PRIVACY POLICY
Last Updated: January 21st, 2021
Dupont Circle Solutions (“Company,” “we,” “us,” and “our”) is committed to treating your personal information with respect and sensitivity. This privacy policy (this “Privacy Policy”) explains how we may collect, store, use, and disclose information when you access or use (1) our website located at [www.DupontCircleSolutions.com] and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”); (2) our [Dupont Circle Solutions] (“Programs”); and (3) any services, content, and features made available by us through the Website or the Programs (together with the Website and the Programs, the “Services”).
YOUR ACCEPTANCE OF THIS PRIVACY POLICY
By accessing or using the Services, you consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Services.
We may revise this Privacy Policy from time to time in our sole discretion, subject to applicable law. When we revise this Privacy Policy, we will post a revised version on the Website. The revised Privacy Policy will be effective upon posting on the Website, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for your continued access and use of the Services. If you do not agree to this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of the Services. Except as otherwise expressly stated by us, your access and use of the Services are subject to the version of this Privacy Policy in effect at the time of your access or use of the Services.
TYPES OF INFORMATION WE COLLECT
When you use the Services, we may collect information that identifies you (“Personal Information”), and we may also collect information that does not identify you (“Anonymous Information”). When Anonymous Information is, directly or indirectly, associated or combined with Personal Information, such Anonymous Information will be considered Personal Information for purposes of this Privacy Policy. In addition, to the extent Internet Protocol (“IP”) addresses or similar identifiers or information are considered personally identifiable information by applicable law, we will treat such identifiers and information as Personal Information under this Privacy Policy.
Information You Provide to Us
In general, you may visit the Website without telling us who you are or sharing any Personal Information with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Information, such as [your name, email address, postal address, telephone number, date of birth, and gender]. You may decline to provide Personal Information to us, but, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all. You may also voluntarily provide Personal Information to us, such as [your educational background, personal and professional goals, and other biographical information], which may or may not be associated with your Account.
[By providing your mobile phone number, you expressly consent to receive direct dial calls, autodialed and prerecorded message calls, and text messages from us relating to our Services at that number. Third-party data and message fees may apply.]
Information Collected From Devices
When you access the Services using a computer or mobile device, including, without limitation, a desktop computer, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”), we may collect information from your Device, such as [your Device type and manufacturer, your mobile carrier, your device software version, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website]. Your behavior and activity on the Website may include, but is not limited to, [the amount of time you spend using the Services, your login and log out times.
Information Collected by Cookies and Similar Technologies
When you access or use the Services, we may place small data files on your Device that assign random, unique numbers to your Device to enable us to recognize your Device when you use the Services. These data files may be cookies, pixel tags, other local shared objects, or similar technologies provided by your browser or associated applications (collectively, “Cookies”). We use Cookies to [recognize your Device, manage and store your settings and preferences for the Services, improve the Services, offer targeted products and services to you, and collect and analyze information about your use of the Services].
Use of Cookies and Similar Technologies by Data Partners and Vendors
When you visit or log in to our Website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
The Cookies we use in connection with the Services may include the following:
Session Cookies: Session Cookies are temporary Cookies that expire and are automatically erased when you close your browser window. We may use session Cookies to grant you access to content and to enable actions that require you to be logged into your Account to perform.
Persistent Cookies: Persistent Cookies are Cookies that usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent Cookies to better understand usage patterns so we can improve the Services. For example, we may use a persistent Cookie to associate you with your Account or to remember your choices for the Services.
Third-Party Cookies: We may permit certain third parties to place Cookies through the Services to provide us with better insights into the use of the Services and user demographics [and to provide relevant advertising to you]. These third parties may use Cookies to collect information about your online activities over time and across different websites when you use the Services. [For example, we may utilize Google Analytics to analyze usage patterns for the Services. Google Analytics generates a Cookie to capture information about your use of the Services that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its Cookie]. [We may also allow third parties to display advertisements through the Services. These third-party advertisers may use Cookies to collect Anonymous Information. In some cases, we may have access to information from Cookies used by third-party advertisers through the Services, and this information may permit us to identify other websites or services that you have visited that are also associated with such third-party advertisers. The use of Cookies by third-party advertisers is subject to the respective third-party advertisers’ privacy policies.]
By accessing or using the Services, you consent to the placement of Cookies on your Devices as described in this Privacy Policy. If you prefer not to receive Cookies through the Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all Cookies, our system may issue Cookies when you access or use the Services. If you set your browser settings to refuse all Cookies, the performance of certain features of the Services may be limited or not work at all.
[In some of our email messages to you, we may use “click-through URLs” linked to content on the Website. We track click-through data to help us understand and analyze interest in topics and use of the Services.]
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties . We do not use technology that recognizes DNT signals from your web browser.
Information Collected From Third Parties
We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from [educational institutions, nominating partners, and third-party service providers].
HOW WE USE INFORMATION
We may use Anonymous Information as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve the Services.
We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to:
- provide the Services and notices related thereto
- analyze, improve, and customize the Services
- provide customer and technical support for the Services
- send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you
- detect, prevent, and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Services
- collect fees and other amounts owed in connection with the Services
HOW WE SHARE INFORMATION
We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.
We may share Personal Information for the purposes described elsewhere in this Privacy Policy and as follows:
- if you request or authorize it
- to complete a transaction or provide a service requested by you
- to our third-party service providers that provide services on our behalf, such as payment processing, data analysis, e-mail delivery, hosting, order fulfillment, infrastructure, network storage, customer service, technical support, and promotional services
- to comply with applicable laws, rules, and regulations and governmental and quasi-governmental requests, court orders, and subpoenas
- to protect our rights, property, and safety or the rights, property, and safety of our users and others
- if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy
[to allow third parties market to you]
YOUR CHOICES ABOUT YOUR INFORMATION
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
INFORMATION YOU SHARE SOCIALLY
The Services may allow you to connect and share your actions, comments, content, and information publicly or with mentors, mentees, and other Program participants. We are not responsible for maintaining the confidentiality of any information you share publicly or with mentors, mentees, and other Program participants. In addition, the Services may allow you to connect with us and share on third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those websites and services directly if you want to learn about their privacy practices.
HOW WE PROTECT YOUR INFORMATION
We have, and require our third-party service providers to have, administrative, technical, and physical safeguards in place in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we utilize may include [storing Personal Information on secured servers, transmitting Personal Information using [secure socket layer (SSL)] [Transport Layer Security (TLS)] technologies, and auditing and reviewing our data collection practices].
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.
ACCESS TO YOUR PERSONAL INFORMATION
Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. You may change your Account information at any time by updating your Account profile via the Website.
[You may ask us whether we are storing your Personal Information and you may ask to receive a copy of that Personal Information. Before sending you any of your Personal Information, we will ask you to provide proof of your identity. If we are not able to verify your identity to our satisfaction, we reserve the right to refuse to send you any Personal Information.]
PROTECTING CHILDREN’S PRIVACY
The Services are not directed, or intended to be attractive, to children younger than 13 years old. We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, do not use the Services or submit any information to us.
THIRD-PARTY LINKS
When you use the Services, you may be directed to other websites and applications that are beyond our control. We may also allow third-party websites or applications to link to the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services.
INTERNATIONAL TRANSFERS
Your Personal Information may be stored on computers and systems in the United States and other countries. By using the Services, you consent to the collection, transfer, processing, and storage of your Personal Information in such countries in the manner described in this Privacy Policy. You also acknowledge that the privacy laws of such countries may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Information.
CONTACT US
If you have any questions regarding this Privacy Policy, please contact us at legal@dupontcirclesolutions.com