Directive Communication Systems, Inc., Privacy Policy
Version: April 6, 2015
Directive Communication Systems, Inc. (“DCS”) is the producer and owner of Directive Communication Systems (collectively referred to here as the/our “Software” or the/our “Services”), which comprises a web-based solution and mobile application that assist in estate administration. We take the private nature of your personal information very seriously, and are committed to protecting it. To do that, we’ve set up procedures to ensure that your information is handled responsibly and in accordance with applicable data protection and privacy laws.
This privacy policy describes what information we collect when you visit our Services, how we use that information, and what choices we offer you to access, update, and control it. This version of the policy is effective as of April 6, 2015.
TYPES OF INFORMATION
“Personal information” is any information that we could use to identify an individual. It does not include personal
information that is encoded or anonymized, or publicly available information that has not been combined with non-public information.
“Sensitive personal information” is information that meets the “personal information” criteria and also a.) reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or b.) concerns health or sex life, information about Social Security benefits, or information on criminal or administrative proceedings other than in the context of pending legal proceedings.
Some of the information we collect in connection with the Application may be “Protected Health Information” (as that term is defined at 45 C.F.R. 160.202) protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and Subtitle D of the Health Information Technology for Economic and Clinical Health Act (the “HITECH Act”). We will use, protect and disclose any Protected Health Information in accordance with our Notice of Privacy Practices, as mandated by HIPAA. To the extent that there is any inconsistency between this Privacy Policy and the Notices of Privacy Practices, the Notice of Privacy Practices will prevail.
HOW WE COLLECT INFORMATION
The information we collect is primarily the information you provide to us through your use of the Services, but we also collect other information you provide to us.
Some of the information we get from your use of the Services is non-personally-identifying information of the sort that web browsers, servers, and marketing services typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other non-identifying information that we might have access to includes how you use the Services, your approximate location, cookies, etc.
A cookie is a small piece of data that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies to help us track visitors’ use of the Services and their preferences. If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies, but should be aware that certain features of our Services may not function properly without them.
We collect this non-personally-identifying information in order to better understand how visitors use the Services and, where possible, to improve their experience. For instance, we log the time it takes to run database queries so that we can improve performance. In some cases, we may publicly display information that is not personally identifying in the aggregate, (e.g., by publishing a report on trends in the usage of our Services) or may provide the aggregate data to third parties.
When you use the Services, we may also collect potentially personally identifying information in the form of Internet Protocol (IP) addresses, the Uniform Resource Locator (URL) accessed, and the unique identification number associated with the account. We don’t use that information to identify you, with one exception: we may discover, by reviewing log files, that a particular account is using the Services in a way that is degrading the experience for all the Services’ users or is otherwise, in our judgment, an attempt to circumvent or violate applicable law. If this is discovered, we may look up personally identifiable information associated with that account in order to contact the account owner. We handle and disclose this information in the same way we handle other potentially personally identifying information as described below.
INFORMATION YOU PROVIDE TO US DIRECTLY
Our Services require users to interact with us in ways that results in them providing us with personally identifying
information. We do not disclose personally identifying information other than as described below. And users can
always refuse to supply personally identifying information, with the caveat that it may prevent users from fully
enjoying the benefits of our Services.
If you send us a request, such as emailing us for support, we reserve the right to publish it (absent any personally
identifying information) in order to help us clarify or respond to your request or help other users.
In the process of supporting our Services, we may discover personally identifiable information associated with your account. The only personally identifiable information we may discover during the support process without your consent includes your name, date of birth, telephone number and the information concerning your accounts that you or your agent provides to us in connection with the Services. Any further information will not be discovered without your consent.
In the process of supporting our Services, we must use the data within your account, including data you have entered into the Software. We will do so only in connection with our performance of the Services, unless you approve otherwise If you are outside the United States, you should know that any personally identifiable information you enter into the Services will be transferred out of your country and into the United States, and possibly to other countries. By using the Services, you consent to such transfer and are representing that you have the right to transfer such information outside your country.
We do not collect any personally identifiable information from children under the age of 13. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at info@directivecommunications.com. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.
INFORMATION YOU GIVE TO OTHER PEOPLE
This Policy only applies to information collected by DCS. It does not apply to the practices of companies that we don’t own or control, or employees that we don’t manage. Information made available by the Services may contain links to third party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites’ responsibility to protect any information you give them, so we can’t be held liable for their wrongful use of your personally identifying information.
HOW WE USE INFORMATION WE COLLECT
When we collect your personal information, we will inform you if and/or how we are using it, any types of third parties to which we might disclose it, (other than “agents,” such as vendors, contractors and partners, who are only processing such information for us or at our direction or are directly obligated to you with respect to privacy matters), and the choices we offer you to limit the use of your information. If anything in this policy seems unclear, please don’t hesitate to contact us at info@directivecommunications.com, so we can address your question and possibly clarify this document.
Although most changes are likely to be minor, we may occasionally need to change this policy. If we do update it,
we’ll notify you either by posting the new policy on our Services, their website or their blogs, or by emailing you the changes or a link to the modified document. (See the “Choice” section below for information about how we’ll notify you if we change our policy regarding sensitive personal information.) In any case, the way we use information you provide will be covered by the privacy policy that was in effect at the time it was collected.
Here are some of the ways we may use personal information you provide us:
- To allow you to register for and for us to perform our Services and to administer and process the registration
- To communicate with you about our products, services and related issues
- To evaluate the quality and usage of our products and services, and to enhance your experience on our web sites
- To maintain and administer our web sites and comply with our legal or internal obligations and policies
- To transfer information to others as described in this policy or to satisfy our legal, regulatory, compliance, or auditing requirements
- To charge you any fees and provide you with a receipt or resolve billing issues associated with your account
- To communicate with third parties with whom you have accounts and have directed us to contact in connection with our administration of the Services
You have the ability to control how we share your personal information with others. We never share any of your
personal information with non-agent third parties except in connection with our performance of the Services. We will employ vendors and other third parties with whom we have an agency relationship in our discretion to assist in the performance of the Services. However, we will instruct any such agent third parties to comply with the requirements of this privacy policy.
We will not share your personal information with non-agent third parties unless we are required to do so by law, or if we believe in good faith that disclosure is reasonably necessary to protect our property, rights or those of third parties or the public at large. Likewise, we will not knowingly disclose your personal information in violation of applicable law. It is possible that we may, on occasion, buy or sell assets from or to other companies. If that should occur, user information is typically one of the assets that get transferred. Similarly, if DCS or most of its assets were acquired, or if we go out of business or enter bankruptcy, user information could be transferred or acquired. You should be aware that such events can occur, and that if it does, the buyer may continue to use your personal and non-personal information, but only as set forth in this policy. Other than in these circumstances, DCS will not rent or sell potentially personally identifying information to anyone.
We may from time to time request some of your financial information for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.
If you are a registered user of our Services, we may occasionally send you an email to tell you about new features, solicit your feedback, to keep you up to date with what’s going on with the Services, and to provide other notices that are not essential to our administration of and your use of the Services. We generally use our Services to communicate this type of information, so we expect to keep this type of communication to a minimum. If we do send you non-essential information that you did not expressly request, we will provide you with a way to request that you don’t get any similar non-essential notices (opt-out, unsubscribe, etc.).
Prior to providing agents with any personal information, we will obtain assurances that they will safeguard it in
accordance with this policy. In the unlikely event that we should discover that an agent is using personal information in a way that conflicts with this policy, we will take all reasonable steps to stop it immediately.
All records containing personal or financial information are considered to be our property and are afforded
confidential treatment at all times. We work hard to protect against the unauthorized access, use, alteration or
destruction of personal or financial information. All such electronic information is stored on restricted database
servers, and is generally kept until such time as you may ask us to edit or delete it, as described below. We only
disclose such information to our employees, contractors or affiliates that a) need to know that information in order to process it for us or to provide other services, and b) have agreed not to disclose it to others.
In addition to assuring you that we will protect your personal information, we also want to make sure that it is reliable, accurate, and up-to-date. In order to do that, we provide:
Access. Upon request, we will provide you with reasonable access to the personal information we collect about you. Because personal information—for example, your email address—is required to use The Services, we retain personal information as long as your account is active. You will have the opportunity to correct, update, modify or delete this information updating your information in the Services. Please note that some information may remain in our records even after you request deletion of your information. Additionally, there may be limits to the amount of information we can practically provide. For example, we may limit an individual’s access to personal information where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where doing so would violate others’ rights.
Enforcement. We will take all reasonable measures against any employee or other agent found to be in violation of this policy.
If you have any concerns or complaints about how you think we’ve handled your personal information, please contact info@directivecommunications.com]. We will make every reasonable effort investigate and resolve any complaints you might have.
HOW TO CONTACT US
If you have any questions about this policy or our site in general, please contact us at info@directivecommunications.com.