1) Information That We Collect On Our Own Behalf.
a) We collect personally identification about you such as your name, address, phone number, e-mail address, or similar information when you create an account. If you decide to purchase a product or subscription from us, we or a third-party payment gateway will collect your payment information. If you visit Direct Effect, LLC’s websites, we may receive certain information about you as described in this Policy. We may use this information to send promotional or service related emails about your account. If you wish to no longer receive these e-mails, you can opt out of them by simply canceling your account.
a) We may collect data on behalf of our customers to gauge the behavior or the visitors of our customers’ websites or mobile applications. When you visit such websites or mobile applications, we may receive certain information about your behaviors such as page content, click/touch, movement scroll, and keystroke activities. If you are located in the European Union, your IP address, keystroke activity, and personal information are never stored or shared with any third-parties.
b) We collect information under the direction of its customers and has no direct relationship with the individuals whose data it may process. If you are a customer of one of our current customers and would no longer like to be tracked by such customer, please contact the respective customer directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the individual service agreements with our customers.
c) An individual who is a current or former Direct Effect, LLC customer who seeks access or wishes to correct, amend or delete inaccurate data should direct his/her query to Jonathan@DirectEffectTherapy.com. An individual who is a client of a current or former Direct Effect, LLC customer who seeks access or wishes to correct, amend or delete inaccurate data should direct his query to the respective customer first and then if no response is obtained or such response is not satisfactory, should Jonathan@DirectEffectTherapy.com. If we receive a request under this provision, we will acknowledge it within seventy-two (72) business hours and handle it promptly.
We will retain personal data we process on behalf of our customers for as long as needed to provide our services. Direct Effect, LLC will retain this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
3) Information We Collect on Behalf of Third Parties.
a) Technologies such as cookies, beacons, tags, and scripts are used by our partners, affiliates, analytics or service providers. These technologies may be used in analyzing trends, administering the Sites, tracking your movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis.
A) How We Use Your Information.
i) We use the information that we collect to operate and maintain our Sites and Service and to respond to your questions and concerns. The legal basis is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR). ii) If you have given your consent, we use the information that we collect to send you marketing communications in our newsletter. The legal basis is art. 6(1)(a) of GDPR. iii) We also use the information that we collect to help our customers improve their website(s).
B) How We Share Your Information.
ii) We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain of our Services and those of our partners. Our partners also have the option to publish the results for their websites on our Service. Such results consist solely of non-personally identifiable information. If you choose to publish such results on our Service or Site (for example, in a results gallery), you understand and agree that this information, along with any personally identifiable information you choose to make available in connection with such results, will be made publicly available. By publishing your results on our Service or Site, you agree that you have obtained all necessary consents to make such information public and that doing so will not violate any laws. If you remove information that you have made public on our Service or Site, copies may remain viewable in cached and archived pages of our Service or Site, or if other users have copied or saved that information. Non-personally identifiable information may be stored indefinitely.
iii) Direct Effect, LLC will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Direct Effect, LLC, our users or others.
iv) We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses and other User information related to our Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information during corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
v) We may, from time to time, display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at Jonathan@DirectEffectTherapy.com.
C) Storage and Processing. Your information collected through our Service may be stored and processed in the United States, Europe, or any other country in which Direct Effect, LLC or its subsidiaries, affiliates or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or European Economic Area, please note that we will not transfer information, including personal data, to a country outside of the European Union or European Economic Area.
D) We are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to us or guarantee that your information on our Service may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as login credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at Jonathan@DirectEffectTherapy.com. We use an outside help platform, and a credit card processing company to bill you if you purchase services. These companies do not retain, share, store or use personally identifiable information for any other purposes.
E) We self-certify our compliance with EU-US Privacy Shield at the U.S. Department of Commerce. We comply with the EU GDPR framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. We have certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access, and enforcement.
F) If personal information is compromised as a breach of security, we will promptly notify our customers in compliance with applicable law.
G) Our current customers can review, correct, update or delete inaccuracies to the information about you that we keep on file by logging into your account to update your password and billing information. Alternately (for data subjects tracked by us and our former customers), you can contact us directly at Jonathan@DirectEffectTherapy.com. We will acknowledge your request within seventy-two (72) hours and handle it promptly. If you wish to opt-out of being tracked by our analytics software, you can do so at Jonathan@DirectEffectTherapy.com. Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.
H) Our Retention Of Your Information.
a) If you have an account with us, we will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
b) If you are a visitor to our Sites we will retain your information for as long as necessary but no longer than one (1) year after your last visit to our Sites.
I) Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 13. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at Jonathan@DirectEffectTherapy.com.