DMA recognizes the importance of and is committed to protecting your privacy. This policy describes how we collect, use, and disclose personal information collected from individuals themselves or third parties, and provides information about individuals’ rights with respect to personal information. Our goal is to process personal information as necessary for our legitimate business purposes in a transparent manner. The words “our,” “us,” “we,” and “DMA” refer to DuCharme, McMillen & Associates, Inc., and its subsidiaries.
SCOPE OF POLICY
This policy applies to personal information that we collect (i) directly from you (for example, if you visit our website, sign up to receive our marketing communications, send us an email, provide us a business card, or attend an event sponsored by us), (ii) from past, existing and potential clients in the course of providing our services (for example, business contact details of client employees or personal information collected from clients’ necessary to provide our services, such as unclaimed property services), and (iii) from past, existing and potential vendors, suppliers, subcontractors and other business partners (for example, business contact details of employees of any of the foregoing) in the course of receiving services or pursuing mutually beneficial business opportunities.
This policy does not apply to information concerning our own employees or potential employees. The Employee Privacy Notice on the DMA Café (intranet) contains information for our employees. For formal applicants to one of our positions, you will be presented with the Employee Privacy Notice at the point of data collection during the recruitment process.
PERSONAL INFORMATION COLLECTION
In order to use our website, you are not required to provide us with your personal information. However, we may be unable to provide you with information you request if you do not provide us with some or all of the personal information requested via our website. You may voluntarily provide us with personal information, such as your name, email address, telephone number, company name, and other business contact information when registering for events, seminars, or webinars, or when making selections on our subscription center as to the types of information you would like to receive.
In connection with providing our services to our clients, we enter into contracts that describe the scope of services for which information is collected and used. A client that provides us with personal information of any individual (including its employees) is responsible for obtaining from such persons any consents required to provide such information to us.
We may store your name, email address, and other contact information such as company, title, phone number, and industry, in a customer relationship management tool and use it to manage our relationship with you or your company/employer.
We automatically collect information regarding visitors’ use of our website without any personal or identifying information. This information includes: the domain name from which a user accesses the internet, the date and time and duration the user was connected to the website, the internet address of the website from which a user linked directly to this website, the type of browser used to access this website and the search engine and keywords used when searching for this website. This information is in aggregate to measure website performance.
You may be able to disallow cookies by modifying the settings in your browser. If you choose not to accept cookies, you may be unable to access certain parts or pages of our website.
We or our digital media service providers also use web beacons, a small transparent image also referred to as a tracking pixel, to help us better understand the effectiveness of our content and advertisement, the interests of our visitors, and to improve visitor experience on the website. These beacons allow us to determine which visitors have come to the website after viewing an advertisement we have served on third-party websites. We also work with such third parties to collect data so that we can determine the effectiveness of our ads and serve ads targeted to your interests. The use of web beacons does not provide us with any personal information, and we do not use this technology to access your personal information. It is used only to compile aggregated data about visitors to the website.
Web beacons do not place information on your device, but may work in conjunction with cookies to monitor activity. You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.
In some of our newsletters and other email communications, we may monitor recipient actions, such as email open rates through embedded links within the messages. If you do not wish us to confirm whether you have opened, clicked, or forwarded our email marketing communications, you will need to unsubscribe, as it is not possible for us to send these emails without tracking enabled. Registered subscribers can update their subscription preferences at any time by following the instructions in the individual email communications you receive from us.
USE, DISCLOSURES, AND TRANSFERS
We use the personal information we collect in the course of conducting our business to, among other things:
- Fulfill your requests or any other purpose for which you provided information to us.
- Provide invitations to or register you for events, seminars, or webinars.
- Provide newsletters and marketing information to you.
- Provide continuing professional education (CPE) to you, which may include sharing your personal and CPE information with the appropriate professional organizations so that you receive CPE credit.
- Respond to your inquiries, process your requests, investigate and address your concerns, and monitor and improve our responses.
- Help maintain the safety, security, and integrity of our website, products, services, and other technical assets and business.
- Improve or modify our website.
- Update and maintain client, subscription, or email lists and for other internal purposes.
- Deliver our products and perform our services.
- Receive products and services from third parties.
- Provide communications about our products and services.
- Respond to requests for information or requests for proposals, or provide information about products or services you request.
- Respond to lawful requests for information through court orders, subpoenas, warrants, and other types of legal process or obligations.
- Establish, exercise, or defend legal claims.
We will only disclose personal information to others for a business purpose and when we are legally permitted to do so. When we disclose personal information to others, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality, and security standards.
We may share your information in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
DMA may process and store your data in your region, or we may transfer it to the United States or to other countries in which we have affiliates or service providers. Any technical information from the browser of your computer, tablet, or mobile device will be transferred out of your country and into the United States. We may transfer data from the European Economic Area to other countries, and when we do, we use legal mechanisms like contracts to make sure there is an adequate transfer mechanism in place.
The security of your personal information is important to us. We seek to use reasonable and appropriate safeguards to protect your information, which includes physical, technical, and administrative measures. However, no method of transferring data over the internet or storing electronic data is entirely secure, so while we strive to use reasonable means to protect your personal information, we cannot guarantee security against all threats.
If you would like to opt out of receiving promotional or marketing email from us, you may use the “unsubscribe” or “opt-out” mechanism included in each marketing email, or you may opt out by visiting our subscription center at https://dmainc.com/newsletter. Please be aware that your option to not receive promotional and marketing email from us does not preclude us from corresponding with you by email or otherwise regarding your existing relationship with us.
Any personal information a resident of Canada provides to us is protected under the federal Personal Information Protection and Electronic Document Act or British Columbia’s or Alberta’s Personal Information Protection Act. If there is a discrepancy between any of the provisions of this policy and the requirements of the aforementioned laws involving an individual who is a resident of Canada, the applicable law shall govern our obligations and responses.
Any information you provide via our website and any technical information from the browser of your computer, tablet, or mobile device will be transferred out of Canada and into the United States. If you do not want any personal information to be transferred to the United States, please do not provide that information to us via our website or otherwise.
By completing a form on our website, you may be consenting to receive from DMA “commercial electronic messages” (as such term is defined in Canada’s Anti-Spam Legislation (2010 S.C., ch.23 (Can.)) (“CEMs”), in such forms and containing such content as DMA may determine appropriate. You may withdraw consent to the receipt of DMA CEMs at any time by contacting DMA at firstname.lastname@example.org.
In addition to the rights set forth in this policy, if you are an individual who is a California resident, you have certain additional rights under California law.
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
|The Right to Access/Know
|You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
|• The specific pieces of personal information we have collected about you;
|• The categories of personal information we have collected about you;
|• The categories of sources of the personal information;
|• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
|• The categories of personal information about you sold about you (if any), and the categories of third parties to whom the information was sold; and
|• The business or commercial purposes for collecting or, if applicable, selling the personal information.
|The Right to Request Deletion
|You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
|The Right to Opt Out of Personal Information Sales
|You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. Note that DMA does not sell personal information.
|The Right to Non-Discrimination
|You have the right to not be discriminated against for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.
|“Shine the Light”
|California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).
To make a request described above, you or your authorized agent may either call us at 1-800-309-2110 or use our Data Subject Access Request web form.
An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.
INDIVIDUAL RIGHTS IN CERTAIN CIRCUMSTANCES
In certain circumstances under applicable law, you may have the right to access your personal information (including in a portable format if so requested), to correct your personal information, and/or to delete your personal information. To submit a request relating to any of these rights, please use our Data Subject Access Request web form. Applicable law may also give you the right to lodge a complaint with the data protection authority in your country.
We understand the importance of protecting children’s privacy, especially in an online environment. Our websites are not intentionally designed for or directed at children under the age of 13 years. It is our policy never to knowingly collect or maintain information about anyone under the age of 13.
If you have any questions or comments about this policy, please submit them using the Contact Us option on our website.