measures to protect this information.

Data Breaches

If we become aware that the security of the website and services is compromised or that users` personal information has been compromised as a result of external activities, including, but not limited to, security attacks or fraud, we reserve the right. We have the right to take appropriate action, including, but not limited to, investigation and reporting, as well as notification and cooperation with law enforcement authorities. In the event of a data breach, if we believe there is a reasonable risk of harm to the user as a result of the breach, we will make reasonable efforts to inform affected individuals. When we do this, we will send a notice on the website.

Changes and Revisions

We reserve the right to change this policy or its terms relating to the website and services at any time, at our sole discretion. When we do, we will revise the updated date at the bottom of this page. We may also notify you in other ways at our discretion, such as through contact information you have provided.

The updated version of this policy will be immediately enforceable upon posting of the revised policy unless otherwise specified. Your continued use of the website and services after the effective date of the revised policy (or any other action specified at that time) will be deemed to constitute your consent to the changes. However, we will not use your personal information in a manner materially different from what was stated at the time your personal information was collected without your consent.

Acceptance of this Policy

You acknowledge that you have read this policy and agree to all its terms and conditions. By accessing and using the website and services and submitting your information, you agree to be bound by this policy. If you do not agree with the terms of this policy, you are not authorized to access or use the website and services.

Contact Us

If you have any questions about this policy, the information we hold about you, or if you would like to exercise your rights, raise a concern, or make a complaint, we recommend contacting us using the details provided below:

info@directplus.org

We will endeavor to resolve complaints and disputes and will make every reasonable effort to honor your request to exercise your rights in a timely manner and within the timeframes provided by applicable data protection laws.

This document was last updated on 22 March 2024