Privacy Policy

Effective and last updated as of June 28, 2023

Direct Supply, Inc. (“Direct Supply,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access the websites on which this Privacy Policy appears (each, a “Site”) and any of our online, and where required offline, services (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

This Privacy Policy covers the following topics:

1. Personal Data We Collect
2. How We Use Your Personal Data
3. How We Share Your Personal Data
4. Opt-Out Preference Signals
5. Security
6. Third Party Links
7. Children’s Privacy
8. Notice To Nevada Residents
9. Notice To California Residents
10. Accessibility
11. 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.
• Webinars. To register for one of our webinars or events, we will collect your first and last name and email address. Certain webinars or events provide for continuing education units, in which case will also collect your professional license number. The collection of your Personal Data may also be subject to a third-party platform’s privacy policy, to the extent a webinar is being provided by a third-party platform.
• 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 privacy@directsupply.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.
• Chatbot. If you use our chatbot feature, you will provide your name, email address, postal address, phone number, and any other information you choose to provide in your message. Our chatbot feature is provided by LiveChat, Inc. LiveChat, Inc. may collect, record, and store the information you provide in the chat. Please review LiveChat, Inc.’s privacy policy here.

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 privacy@directsupply.com.

Personal Data as You Navigate Our Sites and DSSI Platform

We automatically collect certain personal data through your use of our Site and our use of cookies and other tracking technologies, such as the following:

• 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.

For more information on our cookie usage see our Cookie Policy.

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;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use, and to otherwise fulfill our legal obligations;
• Monitor compliance with and enforce this Privacy Policy and any other applicable agreements and policies;
• 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.

5. Security

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 privacy@directsupply.com.

9. Notice To California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

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

We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected the following categories 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)
• Geolocation
• 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.

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We sold or shared Personal Information to third parties for the following business or commercial purposes:

• Performing Services
• Auditing Interactions with Consumers

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

We disclosed Personal Information for the following business or commercial purposes:

• Performing Services

We do not knowingly collect or sell or share the Personal Information of consumers under 16 years of age. We do not process sensitive Personal Information for the purpose of inferring characteristics and, consequently, do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

If you have an account with us, you must log into your account and submit your request to know, delete, and/or correct through your account. If you do not have an account, you may submit a request to know, delete, and/or correct by emailing us at privacy@directsupply.com or by calling us toll free at 1-800-899-3795.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

The Site’s use of certain third-party cookies may constitute “sales” under the CCPA. If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing through our interactive webform available by clicking here. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Opt-Out Preference Signals” section above for more information.

Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

10. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

11. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at privacy@directsupply.com.