THE DDP PRIVACY POLICY

1. Introduction

1. websites, portals, mobile applications, channels, and software, including datadividendproject.com, ddpforall.com, social media pages and channels (collectively, the "Websites"); and
2. any services, features, media, functions, content, tools, and links contained or offered in the Websites (collectively, the "Services").

2. Information We Collect And How We Use It

Information We Collect

1. Account Information: If you create an account on any of the Websites or Services (a "User Account"), you may submit your full name, e-mail address(es), address with a zip code, phone number, birth date, and also sign an Authorized Agent Agreement. Your information may further need to be verified by a second means of confirmation, such as by sending a verification code to your mobile phone number. We use this information to facilitate the creation and continued security of your User Account and to assist in facilitating transactions that you initiate through the Websites and Services. We also use it to identify you as a user in our system based on a legitimate interest in providing, personalizing, and improving the Services for an optimal user experience. See below for more on Managing and Deleting Your Information.
2. Your Information In The Possession of Other Companies and Organizations: As your authorized agent exercising your data rights, we may specially request on your behalf, your information from other companies and organizations that hold your data. This is often on an as-needed basis only, and we typically request this data to understand how that company or organization is collecting, using, monetizing, or selling your data. After we have made our assessment and gained the necessary understanding, we will delete your information as a matter of course. In general, DDP's purpose is to help you exercise your data rights, and it does not want to hold any more of your data than necessary to accomplish this task.
3. Communications: When you sign up for a User Account or use certain features, you may exchange messages with DDP administrators, or other users. Messages that you exchange through the Websites or Services may be saved. If you send or receive messages through the Websites or Services via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. We may also store any information that you provide when you communicate with us, including phone calls, letters, e-mails, and other electronic messages, or in person.
   This information is largely used to process our Services, deliver important messages to you regarding your data rights, and sometimes to verify your identity. For example, when we need your input regarding your data, you will receive communications directly from us, and you should carefully review all such messages. We may also use this information to send newsletters, surveys, offers, and other promotional materials. You may always opt out of our direct marketing e-mails by following the instructions contained within our promotional e-mails or, in some cases, by logging into your User Account and changing your communication preferences.
4. Activity: We may collect information about you through your use of our Websites and Services, including geographic location, IP address, browser type, domain name, the website that led you to the Websites, the dates and times you access the Websites, your device ID, and your activities within our Websites or Services (e.g., links you click, the date and time of your visits, and any agreement you accept or reject).
5. "Do Not Track" Requests: DDP does not currently use advertising cookies, and as such, it currently does not recognize Do Not Track ("DNT") signals from web browsers.

How DDP Uses Your Information

1. To facilitate Services on your behalf, including the enforcement of your data rights. DDP may request that companies and organizations holding your data: (a) accept a request to opt-out of the collection and sale of your personal data; (b) provide access to the data that they hold regarding you; and (c) delete your personal data. In addition, as DDP is not acting as your attorney, DDP may provide your contact information to third party attorneys so that they may assist in the enforcement of your data rights; however, DDP will not do this without first obtaining your consent.
2. To track usage of the Websites and Services, to analyze system administration, to debug and identify repairs, and to back up our systems to allow for disaster recovery, which are all based on our legitimate interest in operating and providing the continued availability our Services and Websites.
3. To detect security incidents and to protect, investigate, prevent, and potentially take action against possible deceptive, fraudulent, unauthorized, malicious or illegal activities, and to respond to claims that Website content is inauthentic, counterfeit, or otherwise violates the rights of third parties, which are all based on our legitimate interest in promoting the safety and security of the systems and applications used for our Websites and Services and in protecting our rights, your rights, and the rights of others.
4. To improve, upgrade, and enhance the Websites and Services, based on our legitimate interest in providing you and other users with an optimal user experience.
5. To enforce our Terms & Conditions, this Privacy Policy, and any other policies governing your access to or use of any of the Websites or Services.

How DDP Shares Your Information

1. Companies and Organizations - We may share your personal information with businesses and organizations to verify that they hold your data, and request that they (a) accept a request to opt-out of the collection and sale of your personal data; (b) provide access to the data that they hold regarding you; and (c) delete your personal data at your direction.
2. Attorneys That May Assist in Enforcing Your Data Rights - DDP may provide your contact information to third party attorneys so that they may assist in the enforcement of your data rights; however, DDP will not do this without first obtaining your consent.
3. Third Parties Who Perform Legitimate Services on Our Behalf - We may rely on third parties to provide some of the features and services that are available through the Websites or Services, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, marketing and promotional features, product listings, and brand management. We may share information from or about you with these third party providers so that they may, for example, complete your requests.
4. We may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful activities or uses, or to protect DDP, our Websites and Services, or any rights, property, or personal safety of DDP or others.
5. In the event that DDP is or may be acquired by or merged with another company or involved in any other business deal involving sale or transfer of all or part of our business or assets, we may transfer or assign your information as part of or in connection with the transaction and such acquirer or merged entity may thereafter utilize your personal information in accordance with this Privacy Policy. Finally, in the event of insolvency, bankruptcy, or receivership, your information may be transferred as a business asset.
We may also share your information with our affiliates as described above for any purpose consistent with this Privacy Policy.

3. Tracking Scripts

4. Managing And Deleting Your Information

Your Right To Access and Manage Your Information

Your Right To Delete Your Information

In some circumstances, we may retain information about you for legitimate business or legal purposes, or for any purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Websites or Services, or to comply with legal obligations. Some information may persist in a limited internal capacity for internal administration, such as in backup files maintained for data integrity and disaster recovery. We strive to store your information no longer than necessary, and will take steps to delete your information when reasonably possible.

Data Requests

If you are not satisfied with our method of storing or processing your personal information, please contact us pursuant to the section below. If you would like to access, revise, or delete any personal information, please submit a written Data Request by contacting us pursuant to Section 6 below.

We will take such steps as we deem necessary to verify your identity before proceeding with your Data Request. For example, we may ask you for a piece of information we have on record that you might reasonably be expected to know. We cannot disclose personal information pursuant to a Data Request to anyone other than the individual in question.

Once any queries around the information requested have been resolved, copies of the information will be sent to you electronically when possible or by mail.

If you submit multiple Data Requests and these Data Requests are excessive or manifestly unfounded, we will charge $20.00 to cover the administrative costs involved in dealing with each Data Request. In extreme circumstances, we reserve the right to refuse your Data Requests if they are excessive or manifestly unfounded.

We will attempt to respond to proper and confirmed Data Requests within thirty (30) days, or as otherwise required by applicable law.

6. Contact Information for submitting a Data Request

Data Dividend Project
[insert address]
[insert address]

7. Your California Rights; Privacy Notice For California Residents

Information We Collect About Our California Consumers

Your Rights as a California Consumer

1. Opting Out of "Sales"
   We do not "sell" your personal information gathered in our Websites without your permission or instruction. You may delete your tracking number and any information associated with it and remove our Services at any time.
2. Your Access Rights
   You have the right to request from us the following information: (1) the categories of personal information we have collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting or selling your personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you.
3. Your Deletion Request Rights
   You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
4. How to Exercise Your Rights
   To exercise any of the rights listed above, please submit a verifiable consumer request to us at _______@datadividendproject.com, or write to us at the following address:

   Data Dividend Project
   [insert address]
   [insert address]
   

You are not required to have an account with us in order to submit a request and we will only use personal information provided in a consumer request to verify the requestor's identity or authority to make such a request. Please note you may only make a verifiable consumer request for access or data portability twice within a 12-month period. Please note that for requests to access or for data portability, DDP must verify the identity of the requestor.

Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. If we are unable to comply with a request, we will provide an explanation.

1. Non-Discrimination Policy
   California residents who choose to exercise such rights will not be denied any goods or services, be charged different prices or rates, or be provided a different level or quality of goods or services unless those differences are related to your personal information.
2. Shine the Light Disclosure
   Please note that DDP is not currently collecting your information for third party marketing purposes. However, if we were to, and we aren't, you may request and obtain from us once per year, free of charge, information about your personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year.

Changes to Our Privacy Notice for California Residents

Contact

Data Dividend Project
[insert address]
[insert address]

8. Children Using The Websites Or Services

If you become aware that an underage user has created a User Account by using false, stolen, or otherwise misleading information, please contact us immediately at _______@datadividendproject.com.

9. Security

DDP is not responsible for the actions or activities of unauthorized third parties who compromise our security measures, and so we cannot be responsible for such unauthorized party's access, acquisition, or distribution of your personal information. If you believe your personal information has been compromised, please notify us immediately using the contact information above.

Please note that we must retain some personal information about you in accordance with our record retention policies, as required by law, or as required for the achievement of the purposes of the processing as mentioned above (e.g., to enforce any agreements or provide a product/service).

It is important for you to protect against unauthorized access to your primary email account, password, and computer. You can learn more about steps you can take to protect your personal information at: https://www.consumer.ftc.gov/articles/0272-how-keep-your-personal-information-secure.

Last Updated May 9, 2023