Welcome to directtoconsumer.co (the “Site”). The Site is an Internet property of Pilothouse Digital Ltd. and its affiliated companies (“Pilothouse”, “our”, “we” or “us”). Pilothouse is committed to protecting your privacy. We have prepared this privacy policy (“Privacy Policy”) to describe to you and to outline our practices and policies associated with any information that we may collect from you, or that you may share with us when you access or use the Site, or when you use any of the related products and/or services being made available to you through the Site (the "Related Materials").
BY ACCESSING THE SITE OR USING ANY RELATED MATERIALS, YOU HEREBY ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY IN ITS ENTIRETY.
In summary:
Lawful Basis for Processing Data
In certain jurisdictions, the processing of your Personal Data (as defined below) is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:
How We Collect and Use Personal and Anonymous Data
When you access the Site, register for any associated products and/or services, or use the Related Materials in any way, we may collect Personal Data and Anonymous Data from you. The Personal Data that we collect is either (i) provided by you; (ii) collected by Pilothouse when you use the Site and/or Related Materials; or (iii) provided to Pilothouse by third parties.
“Personal Data” means data that allows someone to identify or contact you, including, for example, and without limitation:
Personal Data may be used for the purposes of recording the transaction when you access the Site, or when you use any of the associated products and/or services services, or when you use any of the Related Materials. Pilothouse does not knowingly collect any sensitive Personal Data or any data defined under special categories under Applicable Data Law (as defined below).
We may also use Personal Data for the following purposes:
If and when we use a third-party technology/services/solutions provider, we ensure that the same privacy criteria as defined herein with respect to Personal Data are in place with such third-party providers. We do not (knowingly) collect personal information from minors or children. “Minors” or “children” are persons under the age of thirteen (13), or under such age as defined under Applicable Data Law or the country’s minimum age where the person resides.
“Anonymous Data” refers to data about you that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons.
To make the Site and any Related Materials more useful to you, our servers (which may be hosted by a third-party service provider) may collect Personal Data or Anonymous Data from you such as browser type, browser settings, information about your hardware, operating system type and version, your mobile carrier or Internet service provider (ISP), domain name, Site usage and statistics, and/or a date/time stamp of your visit to the Site. We may also use cookies and navigational data like Uniform Resource Locators (URL) and referring URLs to gather information regarding the date and time of your visit. We may also use Anonymous Data for market research purposes and to improve our products and services, the Site, and any Related Materials.
We may share Anonymous Data with our affiliated companies, selected third parties and business partners, however, we will not share any Anonymous Data if such information is, contains, or will be linked to your Personal Data, unless we have given you notice, as described in this Privacy Policy, and you have given us authorization to do so. Pilothouse will use Personal Data to identify users of the Site if and when we feel it is necessary to enforce compliance with the Site’s policies or to protect our products and services, Related Materials, the Site, or other users of the Site and/or Related Materials.
Sharing and Retention of Personal Data
We will never sell, trade, or rent any Personal Data, or any Anonymous Data that may contain Personal Data, to any third party without your explicit consent.
In certain special cases, we may disclose Personal Data when we have reason to believe that using, retaining, or disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to you, or is otherwise injuring or interfering with our rights, property or operations, other users of the Site or Related Materials, or anyone who could be harmed by such activities. We may also use, retain, or disclose your Personal Data when we believe the law requires it or in response to any demand by law enforcement authorities in connection with criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.
If we determine, in our sole discretion, that you have engaged in conduct that might be considered unlawful, fraudulent, or might harm or damage the reputation or standing of Pilothouse with either the general public or with a business partner or potential business partner of Pilothouse, we reserve the right to release your Personal Data to such persons or third parties, as we consider necessary, to prevent you from causing injury to, or otherwise injuring or interfering, now or in the future, with our rights, property or operations or otherwise the rights, property or operations of anyone who could be harmed by such conduct.
We offer you choices regarding the collection, use, and sharing of your Personal Data. We will periodically send you newsletters and emails that directly promote the use of the Site, the Related Materials, and/or other products, goods, services, and software applications that may be of interest to you. When you receive newsletters or promotional communications from us, you may indicate apreference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, or by contacting us directly (please see contact information below). Should you decide to opt-out of receiving future mailings from us, you may continue to receive future mailings from third parties that you have requested to receive information from. If you do not wish to receive future communications from third-party providers, you should notify them directly of your choice regarding their use of your Personal Data. To opt-out of having future third-party marketing communications sent to you, you will be required to unsubscribe with the applicable third-party providers. Despite your request to no longer receive future newsletters or promotional and marketing communications from us, we reserve the right to continue to send you notices of any updates to the Site, the Related Materials, and this Privacy Policy.
We may also share Personal Data with our affiliated companies for customer support, marketing, technical operations, and account management purposes.
Your Rights with Respect to Your Personal Data
For the purposes of this Privacy Policy, the term “Applicable Data Law” shall mean all data protection and privacy laws, regulations and self-regulatory codes applicable to the personal data in question, including, where applicable and without limitation, the CPRA, the CPA, the CTDPA, the UCPA, the VCDPA, European Data Law, the CASL, the LGPD, and all FTC guidelines and any other applicable laws, rules and regulations with respect to data privacy.
“CPRA” as used herein means the California Privacy Rights Act (formerly, CCPA (California Consumer Privacy Act)), as amended, including without limitation any and all applicable implementing regulations. “CPA” as used herein means the Colorado Privacy Act, as amended, including without limitation any and all applicable implementing regulations. “CTPDA” as used herein means the Connecticut Data Protection Act, as amended, including without limitation any and all applicable implementing regulations. “UCPA” as used herein means the Utah Consumer Privacy Act, as amended, including without limitation any and all applicable implementing regulations. “VCDPA” as used herein means the Virginia Consumer Data Protection Act, as amended, including without limitation any and all applicable implementing regulations. “European Data Law” as used herein shall mean, without limitation, (i) the EU General Data Protection Regulation (“EU GDPR”); (ii) the EU e-Privacy Directive; (iii) the United Kingdom’s European Union (Withdrawal) Act (“UK GDPR”); (iv) the Swiss Federal Act on Data Protection (“Swiss DPA”); and (v) any and all applicable national laws made under or pursuant to (i), (ii), (iii) and (iv); in each case as may be amended or superseded from time to time. “CASL” as used herein means Canada’s anti-spam legislation, as amended, including without limitation any and all applicable implementing regulations, as may be amended or superseded from time to time. “LGPD” as used herein means the Lei Geral de Proteção de Dados, as amended, including without limitation any and all applicable implementing regulations, as may be amended or superseded from time to time. “Israeli Law” means Israeli Privacy Protection Law, the regulations promulgated pursuant thereto, including the Israeli Privacy Protection Regulations (Data Security), and other related privacy regulations, as may be amended or superseded from time to time.
In accordance with Applicable Data Law, you have the following rights in respect of any Personal Data that we may collect and hold about you:
If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy. You also have the right to lodge a complaint to your local data protection authority. In accordance with Applicable Data Law, you have certain rights with respect to the processing of your Personal Data. Under Applicable Data Law, you have a right to request that we provide you with the following:
You also have a right to request that we update or delete personal information under certain circumstances, subject to certain exceptions and requirements. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy. We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you have failed to provide us with sufficient information to verify your identity.
Authorized Agents
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Cookies and Similar Technologies
A cookie is a small piece of text that is sent to your web browser by the Site. The cookie helps the Site remember information about your visit, which makes your next visit to the Site easier and the Site more useful to you. We also use cookies for tracking and reporting purposes, to make the ads that you may see more relevant to you, and to count how many visitors we receive to a page on the Site. The information collected by cookies is used to enhance your experience with on the Site, for marketing analysis, for targeted and display advertising, and for quality improvement of the Site and any Related Materials. No personally identifiable information is collected or stored by Pilothouse during this process. We may use your IP address to identify your general location for traffic monitoring purposes. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site functionality and/or any Related Materials.
Do Not Track
If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs third-party service providers not to track your future activities when that cookie is detected (a “do-not-track” cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a “do-not-track” cookie may not be set on your computer or mobile device. Also, if you subsequently erase “do-not-track” cookies, use a different computer, mobile device, or change web browsers, you will need to opt-out again. We currently do not respond to browser "do-not-track" signals.
Third-Party Relationships
Third-party Links. The Site, our newsletters, and/or any Related Materials may contain links to other third-party owned and/or operated websites and, where you request information from third-party providers, we may transfer you directly to the websites of such third-party providers. Pilothouse is not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be required to provide certain information to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such third-party website. These third-party entities are independent third parties and are not affiliated with Pilothouse.
Third-party Offers
Pilothouse may provide you with the opportunity to receive special offers, products and/or services from third parties. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your Personal Data that was provided during that information collection process will be shared with the applicable third party so that such third party may provide their products and/or services to you without the need for you to complete another information collection form in order to purchase or receive that product or service.
Third-party Cookies
Clicking on any third party offers may add and place cookies on your computer prior to directing you to the applicable third party’s site. These third parties have separate cookie polices and Pilothouse has no responsibility or liability relating to them. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer or mobile device. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site functionality.
Third-party Technology/Software/Service/Solutions Providers
The Site, and any Related Materials being made available through the Site, may contain certain software technologies and services licensed from third-party providers. Pilothouse may engage with certain third-party services and solutions providers such as, and without limitation, data hosting service providers, payment processing service providers, traffic monitoring service providers, advertising service providers, and email marketing service providers. These third-party providers have separate privacy and data collection practices and policies, and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of the terms and conditions of any third-party privacy policies. These third-party entities are independent third parties and are not affiliated with Pilothouse.
Pilothouse may be using or sharing your Personal Data for Legitimate Interest purposes with third-party technology and service providers. For more information about these third-party service providers, please CLICK HERE.
Security of Data
Pilothouse is committed to protecting the security of any Personal Data that is collected by us. We use a variety of industry-standard security technologies and procedures to help protect any Personal Data from unauthorized access, use, or disclosure. Despite these measures, no method of transmission over the Internet, or method of electronic storage is 100% secure. Pilothouse cannot fully eliminate security risks associated with the collection and storage of any Personal Data, including without limitation, any mistakes and security breaches that may happen. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the unlikely event of a data breach where your Personal Data has been compromised, Pilothouse will promptly notify you, the applicable authorities and supervisory authorities or data protection authorities.
If you are located in the EU/EEA and Pilothouse is required to transfer your Personal Data in accordance with this Privacy Policy, we exert commercially reasonable efforts to ensure that any transfer of your Personal Data outside of the EU/EEA is protected under industry-standard contractual clauses and any subsequent data protection safeguards. Where European Data Law applies, Pilothouse shall not process its collected Personal Data (nor permit its collected Personal Data to be processed) in a territory outside of the EU/EEA unless it has taken such measures as are necessary to ensure the transfer is in compliance with European Data Law. Such measures may include (without limitation) transferring its collected Personal Data to a recipient in a country that the European Commission has decided provides adequate protection for Personal Data, to a recipient that has achieved binding corporate rules authorization in accordance with European Data Law, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.
Data Retention Period
Any Personal Data that is collected and stored by Pilothouse will be retained only for as long as required in order to provide certain products and/or services to you, or as required by applicable law and/or Applicable Data Law. Any Personal Data that is no longer required by Pilothouse will be destroyed.
Questions, Requests & Contact Information
If you have any questions regarding this Privacy Policy, would like to review, update or remove your Personal Data, or would like more information on our data collection, usage, and privacy practices, please contact us at:
Pilothouse Digital Ltd.
1011 Government St.
Victoria, BC V8W 1X6
Canada
We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you, or your agent, have failed to provide us with sufficient information to verify your identity.
Changes to This Privacy Policy
We reserve the right, in our sole discretion, to modify, update and change this Privacy Policy at any time without prior notice to you. Notice regarding any material changes to this Privacy Policy and how Pilothouse will collect and use Personal Data will be placed in a prominent location on the Site and/or Related Materials and will take effect immediately upon posting on the Site and/or Related Materials. Furthermore, Pilothouse reserves the right to update, add, and/or remove third-party service providers with whom Pilothouse may be using or sharing Personal Data for legitimate and lawful purposes without prior notice to you. Please check the Site and this Privacy Policy periodically for any changes. Your continued use of the Site and/or Related Materials following the posting of changes to this Privacy Policy, or any changes to the third-party service providers with whom Pilothouse may be using and sharing Personal Data for legitimate and lawful purposes, will constitute your acknowledgment and acceptance of any and all changes.
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