Introduction
DataVaultAlliance Holdings, LLC (“DVA,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services (as defined below).
This policy describes the types of information we may collect from you or that you may provide when you visit https://wwdvc.com/ (the “Website”) or offline when you are attending the WWDVC Conference (together, with the Website, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- In connection with your use of the Services.
- In email, text, and other electronic messages between you and the Website and/or DVA.
- Offline while you are attending the WWDVC Conference, including when you swipe your event badge or otherwise provide information during the WWDVC Conference.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by DVA or any third party (including Eventbrite, our registration and payment provider); or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Services. By accessing or using the Services, you agree to this Privacy Policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Website and/or the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 18
Our Website are not intended for users under 18 years of age (or the age of majority where you reside). No one under age 18 (or the age of majority where you reside) may provide any information, including any personal information, to or on the Website. We do not knowingly collect personal information from children under 18 (or the age of majority where you reside). If you are under 18 (or the age of majority where you reside), do not use or provide any information on the Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 (or the age of majority where you reside), we will delete that information. If you believe we might have any information from or about a child under 18 (or the age of majority where such child resides), please contact us at [email protected].
Changes to Our Privacy Policy
If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Services, including information:
- That identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with, directly or indirectly, you, your household, or your device (“personal information”);
- That is about you but individually does not identify you; and/or,
- About your internet connection, the equipment and personal device(s) you use to access our Website, and usage details.
Please note, however, that personal information does not include:
- Publicly available information from government records; and,
- Deidentified or aggregated consumer information.
In particular, we collect the following categories of personal information in connection with our Services:
- Identifiers – first and last name, email address, postal address, online identifier, Internet Protocol address, account name, social media account username, alias, or other similar identifiers
- Protected classification characteristics under federal law – age (40 years of older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status
- Internet or other similar network activity – browsing history, search history, information on a consumer’s interaction with the Website, advertisements, or third party websites
- Geolocation data – physical location or movements
- Sensory data – audio, electronic, visual, or similar information
- Professional or employment-related information – current and past job title, current and past employer name(s), and business address Inferences drawn from other personal information – profile reflecting Your personal preferences, characteristics, attitudes, intelligence, abilities, and aptitudes
We collect this information:
- Directly from you when you provide it to us by creating an account or using the Services.
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
- From third parties, for example, our business partners or service providers like Eventbrite.
Where information is received from a third party, such data collection is subject to that third party’s privacy policy. The terms of our Privacy Policy do not apply on any third-party website or with respect to their information collection practices. Except as otherwise required under the relevant laws and regulations, we are not responsible for the privacy practices of these third parties and their websites. We encourage you to read their respective terms of service and privacy policies if you wish to utilize these websites so that you are informed of their practices.
Information You Provide to Us
The information we collect on or through our Services may include:
- Registration information, such as username and password, language, and email address, and other information that you provide by filling in forms on our Website or otherwise in connection with the Services.
- Profile information, such as name, company name, social media account information, and profile image.
- User-generated content, including comments, photographs, audio recordings, and videos that you choose to create with or upload to the Website (“User Content”).
- Your opt-in choices and communication preferences.
- Information in correspondence you send to us.
- Information you share through surveys or testimonials or your participation in challenges, sweepstakes, or contests such as your gender, likeness, and preferences.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services, including when you scan the QR code on your attendee badge at the WWDVC Conference.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Location Information. The Services collect real-time information about the location of your device, including location information based on your IP address. With your permission, we may also collect precise location data (such as GPS).
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See the section titled “Choices About How We Use and Disclose Your Information” for information on how you can opt out of behavioral tracking on the Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically does include statistical information and personal information. The statistical information collected automatically helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Recognize you when you return to our Website.
- Identify email bounce back or send errors.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit DVA, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Information We Receive from Third Parties
We may receive the information described in this Privacy Policy from other sources, such as:
- Third-Party Services. We may collect information about you from third-party services, such as advertising partners, data providers, and analytics providers.
- Other Users of the Services. Sometimes other users of the Services may provide us information about you, including through customer service inquiries.
- Other Sources. We may collect information about you from other publicly available sources.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the section titled “Choices About How We Use and Disclose Your Information.”
Please note that our Website, to the extent they are accessed through a website and not via our mobile application, are not configured to accept and respond to web browser Do Not Track (DNT) signals. As such, if you would like to opt-out of certain specific cookies or automatic tracking technologies, you will need to do so by exercising one of the other methods described in this Privacy Policy.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Services, including our Website and its contents to you.
- To provide you with information, products, or services that you request from us when you use the Services.
- To support the social functions of the Services, including to permit you and other users to connect with each other through the Services and for you and other users to share, download, and otherwise interact with User Content posted through the Services (if such functionality is made available to you).
- To send promotional materials from us or on behalf of our affiliates, trusted third parties, and marketing partners.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To improve and develop our Services and conduct product development.
- To measure and understand the effectiveness of the advertising we serve to you and others and to deliver advertising.
- To use User Content as part of our advertising and marketing campaigns to promote the Services.
- To understand how you use the Services, including across your devices.
- To infer additional information about you, such as your age, gender, and interests.
- To help us detect abuse, fraud, and illegal activity on the Website.
- To notify you about changes to our Services or any products or services we offer or provide through it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We are committed to maintaining your trust and want you to understand when and with whom we may share the information we collect for business purposes.
Please be aware that sponsors and exhibitors of the WWDVC Conference receive your first and last name, email address, company name (if provided), job title (if provided), and phone number (if provided), as a paid benefit for sponsoring the event. WWDVC Conference sponsors and exhibitors are permitted to use this information for any purpose as they see fit but will mainly use it to contact you with marketing communications regarding their products or services and as you have otherwise expressed interest to them during the course of your attendance at the WWDVC Conference.
Additionally, when you attend the WWDVC Conference you will receive an attendee badge that displays a QR code. That QR code will allow you to interact with us, the event sponsors and exhibitors, and other event attendees. To enable that interaction, the QR code will communicate to any device that scans that QR code the following information: your first and last name, email address, company name (if provided), and job title (if provided).
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates.
- To WWDVC Conference sponsors and exhibitors as one of the paid benefits to those sponsors in connection with the event.
- To other users of the Services.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. For example, we may share your personal information with payment processors and transaction fulfillment providers in order to fulfill the services you have requested.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of DataVaultAlliance Holdings, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by DataVaultAlliance Holdings, LLC about our Services customers or users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Registration Terms and Conditions[JD1] and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DataVaultAlliance Holdings, LLC, our customers, or others.
The categories of personal information we may disclose include:
- Identifiers
- Protected classification characteristics under federal law
- Internet or other similar network activity
- Geolocation data
- Sensory data
- Professional or employment-related information
- Inferences drawn from other personal information
If you choose to engage in public activities on the Website, you should be aware that any information you share may be read, collected, or used by other users. You should use caution in disclosing personal information while using the Website. We are not responsible for the information you choose to submit.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
- Location Information. You can choose whether or not to allow the Website to collect and use real-time information about your device’s location through the device’s security settings. If you block the use of location information, some parts of the Website may become inaccessible or not function properly.
- Promotional Offers from DVA. If you do not wish to have your email address used by DVA to promote our products or services, you are not required to sign-up to receive our newsletter. If you have subscribed to our newsletter, you can opt-out by using the “Unsubscribe” (or other similar) link in the footer of each newsletter email you receive or by emailing us at [email protected]. This opt-out does not apply to information provided to DVA as a result of a product purchase, warranty registration, product service experience or other transactions.
- Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending us an email stating your request to [email protected]. Please note, however, that you are not permitted opt-out of having your personal information shared with WWDVC Conference sponsors unless required by law where you are a resident.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Residents of certain states, such as California and Nevada may have additional personal information rights and choices. Please see the section titled “Your State Privacy Rights” for more information.
Accessing and Correcting Your Information
You can review and change your personal information by sending us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents of Nevada who wish to exercise this sale opt-out rights may submit a request by email to [email protected].
Your GDPR and UK-GDPR Privacy Rights
If you are a resident of the European Economic Area or the United Kingdom, your local laws provide you with additional rights regarding our use of your personal information. The following supplements the information contained in the other sections of this Privacy Policy and applies only with respect to personal information collected from residents of countries to which the General Data Protection Regulation (“GDPR”) or UK General Data Protection Regulation (“UK-GDPR”) apply.
Cross-Border Transfers
DVA is a company located in the United States. If personal information is collected on our behalf from residents of the European Economic Area or the United Kingdom, that information may be transferred to the United States, which is not subject to an adequacy decision by the European Commission or the UK Information Commissioner’s Office. If personal information is transferred to the United States, those transfers will be subject to legal transfer mechanisms that may include the European Commission’s Standard Contractual Clauses and the UK’s International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses. DVA adopts additional measures to protect your personal information during cross-border transfers including encryption in transit.
Lawful Bases for Processing
Under GDPR and UK-GDPR, the lawful bases we rely on for processing your personal information are:
- You have given your consent to the processing of your personal information
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation
- Processing is necessary in order to protect the vital interests of you or another person
- Processing is necessary for the purposes of the legitimate interests pursued by DVA (provided that our interests are not overridden by your interests or fundamental rights and freedoms)
Where you have given your consent to the processing of your personal information, you are able to revoke your consent at any time and can do so by following the instructions in the section titled “Your Data Protection Rights” below.
Your Data Protection Rights
Under GDPR and UK-GDPR, you have the right to exercise control over your personal information, including:
- Right of access – you have the right to obtain a copy of the personal information that we hold about you, including other supplementary information
- Right to rectification – you have the right to have inaccurate personal information corrected and to have incomplete personal information completed
- Right to erasure – you have the right to have the personal information that we currently hold about you erased, subject to certain exceptions (such as if the personal information is necessary for us to comply with a legal obligation)
- Right to restrict processing – you have the right to request that we restrict the processing of your personal information in certain circumstances
- Right to object to processing – you have the right to object to the processing of your personal information in certain circumstances
- Right to data portability – you have the right to obtain the personal information we currently hold about you in a structured, commonly used and machine readable format so that you can transmit that personal information directly to another controller or you can request that we transmit that personal information for you
You are not required to pay any charge for exercising your rights under GDPR and UK-GDPR. If you would like to exercise any of these rights, you can do so by sending us an email to [email protected] with the subject line “Data Subject Rights Request” indicating which right(s) you would like to exercise. We may need to collect some additional information from you so we may verify your identity and those identity verification efforts might come from us or from a trusted vendor on our behalf.
We will only use any personal information you provide for identity verification purposes to verify your identity and to respond to your rights request. DVA will do our best to respond to your request as soon as possible and within 30 days from when your request is received. In some circumstances, we may not be able to comply with your requests within that 30-day period and, if that is the case, we will let you know that we require an extension of time to complete the request along with the reason for that extension.
How to Complain
If you have any concerns about our use of your personal information, you can make a complaint to use using the information contained in the “Contact Information” section below. We request please contact us first so we can try to resolve your concerns. We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about our use of your Personal Information.
If, however, you believe that we have not been able to assist with your request, complaint, or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority. You can find more information about your data protection authority, including their contact information, by following this link to the European Data Protection Board’s website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. You may also have a right to a judicial remedy if it is determined your Personal Information is being used illegally.
If you are a UK resident, the data protection authority is the Information Commissioner’s Office (“ICO”), which can be contacted using the below information:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Data Security
We have implemented technical and organizational precautionary measures, in accordance with industry best practices, designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, disclosure, loss, deletion, or destruction. All information you provide to us is stored on our or our trusted service providers’ secure servers behind firewalls.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures made available or incorporated in the Website.
Data Retention
We will only keep your information, including any personal information, for as long as necessary to fulfill the purposes for which we collected it, to comply with our legal obligations, or to enforce our legal rights (or as required so others may enforce their legal rights).
Except as provided elsewhere in this Privacy Policy, DVA limits access to your personal information, regardless of if it is stored electronically or in physical form, to those persons (including employees and contractors) in our organization who have a business need for such access.
Generally, the length of time we keep your information will depend on the type of information and the purpose for which we are processing it. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we are processing it and whether we can achieve those purposes through other means, and any applicable legal requirements.
At the end of the appropriate retention period, we will either delete your information from our systems completely or anonymize it so it can be used without identifying you and so we no longer have the ability to re-associate the anonymized information with you in the future, such as by aggregating the information.
If you would like more information about our retention practices, please contact us using the information provided in the “Contact Information” section below.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, or to register a complaint or concern, contact us at:
DataVaultAlliance Holdings, LLC
ATTN: DVA Executive Management Team
26 Prospect Street
St. Albans, VT 05478 USA
Email: [email protected]
