Privacy Policy

Effective date: June 5, 2020

[DHI Telecom Group] Privacy Policy

1. About This Privacy Policy

This privacy policy (the “Policy”) explains what data the DHI Telecom Group (“DHI”) collects from you through our interactions with you and through our products, services, events and programs – including our websites, apps and digital platforms (each a “Service,” and collectively, the “Services”).

By using any of the Services, you consent to the terms of this Policy.

 2. Data That DHI Collects and Receives

When you interact with DHI through the Services, DHI may collect data from you or from other sources.  This “data” may be information that you directly provide to DHI, such as personal information you provide when you visit the Services, or information that is passively or automatically collected from you, such as anonymous information collected from your browser or device.

The data DHI collects consists of:

Data that you provide directly when you register for, or use, the Services.  This data will vary, but typically consists of name, email address, postal address, phone number and other similar contact data.  DHI also receives data from the communications you send to DHI, such as customer service inquiries, product reviews and other feedback regarding the Services.

User credentials, such as username, password, password hints and similar security information used to create an account and authenticate users of the Services.

Payment data, such as credit card information and billing address.

Device data, such as type of device, operating system and other software installed on the device, device settings, IP address, device identifiers and error reports.

Usage data, and the timing, frequency and duration of your interactions through the Services.

Location data, such as IP addresses received from your device.

 3. How DHI Uses Data

DHI use the data DHI collects for the following purposes:

Operating DHI business.  DHI uses the data it collects to operate its business, including providing and improving the Services.  Specifically:

To fulfill transactions that you request.

To deliver location-based Services and comply with territorial restrictions.

To diagnose and fix problems with the Services and providing other customer support services.

For analytical purposes to better understand our customers and how they use the Services, which allows DHI to continually improve and expand the Services.

To build predictive models, which allow DHI to tailor the Services based on the data DHI has about how you use the Services.

Communicating with you.  DHI uses the data it collects to communicate with you, including responding to your requests or inquiries.  Specifically:

To respond to your request if you contact DHI with a question or concern.

To provide information about your account, your use of the Services or other transactions that you request.

Marketing and advertising.  DHI uses the data it collects for marketing or advertising purposes, on behalf of itself, as well as its partners and other parties.  Specifically:

To send you promotional messages and deliver advertisements about products, services, programs or events that may be of interest to you.  These may be offered by, or on behalf of, DHI, or by DHI’s partners and other third parties with whom DHI has a relationship.

The promotional messages and advertisements that you see may be determined by data that DHI collects or receives about you, such as your demographic data, location data, usage data, interests and preferences.  DHI refers to this as “interest-based advertising”.

Security, compliance and enforcement.  DHI uses the data DHI collects for security, compliance and enforcement purposes.  Specifically:

To protect the safety and security of DHI’s customers and DHI’s Services.

To detect and prevent abuse, fraud or other unlawful or unauthorized activities.

 

To resolve disputes.

To enforce our agreements, including DHI’s policies and terms of service that govern your use of the Services.

DHI may also use your data in any other manner as disclosed at the time of collection, or when DHI has otherwise obtained consent.  Please also note that this Policy is not intended to place any limits on what DHI does with aggregated, pseudonymized or anonymized data.

 

4. How DHI Shares and Discloses Data

There are times when DHI may share the data DHI collects from you.  DHI shares your data for the following purposes:

Providing the Services.  DHI sometimes engages or partners with other companies to operate the Services or perform certain functions on DHI’s behalf, delivering messages and advertising, operating DHI’s websites and digital platforms.  DHI may provide these companies with access to your data as needed for them to perform these functions in a manner consistent with this Policy.

Among the member companies and businesses in the DHI Group family.  DHI may share personal data among the companies within the DHI Group family for purposes consistent with this Policy.

As part of a change in business structure.  In the event of a sale, merger, acquisition, reorganization or similar event, or in contemplation of such an event (e.g., due diligence), your data may be among the transferred assets.

When necessary under certain circumstances.  DHI may disclose your personal data when DHI believes that disclosure is necessary to:

Comply with applicable law or respond to valid legal process.

Protect the safety and security of our customers or our Services.

Prevent fraud, abuse or other unlawful or unauthorized activities.

Protect DHI’s rights or property or the rights or property of DHI’s customers or third parties, including enforcing the terms of DHI’s agreements.

DHI may also share your data for any other purpose as disclosed at the time of collection, or when DHI has otherwise obtained consent.  Please note that this Policy is not intended to limit DHI’s ability to share or disclose aggregated, pseudonymized or anonymized data.

 5. What Choices You Have

You have many choices about how DHI collects, uses and shares your data.

Communications choices.  You can choose whether you wish to receive promotional messages from DHI and which types of messages you wish to receive.  If you receive promotional messages from DHI and would like to opt out, you may do so by following instructions within those messages. 

Advertising choices.  Websites that You access through the Services may permit you to opt out of interest-based advertising as described in this section and in the “Cookies and Similar Technologies” section of this Policy.  When you opt out, your selection is stored on a cookie on your device.  If you delete the cookie from that device or sign in from a different device, you will need to opt out again.

The data used for interest-based advertising is also used for other necessary purposes (including providing the Services and for authentication and security purposes), opting out of interest-based advertising does not stop the data from being collected nor reduce the number of advertisements you will see.  However, the data will not be used for interest-based advertising, which means the advertisements you do see may be less relevant to you.

When using the Services via your phone or other mobile device, the apps that You access may send You interest-based in-application advertisements.  Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your device.  In addition, each operating system (e.g., iOS for Apple devices, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements.  You may review the support materials and/or the privacy settings for the respective operating system in order to opt-out of interest-based in-application advertisements.  For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

Other choices.  You also have choices about the data you provide directly to DHI when you register for or use the Services.  Please note, however, that if you choose not to provide data that is necessary to provide certain features of the Services, your use of the Services may not include those features.

You can choose not to share certain location data by adjusting the settings on your device.  Please note, however, that if you choose not to share this data, you may not be able to access or use location-based Services.

You can choose to limit the data that third-party services (e.g., social media platforms) share with DHI using the options provided to you by the applicable third-party service (for example, the options provided by a third-party social media platform when you connect your social media account with the Services).  You can also disconnect your use of the Services from the third-party service at any time using the options provided to you by the applicable third-party service.  Please note, however, that if you disconnect from the third-party service, that will not delete the data DHI may have previously collected while you were connected.

 6. Cookies and Similar Technologies

DHI uses cookies and similar technologies (collectively, “Tracking Technologies”) to provide the Services and to collect data.  In addition, third parties may also use Tracking Technologies when you use the Services; for example, if DHI engaged a third party to operate the Services, or because the Services contain content or advertisements delivered by third parties.  These Tracking Technologies consist of:

Locally stored objects.  Locally stored objects (“LSOs”), also commonly called “Flash cookies,” are stored on your device or browser to provide Services that use Adobe Flash technology.

 

Web beacons.  “Web beacons” or clear GIFs are small pieces of code placed on a Service to collect data about users of that Service.

Software development kits.  Mobile Software Development Kits (“SDKs”) are bits of computer code used by mobile app developers to enable or enhance various features of a mobile app.  For example, an app developer may include an SDK within a mobile app that enables advertisements to be shown, data to be collected, and related services or analytics to be performed in connection with the mobile app.

 

DHI uses or may use Tracking Technologies for the following purposes:

Security.  To help detect fraud and abuse of the Services, including attempts to access the Services without authorization.

Analytics.  To gather usage and performance data about the Services, including counting the number of unique visitors to a particular Service.

Advertising.  To track how many users have seen or clicked on an advertisement.  This allows DHI to learn which advertising campaigns are most effective and also to help limit the number of times a user is shown the same advertisement.

Interest-based advertising.  To collect information about your interests so that DHI can deliver advertising that is most relevant to your interests.

Tailoring the Services.  Tocollect information about how you use the Services so that DHI can tailor your experience based on what is most relevant to your interests.

In some cases, DHI may work with third parties (for example, third party operators of the Services) to synchronize DHI’s unique, anonymous identifiers (such as those associated with Tracking Technologies) with the third party’s own identifiers.  This enables DHI to better achieve each of the purposes described above.

Managing Tracking Technologies.  Most web browsers give you the ability to manage Tracking Technologies used on a website, including blocking or deleting them.  Please note that if you choose to block Tracking Technologies, you may not be able to use certain features that depend on those Tracking Technologies (such as keeping you signed in or remembering your preferences).  If you choose to delete Tracking Technologies, any settings and preferences that were associated with those Tracking Technologies will also be deleted and may need to be reset. 

You also have the following options to manage Tracking Technologies and opt out of interest-based advertising:

For Flash cookies, you can access Flash management tools from Adobe’s website.  In addition, some, but not all, browsers provide the ability to remove LSOs within cookie and privacy settings.

You may opt out of interest-based advertising from companies that participate in the Digital Advertising Alliance (“DAA”) by visiting their website.

You may opt out of interest-based advertising from companies that participate in the Network Advertising Initiative by visiting their website.

Finally, you may opt-out of interest-based advertising by adjusting your device or browser settings.

Please note that opting out of interest-based advertising does not mean you will stop seeing, or see fewer, advertisements.  It does, however, mean that the advertisements you do see will not be interest-based and may be less relevant to your interests.

Some browsers have incorporated “Do Not Track” features that send an automated signal to the websites that you visit using that browser.  At this time, the Services do not recognize or respond to these signals.  However, you can adjust your preferences regarding the data DHI collects using the tools and methods described above.

 7. Security of Data

DHI takes security seriously.  DHI takes a number of steps to protect your data from unauthorized access, use or disclosure.  These steps take into account the sensitivity of the data DHI collects and uses, as well as the current state of technology.  This includes, for example, storing your data on systems that have limited access and are maintained in controlled facilities.  DHI also uses, and requires our vendors to use, industry standard security protocols when processing any payments for your use of the Services. 

It is important to remember that no system can be guaranteed to be 100% secure.  DHI recommends that you help DHI keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data in places that can be accessed publicly.

 8. Third Party Sites and Sections

DHI works with a number of third-parties to operate the Services.  When DHI engages third-parties in connection with operating the Services, those third-parties may only collect, use or access your data as needed for them to perform these functions. 

The Services may also contain links to, or integrations with, other websites, platforms or services that are not operated or controlled by DHI (each a “Third-Party Site,” and collectively, the “Third-Party Sites”).  Please note that this Policy does not apply to those Third-Party Sites.  For more information on how those Third-Party Sites collect, use and share data, DHI suggests that you contact the operators of those Third-Party Sites directly.

 9. Children and Parents

The Services are not directed at children under the age of 13, and DHI’s policy is to not knowingly collect personal data from children under the age of 13.  DHI encourages parents and guardians to monitor their children’s online behavior, put parental control tools in place, and teach children not to provide their personal data through the Services without parental consent.  For certain activities in which children are allowed to participate, any request for personal data (such as registration data) is directed to the parent or legal guardian.

If you have reason to believe that a child under the age of 13 has provided personal data to DHI without parental consent, please contact DHI using any of the methods described in the “How to Contact Us” section of this Policy, and DHI will endeavor to delete that data from our systems.

For children located in jurisdictions within the EU, DHI complies with the age limits applicable in each Member State.  In these instances, the references above to the age of 13 will be deemed to be references to the age limits applicable in each Member State.  Where this Policy refers to consent, this will require the consent of a parent or legal guardian in relation to any person under the age limits applicable in each Member State.

 10. Storing Data

Personal data collected by DHI may be stored and processed in the region in which it is collected, in the United States, and in any other region where DHI maintains major operations.  DHI takes steps to ensure that the data it collects under this Policy is stored and processed in accordance with this Policy regardless of where the data is located.  By providing personal data in connection with the Services, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of DHI and our authorized third party service providers located in the United States.  Our practice when transferring personal data is to rely on standard data protection contract clauses or individual consent.

DHI retains personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other necessary purposes such as complying with DHI’s legal obligations, resolving disputes and enforcing our agreements.  Because these factors vary for different types of personal data, actual retention periods may vary.  The criteria DHI uses to determine the appropriate retention periods include:

How long is the personal data needed to provide the Services?  This is the baseline for most data retention periods.

Do users expect that DHI will retain the personal data until they affirmatively remove it?  For example, if a user is able to directly access, edit or remove the personal data at any time, DHI may maintain the data until the user affirmatively removes it.

Is the personal data of a sensitive type?  If so, a shortened data retention period will generally apply.

Has the user provided consent for a longer retention period?  If so, DHI will retain the data in accordance with the user’s consent.

IS DHI subject to a legal, contractual or similar obligation to retain the personal data?  If so, DHI will retain the data in accordance with its obligations.

 

 11. European Privacy Rights

DHI adheres to applicable data protection laws in the European Union (“EU”).  In accordance with the General Data Protection Regulation (“GDPR”), users who are located in the EU have the following rights:

 

If the processing of personal data is based on the user’s consent, the right to withdraw consent for future processing of that data.

The right to request from the DHI, a “data controller” as defined under the GDPR, access to and rectification of the user’s personal data.

Subject to limitations as provided for in the GDPR, the right to request restriction of the processing of the user’s personal data.

Subject to limitations as provided for in the GDPR, the right to request erasure of the user’s personal data.

You may contact DHI using any of the methods described in the “How to Contact Us” section of this Policy. 

 

 12. Changes to This Privacy Policy

DHI may change this Policy from time to time to reflect changes in its business, the Services, or its practices and procedures.  If DHI does make changes, DHI will post any changes on this page and indicate the date on which the Policy was last revised.  DHI encourages you to review this Policy periodically, especially before you provide personal data directly to DHI through the Services.  Your continued use of the Services after any changes to this Policy are in effect constitutes your acceptance of the revised Policy.

 

 

 13. How to Contact Us

Although DHI strives to make this Policy as comprehensive as possible, DHI knows you may still have questions or concerns about how DHI collects, uses and shares data.  If you have a question, concern or complaint regarding our data privacy practices, you may contact DHI by any of the following methods:

By writing to DHI at DHI Group, 9251 Park South View, Houston, Texas 77051;

By sending an email to dhitelecom.com/support.  or By calling DHI at (703) 533-8659.