EU General Data Protection Regulation – GDPR

European Union (EU) General Data Protection Regulation (GDPR)

GDPR Privacy Statement. Effective Date: May 25, 2018

Directional Alpha, LLC (“Directional Alpha”) owns and operates this www.DirectionalAlpha.com website business.  All references to “we”, “us”, or “our” shall be construed to mean Directional Alpha.

Directional Alpha will be acting as the “Controller” of the personal data you provide to us. This includes your personal contact information and the contact information of your affiliated organization. We only collect basic personal information about you which does not include any special types of information or location-based information (GPS data).

If you are an employee or other personnel of one of our customers which have entered into an agreement with us for the provision of our products or services, we will be acting as the “Processor” of your personal data which will be governed by the Data Processing Agreement (DPA) agreed with each of the Processors listed below.

WHY WE NEED YOUR DATA

We need to know your basic personal data consisting of contact information for purposes of sending our Newsletters, analysis in different formats, e-Books, product releases, marketing material, product promotions, marketing campaigns, affiliate product links, book releases, Videos, Webinars, Podcasts, and responding to your inquiry on our Contact Us web page and similar web pages.

In addition, we need to know your personal data to send you emails for other specific purposes only if you have explicitly given your consent to receive these emails.

WHAT WE DO WITH YOUR DATA AND LIST OF DATA PROCESSORS AND SUB-PROCESSORS

Your personal data is processed by us in the United States of America (USA); however, for purposes of hosting and maintenance, payments, electronic payments, Email Marketing Services, Email Management Services, Social Media Services, Affiliate Marketing Services, your personal data may be archived on servers provided by:

– GoDaddy.com, LLC or GoDaddy.com which are located in Corporate Headquarters 14455 N. Hayden Rd., Ste. 226. Scottsdale, AZ 85260 USA. Phone number: +1 (480) 505-8800. Fax number: +1 (480) 624-2546.

– Sumo Group Inc. (d/b/a “AppSumo”,”Sumo”,”Sumo.com”) 1305 E. 6th St #3. Austin, TX 78702. USA.

– The Rocket Science Group LLC d/b/a MailChimp or www.MailChimp.com. 675 Ponce de Leon Ave NE, Suite 5000. Atlanta, GA 30308. USA.

– Zoho Corporation or www.Zoho.com . 4141 Hacienda Drive. Pleasanton, California 94588, USA.

– Shopify Inc or www.Shopify.com. 150 Elgin Street, Suite 800. Ottawa, ON K2P 1L4. Canada.

– Stripe. 185 Berry Street, Suite 550. San Francisco, CA 94107. USA.

– PayPal, Inc. or www.paypal.com. 2211 North First Street San Jose, California 95131. USA.

– Dropbox, Inc. or Dropbox International Unlimited Company or www.Dropbox.com. Address: 333 Brannan Street. San Francisco, CA 94107. USA.

– Amazon.com, Inc. or Amazon Services LLC or Amazon’s website www.Amazon.com or any of its affiliate companies. Amazon.com, Inc. P.O. Box 81226. Seattle, WA 98108-1226. https://www.amazon.com

– Udemy, Inc.  www.udemy.com. 600 Harrison St. 3rd Floor. San Francisco, CA 94107. USA.

– WordPress.com and/or WordPress.com and/or Automattic Inc. 60 29th Street #343. San Francisco, CA. 94110. USA.

– Google LLC. Or www.Google.com. 1600 Amphitheatre Parkway. Mountain View, CA 94043. USA.

which are located in the USA, Canada, the EU and/or other locations where each Processor and/or of their designated Sub-Processor(s) operates. If we are acquired by another party, we will share your personal data with the acquiring party.

We maintain a data protection regime for the effective and secure processing of your personal data governed by the Data Processing Agreement (DPA) agreed with each of the Processors and and/or Sub-Processors listed above.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practices to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.

HOW LONG WE KEEP YOUR DATA

We will not retain your personal data for longer than required. This means that we will keep your personal information: (i) for as long as required by law, (ii) until we no longer have a valid reason for keeping it, or (iii) until you request us to stop using it.  When we delete your personal data from our databases, it will remain in our backup system until it cycles out.

We will delete your personal data that you provide for purposes of responding to your inquiry on our Contact Us web page and similar web pages after 1 (ONE) Year, unless you are continuing to request information from us.

WHAT ARE YOUR RIGHTS

You have right to: (i) request access to and rectification or erasure of your personal data, (ii) request restriction of processing your personal data, and (iii) withdraw your consent at any time. If you provide a notice to us regarding your exercise any of the above rights, we will forward your notice to other authorized parties which are holding and processing your personal data, where appropriate.

If you wish to raise a complaint regarding how we have processed your personal data, you can contact us with the Contact Us information below, and we will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you may complain to the data protection officer in the country in which you reside.

HOW TO CONTACT US

Directional Alpha, LLC
10411 Motor City Drive Suite 750
Bethesda, MD, 20817. USA
Telephone: (+1) 3019081514
Contact: info@DirectionalAlpha.com

Document Updated as of May 25, 2018


GDPR Directional Alpha, LLC Processors and Sub-processors
Effective Date: May 25, 2018

A list of Processors and and/or Sub-Processors currently authorized by Directional Alpha, LLC (Directional Alpha) to process Customer Data and assist Directional Alpha with respect to the provision of the applicable Services under the Directional Alpha customer agreement is set out below:

             Processor / Sub-processor

Description – Summary

GoDaddy.com, LLC or GoDaddy.com Website Hosting, Website Domain management, Email Management and Marketing, Secure Sockets Layer – SSL Certificates, Website Security Services, and Internet Management Services, WordPress Services and Management.
Sumo Group Inc. (d/b/a “AppSumo”,”Sumo”,”Sumo.com”) Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company
The Rocket Science Group LLC d/b/a MailChimp or Mailchim.com Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company
Zoho Corporation or www.zoho.com Email Marketing, Email List Building, Contact Forms, Pop-up Forms, Mat Forms, Email collection, and related Email, Traffic Tracking, Website Traffic related Software Company
Shopify, Inc or www.Shopify.com E-commerce, Online Payment, and related e-commerce and affiliate marketing software Company.
Stripe or www.Stripe.com Online Payment, processing and related E-Commerce software Company.
PayPal, Inc. or www.paypal.com Online Payment, processing and related E-Commerce software Company.
Amazon.com, Inc. or Amazon Services LLC or Amazon’s website www.Amazon.com or any of its affiliate companies. Affiliate Marketing, Merchandise, Products, Services, Online Payments, and related e-Commerce Company/Services.
Dropbox, Inc. or Dropbox International Unlimited Company or www.Dropbox.com Online data and information storage services, online users’ collaboration services, and data processing and analysis related services.
Udemy, Inc.  www.udemy.com Online Learning Management System Services, Online Courses and Classes Delivery System, Online Payment and Management System, Online Tracking traffic services.
WordPress.com and/or WordPress.com and/or Automattic Inc. Web Blog and website hosting and Traffic Online Platform
Google LLC. or www.Google.com Website, traffic, tracking, data analysis, data analytics, Data Analysis and Management, Video services, Music & Video Management and streaming services, Website tracking and related website information, email services, and online tools, e-commerce, data online storage services, online users collaboration services, and data processing and analysis related services.

How to Subscribe to Receive Notification of Change in Processor(s) and/or Sub-Processor(s):

If you are a current Directional Alpha customer with a Data Processing Agreement in place with Directional Alpha, you may subscribe to receive notifications of new Processor(s) and/or Sub-Processor(s) for each applicable Directional Alpha Service before Directional Alpha authorizes any new Processor(s) and/or Sub-Processor(s) to process personal data in connection with the provision of the applicable Service.

You can subscribe to receive email notifications for changes to Directional Alpha Processor(s) and Sub-processor(s) by emailing the following information to info@DirectionalAlpha.com:

  • Customer Name
  • Customer Address
  • Executed copy of the Customer- Directional Alpha Data Processing Agreement (DPA)

To edit your email notification information, please re-submit a request to info@DirectionalAlpha.com with the title “Change in Contact Information”.

Right to Object to New Sub-processor:

A Customer with a Data Processing Agreement in place with Directional Alpha may object to Directional Alpha’s use of a new Processor and/or Sub-Processor by notifying Directional Alpha promptly in writing within ten (10) business days after receipt of Directional Alpha’s notice in accordance with the mechanism set out above.

If you object to a new Sub-processor, and that objection is not unreasonable, Directional Alpha will use reasonable efforts to make available to you a change in the applicable Service or recommend a commercially reasonable change to your configuration or use of the applicable Service to avoid processing of personal data by the objected-to new Sub-processor without unreasonably burdening you.

If Directional Alpha is unable to make available such change within a reasonable period of time, which shall not exceed thirty (30) days, you may terminate the applicable Order form(s) or customer agreement with respect only to those Service(s) which cannot be provided by Directional Alpha without the use of the objected-to new Sub-processor by providing written notice to Directional Alpha at:

Directional Alpha, LLC
10411 Motor City Drive Suite 750
Bethesda, MD, 20817. USA

Document Updated as of May 25, 2018


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