Privacy Policy

Last revised 10/14/2020

DigitBridge, Inc and our subsidiaries (“We,”, “us” or “DigitBridge”) care about your privacy. For this reason, we collect and use personal information only as needed to deliver our products, services, websites and mobile applications, and to communicate with you about the same, or as you have requested (collectively, our “Services”). Your personal information includes information such as:

• Name
• Address
• Telephone number
• Email address
• Company name
• Billing and payment information
• Candidate information (for job applicants)
• Other data collected that could directly or indirectly identify you.

Our Privacy Policy not only explains how and why we use your personal information that we collect, but also how you can access, update, or otherwise take control of your personal information.

If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at privacy@digitbridge.com. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.

What information we collect, how we collect it, and why

Much of what you likely consider personal information is collected directly from you when you:

create an account or purchase any of our Services (ex: billing information, including name, address, credit card number, government identification);
connect our Services to your marketplace accounts on third-party websites (ex: login and authentication information necessary to maintain connection; order and inventory information downloaded from these third-party websites);
connect our Services to your internal system;
request assistance from our customer support team (ex: phone number);
complete contact forms or request newsletters or other information from us (ex: email); or
participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so we thought we’d highlight and explain a bit more about what these might be (as they vary from time to time):

Cookies and similar technologies on our websites and our mobile applications allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Services. These technologies automatically collect data when you use and interact with our Services, including metadata, log files, cookie/device IDs, page load time, server response time, and approximate location information to measure website performance and improve our systems, including optimizing DNS resolution, network routing and server configurations. Specifically, interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data is collected. All this allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our Services. For additional information, and to learn how to manage the technologies we utilize, please visit our Cookie Policy. If you wish to opt out of interest-based advertising click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, assess the qualifications of a candidate for employment, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

How we utilize information

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes:

Delivering, improving, updating and enhancing our Services. We collect various information relating to your purchase/subscription, use and/or interactions with our Services. We utilize this information to:

Improve and optimize the operation and performance of our Services (again, including our websites and mobile applications)
Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
Detect and prevent fraud and abuse of our Services and systems
Collecting aggregate statistics about use of the Services
Understand and analyze how you use our Services and what products and services are most relevant to you.

Much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal information.

Sharing with trusted third parties. We may share your personal information with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:

Processing credit card payments
Serving advertisements
Conducting contests or surveys
Performing analysis of our Services and customers demographics
Communicating with you, such as by way email or survey delivery
Customer relationship management
System integration and management
Recruiting support and related services.

We only share your personal information as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors they may be permitted to use) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal information for any purpose other than as they have been specifically contracted for (or without your consent).

We may also share your information with third parties for the purpose of facilitating / allowing a merger, acquisition or sale of all or substantially all of our assets, in which case the acquiring company may continue to utilize your data in the manner for which it was provided and intended.

Communicating with you. We may contact you directly or through a third-party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

Email
Text (SMS) messages
Telephone calls
Messenger applications (e.g. WhatsApp, etc.)
Automated phone calls or text messages.

You may opt-out of receiving promotional emails from us by following the opt-out instructions provided in those emails or by contacting privacy@digitbridge.com.

If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regards to the use and/or sharing of your personal information with a co-branded partner, as well as how to exercise those options. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.

If you make use of a service that allows you to import marketplace orders, we will only use the contacts and any other personal information for the requested service. If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@digitbridge.com.

Transfer of personal information abroad. If you utilize our Services from a country other than the country where our servers are located, your personal information may be transferred across international borders, which will only be done when necessary for the performance of our contract with you, when we have your consent to do so, or when the appropriate standard contractual clauses are in place. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin.

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

How we secure, store, and retain your data

We follow generally accepted standards to store and protect the personal information we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.

We retain personal information only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

mandated by law, contract or similar obligations applicable to our business operations;
for preserving, resolving, defending or enforcing our legal/contractual rights; or
needed to maintain adequate and accurate business and financial records.

If you have any questions about the security or retention of your personal information, you can contact us at privacy@digitbridge.com.

How you can access, update, or delete your data.

To easily access, view, or update your personal information, or to update your subscription preferences, please sign into your Account and visit “Account Settings.”

If you wish to delete or port your personal information, you may submit your request to privacy@digitbridge.com. If you make a request to delete your personal information and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. If you are unable for any reason to access your Account Settings, you may also contact us by one of the methods described in the “Contact Us” section below.

Notice to California Residents – Your California Privacy Rights

If you are a California resident, in addition to the rights listed above, you have certain rights, pursuant to the California Consumer Privacy Act of 2018 (CCPA). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.

Right to Know	As a California resident, you have the right to request that we disclose what Personal Information we collect, use, disclose and/or sell.
Right to Request Deletion	As a California resident, you have a right to request the deletion of your Personal Information collected or maintained by us.
Right to Non-Discrimination	As a California resident, you have a right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.
Authorized Agent	As a California resident, you can exercise your CCPA rights or you can designate an authorized agent to make a request on your behalf. We may require that you provide the authorized agent written permission to submit a request on your behalf and that the authorized agent verifies their own identity directly with us.
Contact Us for More Information	If you have questions about this Privacy Statement, including anything in this section about your CCPA rights, please contact us at privacy@digitbridge.com

You have the right to know whether your Personal Information is being sold. Your Personal Information is sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth within the CCPA. We do not sell your Personal Information and have not sold your Personal Information in the preceding 12 months. For this reason, we have not included an opt-out of sale of your Personal Information.

Your EU Data Protection Rights

Where the processing of your Personal Information is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:

Access: you have the right to request information about how we process your Personal Information and to obtain a copy of that Personal Information

Rectification: you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed.

Objection: you have the right to object to the processing of your Personal Information which is based on our legitimate interests (as described above).

Erasure: you have the right to request the erasure of your Personal Information (subject to certain conditions).

Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.

Restriction: you have the right to ask us to restrict our processing of your Personal Information, so that we no longer process that information until the restriction is lifted.

Portability: you have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization in certain circumstances.

In addition to the above, you have the right to lodge a complaint with a supervisory authority (such as the supervisory authority in your member state of habitual residence, place of work or where the alleged infringement took place) if you consider that our processing of your Personal Information infringes applicable data protection law.

If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or exercise any other data subject right, please send a written request to privacy@digitbridge.com or to the postal address provided at the bottom of this Privacy Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.

‘Do Not Track’ notifications.

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Age restrictions.

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal information, please contact us.

Non-Discrimination.

We will not discriminate against you for exercising any of your privacy rights. Unless permitted under applicable laws, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this policy.

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

Data Protection Authority.

If you are a resident of the European Economic Area (EEA) and believe we maintain your personal information subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority or our lead supervisory authority, the UK’s Information Commissioner’s Office, as noted below:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Phone: 0303 123 1113
www.ico.org.uk

Contact us.

If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our Office of the DPO by email at privacy@digitbridge.com. In the alternative, you may contact us by either of the following means:

By Mail: Attn: Office of the Data Protection Officer, 9440 Telstar Ave, Suite #6, El Monte, CA 91731
By Phone: (626) 377-9118