Your Privacy

As professionals engaged in the provision of information security, privacy, and governance, risk and compliance services to clients in the United States, Digital Assurance Advisors LLC, including its affiliated partnerships, (collectively, the firm) is committed to protecting the privacy of confidential and “Personal Information” (information that directly or indirectly identifies individuals who may be clients, staff, agents, advisors, job applicants or others inside or outside the firm). It has always been and remains the policy of the firm to comply with the rules of professional conduct, which impose a duty to preserve and protect confidential client information, upon advisors and their associated personnel.

This Privacy Statement and Cookie Policy (the “Statement”) is based on the privacy and data protection principles common to the United States in which we operate. We apply it in light of our overarching obligations to comply with law, to preserve client confidentiality and to represent our clients as effectively as possible within the bounds of the law. This Statement is intended to summarize the firm’s data protection practices generally, and to advise our clients, job applicants, website visitors, and other third parties about the firm’s privacy policies that may be applicable to them.

This Statement is also specifically addressed to parties outside the firm who provide Personal Information to the firm or who visit or use the firm’s websites, our apps, our social media sites, our extranets, as well as email messages that we send to you that contain a link to this Statement (collectively, the “Internet Services”). This Statement also describes how the firm collects, processes and discloses Personal Information in connection with the provision of information security, privacy, and governance, risk and compliance services and the Internet Services.

Who we are

Our website address is: DigAssurance.com

Information you provide us directly

We ask for certain information such as your username, real name, birthdate, address, phone number and e-mail address when you register for a DigAssurance.com account, or if you correspond with us. We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service. We use this information to operate, maintain, and provide to you the features and functionality of the Service. Your username and if you choose to disclose it, your real name, will be published publicly. Once published your username and / or real name may not be able to be removed.

Information we may receive from third parties

We may receive information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Facebook Connect, by “following,” “liking,” adding the DigAssurance.com application, linking your account to the DigAssurance.com Service, etc., that third party may pass certain information about your use of its service to DigAssurance.com. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. If you allow us access to your friends list, your friends’ user IDs, and your connection to those friends, may be used and stored to make your experience more social, and to allow you to invite your friends to use our Service as well as provide you with updates if and when your friends join DigAssurance.com. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the DigAssurance.com Service. You may also unlink your third-party account from the Service by adjusting your settings on the third-party service.

Inviting a friend to use DigAssurance.com

DigAssurance.com may, in its sole discretion, develop a feature that allows you to invite third parties to the Service. If you choose to use our invitation service to invite a third party to the Service through our “Invite friends” feature, you may directly choose a friend to invite through your mobile device’s native contact list – but we do not require that you import your contacts list to the Service, and we do not retain the information contained in your contacts list. You understand that by inviting a friend to DigAssurance.com through the “Invite friends” feature, you are directly sending a text or email from your personal accounts and that we are not storing your contact list. In addition, you understand and agree that normal carrier charges apply to communications sent from your phone. Since this invitation is coming directly from your email or phone, we do not have access to or control this communication.

Finding your friends on the Service

DigAssurance.com may, in its sole discretion, develop a feature that allows you to locate your friends with DigAssurance.com accounts through a “Find friends” feature. The “Find friends” feature allows you to choose to locate friends either through (i) your contact list, (ii) social media sites (such as Twitter or Facebook) or (iii) through a search of names and usernames on DigAssurance.com. If you choose to find your friends through your contact list, then you agree to provide DigAssurance.com access to your contact list such that we can perform the search necessary to determine whether or not someone associated with the information you provide is using DigAssurance.com. If you choose to find your friends through social media sites, then you understand that the information these sites provide to use to conduct this type of search is governed by their privacy policies and your account settings on those sites. If you choose to find your friends through a search of names or usernames, then simply type a name to search and see if that name or username appears on our Service. Note that we do not retain any information contained in your contacts list, or information from social media sites about your contacts, and we do not use such information for any purpose other than to help you find your friends on DigAssurance.com.

Analytics information

We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Cookies information and Policy

Full details can be found on our Cookie Policy. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets DigAssurance.com help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. Full details can be found on our Cookie Policy.

A cookie is a text file sent by a web server and placed on your computer by your web browser. Cookies can be usefully divided into two different types, session and persistent. Session cookies differ from persistent cookies primarily in that session cookies are temporary and expire and are normally deleted when you close your browser. Persistent cookies, in contrast, remain stored on your computer after you close your browser until they are deleted either because they expire or you delete them. The firm uses session cookies in connection with its Internet Services, except for Internet Services that require you to log in, such as our client extranets, and a Region Code cookie that persists over time and ensures that you are directed to the correct version of our website. Cookies are often used in conjunction with other Internet technologies, such as web beacons, to understand behavior on the Internet. For example, the firm uses cookies in conjunction with web beacons, which are small sections of code that we may place in our Internet Services to understand the number of unique users that have visited a specific page. Similarly, we may use or receive reporting from tracking scripts that recognize unique cookies issued by another website. These tracking scripts are not used to gather information on your use of the Internet unrelated to the firm, and they do not identify you unless you choose to provide Personal Information to the firm. The firm’s Internet Services use cookies. The firm uses session cookies in connection with its Internet Services, specifically for cybersecurity purposes, to provide you with customizations of your experience, such as highlighting your recently viewed items, to detect and remember your region and language preferences, and track your activities on the Internet Services. We also use a Region Code cookie that persists over time and ensures that you are directed to the correct version of our website. Although the firm uses the services of third parties in connection with these cookies, we do not allow the third-party service provider to use Personal Information about the users of our Internet Services. None of these cookies are strictly necessary to access our Internet Services. You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set, however, certain parts of the Internet Services may function differently and not as well. Unless you have adjusted your browser setting so that it will refuse cookies, our Internet Services will issue cookies when you logon to the firm’s Internet Services. For more information about how to manage your cookies preferences, you should use the “help” menu of your web browser or explore the customer support sections of your web browser. Please note that you need to configure each browser on each device that you use if you wish to opt-out or block some or all cookies. If you do not wish to receive advertising cookies, you may wish to visit the Network Advertising Initiative (NAI) website by clicking here and the Digital Advertising Alliance (DAA) website here.

Log file information

Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear gifs/web beacons information

When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Device identifiers

When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by DigAssurance.com. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Location data

When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Commercial and marketing communications

We use the information we collect or receive, such as your email address, to communicate directly with you. We may send you emails containing newsletters, promotions, and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails. You may also be able to be “found” on DigAssurance.com based on information that you provide (see “Find friends on DigAssurance.com”) above.

Use of certain service type information we collect about you

We use or may use cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems; (f) help you efficiently access your information after you sign in; (g) to provide advertising to your browser or device, and (h) automatically update the DigAssurance.com application on your mobile devices.

Sharing of Your Information

We will not rent or sell your information into third parties outside DigAssurance.com and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below: •Who we may share your information with: We may share your information with third-party business partners and Trusted Users for the purpose of providing the Service to you. Third party business partners will be given limited access to your information as is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy, or operate under a similar privacy policy. •Who can see User Content: Any User Content that you voluntarily disclose for posting to the Service becomes available to the public and cannot be removed, except by DigAssurance.com in its sole discretion. Once posted on DigAssurance.com, User Content may not be removable from public view, as copies may remain viewable in cached and archived pages of the Service, on other sites that have republished us, or if other Users have copied or saved that information. If you do not wish your User Content to be available to the public, please don’t post it on DigAssurance.com. Your username and if you choose to disclose it, your real name, will be published publicly. Once published your username and / or real name may not be able to be removed. •Who can see your IP address: If you post User Content on the Service while not logged in, your IP address will be published with your User Content in order to attribute your contribution to the Service. A selection of Trusted Users with administrative powers on DigAssurance.com have the ability to review IP addresses of users to reduce abusive behavior. Any third party service embedded on DigAssurance.com such as an advertiser, video provider, social network or other third party will also have access to your IP address. •Who can see your email address: If you enter an email address, you will enable communication from DigAssurance.com and other Users. If you reply to users or participate in group DigAssurance.com activities such as meetups, your email address will be shared with these users. In addition, some email addresses such as blocked@DigAssurance.com forward to a group of Trusted Users, who will use your email address to reply to the email.

What happens in the event of a change of control

We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Instances where we are required to share your information

DigAssurance.com will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security, quality or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of DigAssurance.com, our Users, or others.

Sharing certain service type information we collect about you

We may share certain service type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.): (i) with our third-party business partners for the purposes described in the section above on “How We Collect and Use Information.” We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

Ads on DigAssurance.com

We may also share certain information such as your location, browser, and cookie data and other data relating to your use of our Service with our business partners to deliver advertisements (“ads”) that may be of interest to you. DigAssurance.com may allow third-party ad servers or ad networks to serve advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service and on other websites, and to measure the effectiveness of their ads and to personalize the advertising content delivered to you. For example, Google uses DART cookies in order to deliver ads to you through the Service. Google's use of the DART cookie enables it and its partners to serve ads to you based on your visit to the Service and previous websites that you may have visited. Other advertising networks also use similar cookies, clear gifs, or other mechanisms to deliver targeted advertising to you through the Service. You may opt out of use of Google’s DART cookie and cookies placed by Network Advertising Initiative (NAI) certified ad networks here: http://www.networkadvertising.org/managing/opt_out.asp . Opting out of these cookies will be effective not only on the Service, but on all websites with NAI certified advertising networks. However, these opt-outs will be ineffective on networks that are not NAI certified. Please note that an advertiser may ask DigAssurance.com to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, DigAssurance.com or our Partners determines the target audience and DigAssurance.com serves the advertising to that audience and only provides anonymous data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. To enhance your user experience or help us improve and measure our effectiveness, DigAssurance.com may embed code from third parties on the Service. Examples of such parties may include Facebook, Twitter, Pinterest, Google, YouTube, Howcast, VideoJug, AOL, and others. These third parties may collect information about you including IP address, cookies in ways DigAssurance.com does not control. The DigAssurance.com Privacy Policy does not apply to, and we cannot control the activities of third-parties. Please consult the respective privacy policies of such third parties or contact such third parties for more information.

Storage and Processing

Your information collected through the Service may be stored and processed in the United States or any other country in which DigAssurance.com or its subsidiaries, affiliates, or service providers maintain facilities. DigAssurance.com may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which DigAssurance.com or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe

DigAssurance.com cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from DigAssurance.com, at all times. However, DigAssurance.com cannot ensure or warrant the security of any information you transmit to DigAssurance.com or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the DigAssurance.com Service, such as social networks. DigAssurance.com is not responsible for the functionality or security measures of any third party.

Compromise of information

In the event that any information under our control is compromised as a result of a breach of security, DigAssurance.com will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your Choices about Your Information

You control your account information and settings: You may update your account information and email-communication preferences at any time by logging in to your account and changing your profile settings. You can also stop receiving promotional email communications from us by modifying your preferences at DigAssurance.com.com. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at CustomerService@DigAssurance.com.

Opting out of collection of your information for Tracking / Advertising

Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents DigAssurance.com or its business partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at CustomerService@DigAssurance.com.

How long we keep your private profile information

Following termination of your User account, DigAssurance.com may retain your private profile information for a commercially reasonable time for backup, archival, or audit purposes. For the avoidance of doubt, any information that you choose to make public on the service may not be removable.

Children’s Privacy

DigAssurance.com does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at CustomerService@DigAssurance.com.

Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and we do not control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook, Google groups, or an IRC chatroom) and you allow such a third-party access to you User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

Digital Assurance Advisors LLC