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Privacy Policy


January 25, 2019

This DiCentral Privacy Policy ("Privacy Policy") describes our privacy practices for the activities set out below. This Privacy Policy describes how DiCentral collects, uses, shares and processes personal and private information relating to individuals ("Personal Data"). This Privacy Policy is specifically applicable to all Personal Data processed by the websites dicentral.com and smartturn.com. “DiCentral,” “we,” “us” or the “Company” is a reference to DiCentral Corporation and our affiliates.

1. What is Covered

DiCentral is the controller of your Personal Data as described in this Privacy Policy. This Privacy Policy applies to the processing of Personal Data collected by us when you:

  • Visit or use our websites that display or link to this Privacy Policy;
  • Visit our branded social media pages;
  • Receive electronic communications from us; or
  • Register for, attend and/or otherwise take part in our events, webinars or contests; or

2. What is Not Covered

This Privacy Policy does not apply to Personal Data that DiCentral receives, sends, or manipulates in its role as service provider on behalf of our customers. DiCentral stores and processes information on behalf of its customers such as when it sends or receives EDI data or provides analytics on behalf of customers. DiCentral is not responsible for the privacy or data security practices of our customers or their trading partners.
When applications are provided by third parties, the Privacy Policy of the third party applies and this Privacy Policy does not apply. DiCentral websites and services may use applications and services maintained by third parties that are governed by third parties’ Privacy Policys.

3. What Personal Data is Collected?

DiCentral may collect the following Personal Data. Although we have tried to provide a comprehensive list, this list is not exhaustive. Other Personal Data may be collected that is not on this list:

  • • If you attend an event, we may scan your attendee badge, collect business cards, or collect survey information which contains information, such as name, title, company name, address, country, phone number and email address that we obtain from information you submit on a website controlled or contracted by DiCentral, providing us your business card, or filling out surveys;
  • • If you use and interact with our websites or emails, we automatically collect information about you and your device through cookies, Internet Protocol (IP) addresses or other means;

We also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you.

4. Devices, Data and Cookies

DiCentral uses common information-gathering tools, such cookies, web beacons, and similar technologies to automatically collect information that may contain Personal Data. DiCentral gathers information about users automatically on its websites and applications. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to protect our platform against malicious actors and to improve our systems and services. Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could be personally identifying to you.

DiCentral uses cookies, Internet Protocol (IP) addresses or other data collection services When you visit our websites, we or an authorized third party may place a cookie on your browser, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage to improve our services or better suit our marketing to you.

DiCentral uses both session-based and persistent cookies on our websites. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites. DiCentral or third parties may also place or recognize unique cookies for the purpose of serving you targeted advertising.

5. Purposes for Processing Personal Data

We collect and process your Personal Data for the following purposes:

  • Providing services: We process your Personal Data to perform our contract with you for the use of our websites and services and to fulfill our obligations under applicable terms of use/service or contracts. Where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with the content you access and request;
  • Promoting the security of our websites and services:
  • Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
  • Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
  • Marketing and Sales. We process Personal Data to advertise and market to you. DiCentral treats Person Information obtained solely for marketing purposes differently than Personal Data about you as a customer of DiCentral. You may remove Personal Data stored and processed solely for marketing services by following the instructions described further in this document.
  • Complying with legal obligations: We process your Personal Data to comply with laws. Sometimes, laws require that we disclose Personal Data to government authorities.

6. Sharing Personal Data.

In general, we may share your Personal Data with our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, and customer support for the purposes described above.

We may share Personal Data in individual instances, with professional advisers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.

We may share Personal Data with affiliates within the DiCentral and companies that we acquire in the future when they are made part of the DiCentral, to the extent such sharing of data is necessary to fulfill a purpose previously described.

We may also share anonymous usage data with DiCentral’s service providers for the purpose of helping DiCentral in such analysis and improvements. Additionally, DiCentral may share such anonymous usage data on an aggregate basis in the normal course of operating our business.

7. International transfer of Personal Data

Your Personal Data may be collected, transferred to and stored by us in countries where we operate. Therefore, your Personal Data may be processed outside the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

8. Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.

9. How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for which we process Personal Data). We use reasonable business judgment to determine the length of such time.

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

10. Your rights relating to your Personal Data

You have certain rights relating to your Personal Data, subject to local data protection laws. If you are located in the EEA, you may have rights:

  • To access your Personal Data held by us (right to access);
  • To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
  • To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
  • To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
  • To transfer your Personal Data to another controller, to the extent possible (right to data portability);
  • To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  • Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services; and
  • To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

If you are a resident of California, under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our websites. Please note that your request does not ensure complete removal of the content or information, because some of your content may have been reposted by others.

To exercise your rights, please contact us by using the information in the “Contacting us” section, below.

11. How we secure your Personal Data

We take precautions including organizational, technical and physical measures to help safeguard your Personal Data. However, no measures are perfect. You are responsible for protecting your password and taking reasonable precautions to protect your Personal Data.

12. Changes to this Privacy Policy

We will update this Privacy Policy from time to time. You can see updates by visiting the privacy policy section of our website.

13. Contacting us

You can contact us at: legal@dicentral.com. You can also mail us at: Legal Department; 1199 NASA Parkway, Houston, TX 77058, USA