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DittoLive Incorporated Privacy Policy

Last Updated: September 28, 2021

DittoLive Incorporated (“Ditto”, “we”, “us” or “our”) is committed to the protection of your Personal Information. Please read this Privacy Policy to learn more about our privacy practices with respect to your use and access of our public facing corporate websites located at https://www.ditto.live (the “Site”) or the Ditto Cloud service and other services provided by Ditto (the “Services”), or both.

Table of Contents

  1. Introduction
  2. Changes to this Privacy Policy
  3. Data Protection Officer
  4. Information We Collect
  5. Using Your Personal Information
  6. Sharing Your Personal Information
  7. Direct Marketing Communications
  8. Your Choices
  9. Your Rights
  10. Data Retention and Security
  11. Payment Processing
  12. Sensitive Data
  13. Children’s Privacy
  14. External Websites
  15. Transfers of Personal Information Outside the European Union

1. INTRODUCTION

This Privacy Policy is intended to help you better understand how we process your Personal Information, and governs how Ditto may use, transfer, store and disclose such Personal Information in connection with your use of the Site and Services.

“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).

This Privacy Policy applies to personal information collected when you:

  • Access and/or visit the Site;
  • Access or use the Services;
  • Sign up to receive marketing materials; or
  • Directly communicate with us through the Site or Services.

BY ACCESSING OR USING OUR SITE OR SERVICES, OR SUBMITTING INFORMATION IN CONNECTION WITH YOUR USE OF THE SITE OR SERVICES, YOU ACKNOWLEDGE AND AGREE THAT YOU HAVE READ THIS PRIVACY POLICY.

2. CHANGES TO THIS PRIVACY POLICY

Ditto reserves the right to revise this Privacy Policy at any time for any reason. If we make revisions to this Privacy Policy, we will post the revised Privacy Policy prominently on the Site, with the "last updated" date revised accordingly. If we make material changes with respect to the Personal Information collected by the Site, we may also post a notice on the Site that the Privacy Policy has been updated. Where express consent is required by applicable law for the lawful collection, use, or disclosure of information about you, we will obtain that consent. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site (or any part thereof), Services, and/or your continued provision of Personal Information to us after the posting of the revised Privacy Policy will be subject to the terms of the then-current Privacy Policy.

3. DATA PROTECTION OFFICER

Ditto has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO at privacy@ditto.live. You or your authorized agent may also submit requests to exercise your legal rights by submitting a request through the Ditto support portal or by writing to or by writing to us at the following address: DittoLive Incorporated, 548 Market Street PMB 20272, San Francisco, CA 94104, Attn: Privacy Team.

4. INFORMATION WE COLLECT

Information Collected Directly

When you visit the Site, We may collect the following information:

  • Your identity, including your first name, last name;
  • Your email address;
  • Your Job Position and Company/Employer; and
  • Other information you may provide by filling out forms or by contacting us (such as your feedback, platforms that you are interested in using of software on or other communications with us).

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:

  • Compile statistics and analytics about your use of and interaction with the Site, including details about how and where our Site are accessed, how often you visit or use the Site, the date and time of your visits, your actions on the Site, and other similar traffic, usage, and trend data, which allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used in order to improve your experience;
  • Gather important functionality, testing, and performance data about our Site, including performance data related to the Site, such as networking activity, CPU load, and resource usage, among other relevant data;
  • Moderate user behavior on the Site, such as protecting against fraud and other inappropriate activities;
  • Gather demographic information about our user base; and
  • Perform other similar functions.

You may manage your cookie preferences as further explained in Your Choices.

Aggregated Data

In connection with your access and use of the Site and/or Services, we process “Aggregated Data”, such as de-identified statistical or demographic data. Aggregated Data may be derived from Personal Information, but is not considered Personal Information under the law if it does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific feature of the Site. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information, which will be processed in accordance with this Privacy Policy.

5. USING YOUR PERSONAL INFORMATION

Ditto uses your personal information in the following instances:

  • To provide the Site and Services to you;
  • To aid in account creation for the use of Services.
  • Deliver direct marketing communications to you regarding our products and services that we may think are of interest to you;
  • Respond to your queries and requests, or otherwise communicate directly with you;
  • Detect any fraudulent or illegal activity against you and/or Ditto;
  • Perform Site maintenance and upgrades, and enable new features;
  • To comply with a legal or regulatory obligation (for example, keeping records of our sales for tax compliance).

6. SHARING YOUR PERSONAL INFORMATION

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:

  • Hosting services providers;
  • Analytics providers;
  • Advertising and marketing partners;
  • Payment processors;
  • Other third-party service providers that help us provide features and functions for the Site; and
  • Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

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.

Business Transfers

If Ditto enters into a merger, acquisition or sale of all or a portion of its assets or business, your Personal Information may be one of the transferred assets. Should such a sale or transfer occur, Ditto will require the buyer to treat your Personal Information in a manner that is consistent with this Privacy Policy.

Affiliates and Subsidiaries

Personal information that we collect about you through the Site or Services may be shared with the employees, contractors, and agents of Ditto and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Site and Service that we offer to you. We obligate the employees, contractors and agents of Ditto and our Affiliates to ensure the security and confidentiality of your Personal Information and to act on that Personal Information only in a manner consistent with this Privacy Policy.

Legal Disclosures

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.

7. DIRECT MARKETING COMMUNICATIONS

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.

8. 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 privacy@ditto.live and we will use reasonable efforts to correct and/or update such information.

Direct Marketing

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 may download the Google Analytics opt-out browser add-on here.
  • You may turn on the Do Not Track (“DNT”) setting in your browser, which will enable your browser to send a special signal to websites, analytics companies, plug in providers, and other web services you encounter while browsing to stop tracking your activity. To turn on your DNT signal, please visit https://allaboutdnt.com/#adjust-settings. Please note that not all companies will respond to or honor DNT signals.

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.

9. YOUR RIGHTS

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:

  • Request information about how we collect, process, use and share your Personal Information (commonly known as a “right to know request”).
  • Request access to your Personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information (commonly known as a “request to be forgotten”). This enables you to ask us to delete or remove Personal Information. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply in full with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

10. DATA RETENTION AND SECURITY

Data Retention

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.

Data Security

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.

11. PAYMENT PROCESSING

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.

12. SENSITIVE DATA

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.

13. CHILDREN'S PRIVACY

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.

14. EXTERNAL WEBSITES

The Site or Services may contain links to other websites that are not controlled by Ditto (“External Websites”). By clicking on links to External Websites, the operators of the External Websites may collect your Personal Information. We are not responsible for the content or privacy practices employed by the operators of any External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies.

15. TRANSFERS OF PERSONAL INFORMATION OUTSIDE THE EUROPEAN UNION

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.