Last Updated: September 28, 2021
Table of Contents
“Personal Information” means any information about an individual from which that person may be identified. For example, it may include your name, telephone number, email address, or payment information, and in some jurisdictions your IP address. It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).
Information Collected Directly
When you visit the Site, We may collect the following information:
Information Collected Indirectly
Cookies and Similar Technologies
We or authorized third parties collect certain information by automated means using cookies, web beacons, and server logs for analytic purposes. Ditto tracks users use of the Site, but does not track users across third party websites. A cookie is a small text file that is stored on a user's computer for record-keeping purposes. When you visit or access the Site, we may by means of cookies, beacons, tags, scripts, and/or similar technologies automatically collect technical information about the devices and software you use to access the Site, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. Typically, all technical, analytics, and usage information is gathered by Ditto in anonymous form and does not identify you personally.
We use both session ID cookies and persistent cookies. These technologies (or a combination of them) are used to help us:
You may manage your cookie preferences as further explained in Your Choices.
Ditto uses your personal information in the following instances:
Aside from disclosing your information to those of our personnel who are authorized to process the information in order to provide the Site and Service and who are committed to confidentiality, we disclose your Personal Information only to the third parties as described below.
Third Party Service Providers
We share Personal Information with third parties that provide services to help us provide the Site and operate our business. Depending on how you use the Site or Services , the following categories of third parties collect data on our behalf or receive Personal Information:
For a list of all third-party service providers we use, please contact us. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions, unless the data is rendered fully anonymous.
Affiliates and Subsidiaries
Ditto may disclose your Personal Information that we have received through your usage of the Site or Services without your consent when we believe in good faith that the disclosure is required to comply with applicable law or respond to lawful requests or legal processes (such as a subpoena, warrant, court order, etc.) for the purpose of assisting law enforcement and legal authorities in the prevention, detection or prosecution of crime.
If you have opted in to receive direct marketing emails from us, we may use your Personal Information to send you marketing information about the Site, Services and our products that we think may be of interest to you. For instance, when you request additional information regarding the Site, Services and/or our products and services or sign up for our newsletter, we may ask if you wish to opt in to receive marketing communications from us. This is what we call direct marketing. We carry out direct marketing by email and phone. We obtain consent to send you such communications where required under applicable local laws.
If you no longer wish to receive marketing communications, you have the right at any time to opt out. The easiest way to opt out is to use the unsubscribe link that you will find at the bottom of each communication. You may also manage your direct marketing preferences as further explained in Your Choices.
Updating and Correcting Personal information
If you would like to correct or update certain Personal Information (such as your contact information) please contact us at email@example.com and we will use reasonable efforts to correct and/or update such information.
You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner in accordance with applicable law.
Cookies & Targeted Advertising
With respect to your choices regarding cookie and other tracking technologies, most web and mobile device browsers automatically accept cookies; however, you may manage your cookie preferences, by altering the cookie settings in your browser settings at any time.
While tracking is widespread over the internet, there are things you can do to minimize these activities, as explained here:
You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site. In addition, please note that even if you opt out of targeting/advertising cookies using the mechanisms above, advertisements may still be visible to you when using the Site.
Ditto does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use our Site.
Under certain circumstances, you may have rights under applicable data protection laws in relation to your Personal Information.
Where applicable, you may have the right to:
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights listed above), and Ditto does not discriminate based on whether you choose to exercise your choice and rights. We will not, based on your exercise of rights, deny our Services to you, charge you different rates, provide a different level or quality of Services to you, or suggest that you may receive such different treatment. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights).
This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. As part of the verification process, we match the information submitted as part of your request against information stored by Ditto. In some instances, we will require additional information in order to verify your request. If an authorized third party makes a data subject request on your behalf, we will require sufficient written proof that you have designated them as your authorized agent. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to lodge a complaint with a data protection authority if you consider that the processing of your Personal Information infringes applicable law. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
Your Personal Information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.
In order to determine the most appropriate retention periods for your Personal Information, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your Personal Information, and applicable legal requirements.
In some instances, we may choose to anonymize your Personal Information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the Personal Information can be linked back to you or any specific user.
We have put in place reasonable and appropriate security measures designed to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, we use encryption, secure socket layer, firewalls, and password protection. In addition, we limit access to Personal Information to those employees, agents, contractors and the third parties who have a business need-to-know. Please do not disclose your account password to unauthorized people.
We also have procedures in place to deal with any suspected data security breach, and we will notify you and any applicable regulator of a breach where required to do so. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and while we take reasonable steps to provide secure services, by using the or Services, you understand and assume the risks associated with your activities on the internet.
Ditto does not collect any payment information in connection with the use of the Site. Payments for the Services, if any, may be processed through a third-party payment processor as set forth in the Ditto’s Terms of Service.
Ditto does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, and biometric data to use the Site or Services.
Use of the Site and Services are not intended for individuals under the age of 16. Without limiting the foregoing, Ditto does not target the Site or Services to persons under the age of 16 and does not knowingly collect Personal Information from minors. Therefore, we ask you not to provide us with Personal Information of persons under the age of 16. If we learn that Personal Information of persons under 16 years of age has been collected on or through the Site or Services, then we may terminate access to the Site or Services, and/or make the content inaccessible.
Your Personal Information may be transferred and stored in countries outside the European, that are subject to different standards of data protection. Ditto will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, including through the use of standard contractual clauses. Additionally, Ditto uses a limited number of third-party service providers to assist us in providing our services to customers. These third parties may access, process, or store Personal Information in the course of providing their services. Ditto obtains contractual commitments from them to protect your Personal Information.