The Data We Collect
Anonymous Electronic Information. In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. However, we collect your computer’s or mobile device’s IP address, which you necessarily disclose when you visit the Site, so that data (such as the web pages you request) can be sent to your computer or device.
Cookies. The Site may utilize “cookies,” which are text files placed on your computer that web pages on the Site may use to store data on your computer or send data to our web servers. We may use cookie data to “recognize” you when you return to the Site, to troubleshoot how the Site operates, and for internal analysis of how people use the Site. Should you decide not to accept cookies from the Site, you will limit the functionality we can provide when you visit and use the Site.
Additional Electronic Information. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Site.
The Site is not designed to respond to “do not track” requests from web browsers.
Through Your Interactions with Us. When you engage in certain activities on the Site or otherwise interact with us, such as registering as a user of the Site, signing up for a newsletter, completing applications or contacting us for support or other inquiries, we may ask you to provide personal and other information. In order to engage in such activities, you will be required to provide information that lets us know the specifics of who you are, such as your first name, last name, state of residence, e-mail address, phone number, last four digits of your social security number, and other information. The information we will require will depend on the activity. If such information is required to provide services to you and if you do not provide the mandatory data with respect to a particular activity, you may not be able to engage in that activity or we may not be able to assist you in connection with our products or services or fulfill the purpose for which you contacted us. You may also limit your ability to use all or a portion of the Site.
Use of the Data We Collect
We use personal information to provide and improve our products and services, including the Site, for purposes in our legitimate interests and for compliance with applicable laws.
To Operate Our Business. We process personal information where you give us your consent or on the basis that it is: (a) necessary for the performance of a contract we have with you; (b) in our or a third parties’ legitimate interests such as a contract with another party under which we are required to deliver products or services; or (c) for compliance with a legal obligation.
We may use your personal information for particular activities, including, without limitation, customer service, processing your instructions to us, billing and collections, account administration, marketing and research, developing and displaying content and advertising tailored to your interests, providing product, promotional and other information to you, and to contact you regarding administrative notices or to solicit feedback on your experience with us. We may share this information with our affiliated entities, vendors, marketing partners, and other parties with whom we collaborate. In addition, if we use service providers, these service providers may have access to your personal information to perform contractually specified services on our behalf. Where we share your nonpublic personal information with third parties, we will ensure that there are contractual restrictions on their use and disclosure of that information.
To Improve our Business. We may use your IP address and similar website or application use information to: (i) help diagnose problems with the Site, administer and improve the Site, and measure the use of the Site; (ii) identify the type of web browsers used, the pages viewed, the web sites from which a visitor found this Site, and the search terms and search engines used to find this Site; and (iii) gather other web analytics information relating to visitors’ use and navigation of the Site. This information does not identify you personally. On occasion we may aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns and provide this aggregate information to vendors, business partners, or affiliates.
The information we obtain using standard Internet technology, such as web beacons, tracking pixels, and other similar technologies, enables us to customize the services we offer visitors to our Site, to deliver targeted content, and to measure the overall effectiveness of our online content, advertising, or programming or other activities.
We may use the information you provide in an anonymous or aggregated format that does not identify you personally, which uses might include, without limitation, to evaluate existing products, services, and systems; to assist in the development of new products or services; research; advertising; and to identify trends and changes.
For Law Enforcement, Regulators and Other Parties for Legal Reasons. We may also disclose personal information in any of the following circumstances: (a) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by law, rule, or regulation; (b) to protect and defend our rights or property or those of our affiliates or business partners, or others; or (c) as we, in our sole discretion, believe is appropriate under exigent circumstances in response to a perceived threat to the personal safety, property, or rights of any person or organization.
In addition, since our database is a business asset, in the event we are reorganized or become part of another organization, you consent to the sale, assignment, or transfer of your personal information to a successor that acquires substantially all of our business assets, or to an affiliate, as applicable.
Our Relationship to Consumers
Children’s Online Privacy Protection
Our Site is not directed to children under the age of 13 and we will not knowingly collect personal information from children under the age of 13 on our Site. If we become aware that we have inadvertently received personal information from a child under the age of 13 on our Site, we will delete the information from our records.
Security of Personal Information
We take the security of personal information seriously and we take what we believe to be reasonable precautions and have implemented certain safeguards to protect the security of data and personal information. We may transmit your personal data to third parties outside the United States for storage or processing. We will attempt to ensure that your personal information will be subject to appropriate physical, electronic, and procedural safeguards and that it is processed and secured in accordance with applicable state and federal privacy regulations. However, we cannot guarantee against any loss, misuse, unauthorized disclosure, or alteration or destruction of data or personal information. While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to or from the Site, by email or otherwise, and you provide such information at your own risk. You acknowledge that: (a) there are security and privacy limitations in computer systems and on the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Site, including personal information, cannot be guaranteed; and (c) any such information and data may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.
Our Relationship to Other Websites
Privacy Rights and Requests
You may have rights under applicable laws concerning personal information we have collected about you, which may include the right to access your personal information we have, to ask us to delete, correct, or restrict the use of your personal information, to withdraw your consent to our use of your personal information, to ask how we have used your personal information, and to ask whether we have shared your personal information. We will honor your rights to the extent required by us under applicable laws or as we may agree to honor in our sole discretion.
All privacy requests relating to your personal information, including those related to access to, rectification of, restriction of, processing of, sharing of, or objection to the processing of your personal information, withdrawal of consent to handle your personal information, the right to be forgotten, or to opt-out of the sale of your personal information, can be submitted to us one of the following ways:
By email: firstname.lastname@example.org
By U.S. Mail: Diversified Brokerage Services, Inc.
Attn: Privacy Requests
5501 Excelsior Blvd
Minneapolis, MN 55416
By telephone: 952.697.5000 / 800.869.1327
All communications must be in the English language. Please clearly state what information you are requesting and any other requests you are making.
We will respond to reasonable requests within the time limits established by applicable law or within a reasonable time if no time limit is established by applicable law.
If you or your authorized agent sends us an email requesting that we take action regarding your personal information or the right to be forgotten, the requesting email MUST come from the email address we have on file for you in order to verify that the request is valid and also to protect your personal information. All other requests must be made in writing or otherwise be verifiable as originating from you or your authorized agent. In order to protect your information and because people may have the same name, we will only provide or delete personal information that we can verify is associated with your particular email address or where we can reasonably identify the identity of the requestor.
For your protection, we may ask you for additional information to verify your identity. In most cases, we will provide the information you request and correct or delete any inaccurate personal information you discover. We reserve the right, however, to limit or deny your request to the extent permitted by applicable law if: (a) complying with the request may present a threat to the personal safety, property, or rights of any other person or organization; (b) complying with the request may lead to a violation of applicable laws or regulations; (c) we are not required to comply with the request because of a legal rule or exception; or (d) you have failed to provide us with sufficient evidence to verify your identity. We will not delete personal information if that personal information is related to an ongoing transaction. Even after a request, we may also keep personal information where necessary to comply with applicable laws or where necessary to protect a legal right or fulfill a legal obligation.
How Long We Keep Personal Information
We retain personal information in accordance with any records retention policy or program we may implement from time to time. We will retain personal information for the length of time necessary to fulfill the purposes for which we collected the personal information or to demonstrate we have fulfilled our duties or obligations, or retention periods required by applicable law or in which claims may be made or the existence of legal proceedings.
Last updated: January 4, 2021
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