Effective and last updated as of June 28, 2023
- Personal Data We Collect
- How We Use Your Personal Data
- How We Share Your Personal Data
- Opt-Out Preference Signals
- Third Party Links
- Children’s Privacy
- Notice To Nevada Residents
- Notice To California Residents
- How To Contact Us
1. Personal Data We Collect
We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. Our collection will depend on the Site you are accessing and the way in which you interact with us. Across our Sites and Services, we collect the following types of personal data:
Personal Data You Provide
- Create an Account. If you create an account, you will provide us with your first and last name, and your business contact information, including company name, email address, phone number, and postal address (“Business Contact Information”).
- Sign In to the DSSI platform. When you sign into your account, you will provide us with your corporate issued username, password, and corporate code.
- Access Online Content. When you request access to or register for certain online content, such as whitepapers, or content available through our DSSI Partner Executive Network or Product Update Webinars, we may request your first and last name, Business Contact Information, and any information you may submit in a comment or question during a webinar.
- Purchase Products. When you make a purchase or submit an order, we will collect your name, job title, email address, phone number, company payment, and Business Contact Information.
- Contact Us. When you request a free demo, free consultation, need customer support, or otherwise contact us online, we will collect your first and last name and certain Business Contact Information, and any additional Personal Data you choose to provide.
- User Generated Content. If you choose to submit a story, comment on a blog post, leave a product review, or engage in other similar activity, we will collect your first and last name, email address, company name and job title, and any Personal Data you choose to include in your submission, including any images or videos you submit. Certain activities, such as leaving a product review, may be performed anonymously. If you provide User Generated Content anonymously, we will know that your post or submission is associated with you, but your name and Personal Data will not be displayed publicly.
- Sign Up for Newsletter and Emails. If you sign up to receive newsletters via email from us, you will provide us with your name, email address, and any other Personal Data you choose to provide. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at email@example.com.
- Becoming an Advocate. If you purchase a membership for the Direct Supply Senior Living Advocacy, we will collect your name, Business Contact Information, and payment information.
You may use your account to access, correct, or view certain personal data we have collected, and which is associated with your account. To review or request changes to any of your personal data, please contact us at firstname.lastname@example.org.
Personal Data as You Navigate Our Sites and DSSI Platform
- Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Site and DSSI platform are accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from visitors to the Site on a city-regional basis.
Personal Data We Collect About You from Other Sources
In some cases, we may receive personal data about you from other sources. This includes government entities, advertising networks, data brokers, operating systems and platforms, mailing list providers, social networks and advertising and marketing partners.
2. How We Use Your Personal Data
We use the personal data we collect to provide the Services to you, to improve our Site and Services, and to protect our legal rights. In addition, we may use the personal data we collect to:
- Process your account registration;
- Process and fulfill your order;
- Respond to your request for a demo;
- To process your User Generated Content, such as posting your stories, comments, or reviews;
- Email you our newsletters or blogs;
- Process and communicate with you regarding your registration or engagement with the Services;
- Contact you regarding our products and services that we feel may be of interest to you;
- Communicate with you about the Site or Services or to inform you of any changes to the Site or Services;
- Provide support;
- Maintain and improve the Site and Services;
- Protect the security and integrity of the Site and Services;
- Defend our legal rights and the rights of others;
- Fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate;
- Efficiently maintain our business; and
- Comply with applicable law.
3. How We Share Your Personal Data
We may share the personal data that we collect about you in the following ways:
- With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- With vendors to prepare, deploy and analyze advertising content;
- With Direct Supply affiliates;
- To the extent that we are required to do so by law;
- With product manufacturers to. fulfill your order and effectuate product recalls and warranties;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
- With any other person or entity where you consent to the disclosure; and
- For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.
4. Opt-Out Preference Signals
This Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.
6. Third Party Links
The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.
7. Children’s Privacy
The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.
8. Notice To Nevada Residents
Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to email@example.com.
9. Notice To California Residents
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.
Notice at Collection of Personal Information
- Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, other similar identifiers)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
- Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, physical characteristics or description, telephone number, employment, business bank account number, company credit card number, or any other financial information, as well as the categories listed in “Identifiers” category above)
- Commercial information (Business Contact Information or products or services purchased)
- Social Security Number, when submitted as the taxpayer identification number
- Biometric information (imagery of face or voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted)
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
- Sensitive Personal Information. Personal Information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
We collect Personal Information directly from California residents and from advertising networks, internet service providers, data analytics providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
- Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Sale, Sharing, and Disclosure of Personal Information
The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites.