Effective Date: May 25, 2018
Directional Alpha, LLC (“Directional Alpha”) owns and operates www.DirectionalAlpha.com website business. All references to “we”, “us”, “our”, this “website” or this “site” shall be construed to mean FTC Guardian.
Regarding Personal Data (defined below), if any modifications are materially less restrictive regarding our use or disclosure of the Personal Data previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
We may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
THE TYPES OF DATA WE COLLECT
“Personal Data” means data about a living individual who can be identified from those data (or from those data and other information either in our possession or likely to come into our possession).
Personal Data may include, but is not limited to:
- First name and last name
- Email address
- Phone number
- Business name
- Website URL
- Address, State, Province, ZIP/Postal code, City
- Any Personal Data you post on our website
- Any Personal Data you post on a social media platform
- Data about how you use our website
- Technical data such as your IP address, your login data, details about your browser, time zone settings and other technology on the devise you use to access our website
- Your marketing and communication preferences
- Any information that you directly provide to us whether through our contact form ,over the phone, by email or otherwise
- Geo-location data
- Cookies and Usage Data
Passively or Automatically Collected Data (“Usage Data”).
We may also collect information regarding how our service is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Geo-Location Data. We only collect basic personal information about you which does not include any special types of information or location-based information (GPS data). However, if you are accessing a page from a computer or a mobile device, in some cases you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience when we work with a marketing partner such as a third-party service provider, advertiser, or advertising network and platform. If you agree to the collection of location data, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device.
HOW AND WHEN WE COLLECT DATA
Personal Data. We collect Personal Data on the public areas of our site through opt-in forms. We may collect publicly available Personal Data posted publicly with social media profile information.
Your Communications with Us. We collect your Personal Data on the public areas of this site if you complete any of our opt-in forms and/or participate in our follow-up.
Usage Data. We collect Usage Data as you use the public areas of this site, including your interactions with emails we send, and via social media platforms, and services of our marketing partners. This data may be passively or automatically collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies, web beacons, locally stored objects, and mobile device identifiers and SDKs, and other similar methodologies as well as similar technologies developed in the future. (See below, SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS.)
HOW WE USE YOUR DATA
We may use your Personal Data collected from the public areas of this site if you complete any of our opt-in forms and/or participate in our follow-up.
We may use publicly available Personal Data posted on social media profile information including photos for purposes of assisting us, and our marketing partners with marketing and advertising activities and with contact management.
RETENTION OF DATA
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.
TRANSFER OF DATA
Our Company is located in the United States and we do extensive travels. Your submission of your Personal Data via this website will transfer your Personal Data to us. We will not transfer your Personal Data outside the United States unless the transfer is made to a country or territory recognized by the EU as having an adequate level of data security, or is made with your consent, or is made to satisfy our legitimate interest regarding our contractual arrangements with our subscribers that have contracted for access and use of our online services.
DISCLOSURE OF DATA
General Disclosure Policy. We may share and disclose your Personal Data as described below.
Affiliated Entities. We may provide your Personal Data and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.
Service Providers. We may provide access to your Personal Data and Usage Data to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to host our servers, provide security, and optimization, analytics, reporting, and software maintenance and development services. In addition, our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
Legal Process, Enforcement and Security Notice. We may disclose your Personal Data and Usage Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site.
Marketing Partners. We may share your Usage Data with our marketing partners to serve and offer personalized ads. We may share Personal Data with our marketing partners to correlate and match our list with our marketing partners’ lists for purposes of creating an “audience” for serving personalized ads.
With Your Consent. We may share your Personal Data with other parties with your consent.
YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by using the form located in the contact us section of our website.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS
“Cookies” are tiny pieces of information stored by your browser on your computer’s hard drive. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our site.
Flash Cookies – third party cookies that use an Adobe Flash Media Player local shared object (LSO) – may be used along with other third-party cookies for purposes of crediting any purchase you may make on this site to one of our joint venture partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as “browser cookies”. The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.
Web Beacons (sometimes called single-pixel gifs or clear gifs) are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.
Locally Stored Objects – we may employ locally stored objects (“LSOs”) and other client-side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our Partners target ads, analyze ad performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access Flash management tools from Adobe’s website: –> http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html . In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.
We may participate with our marketing partners for purposes of providing personalized ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage advertising activities.
AdWords (Google) – We may participate in AdWords program which is a personalized ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit –> https://support.google.com/ads/answer/2662922?hl=en
Google Analytics for Display Advertising (Google) – We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out, visit –> https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –> https://tools.google.com/dlpage/gaoptout
For information in general about Google’s personalized ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google’s advertising cookies for these campaigns, visit –> http://www.google.com/policies/technologies/ads/
For information regarding how Google uses data when you use Google’s partners’ sites or apps, visit –> http://www.google.com/policies/privacy/partners/
Custom Audience (Facebook). We may participate in Facebook.com’s Custom Audience program which enables us to display personalized ads to persons on our email lists when they visit Facebook.com. We provide Personal Data such as your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the email address provided in our contact information below. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.
Tailored Audiences/Conversion Tracking Programs (Twitter). We may participate in Twitter.com’s Tailored Audiences/Conversion Tracking Programs which enable us to display personalized ads. You may opt-out of participation in these programs by visiting https://support.twitter.com/articles/20170405 .
Other Personalized and Behavioral Advertising services. We may participate in additional retargeting and behavioral advertising services that will be similar to the services described above.
Managing Personalized Ads. You can control the placement of cookies and other data collection methodologies for purposes of opting out.
Managing Cookies Via Your Browser. You should note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first party or third-party cookies or to indicate when a third-party cookie is being sent. However, disabling or limiting cookies may cause certain features of this website to not function properly or optimally. Check your browser’s “Help” files or other similar resources to learn more about handling cookies on your browser. In addition, visit –> http://www.allaboutcookies.org/manage-cookies/
Managing Flash Cookies. Flash cookies, also called local shared objects (LSOs), function similarly to standard cookies except that they are often larger and are downloaded to a computer or mobile device by the Adobe Flash Player. In some cases, these Flash cookies can be managed through browser settings. Adobe also provides a means of controlling Flash cookies on its Flash Player: Setting Manager page.
Digital Advertising Alliance (DAA). DAA member advertising associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit DAA Consumer Opt-Out page –> http://www.aboutads.info/consumers .
Opting Out with Ad Choices for Mobile Devices. When using mobile applications you may receive personalized in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of personalized in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of these advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.
We may participate with third party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site.
Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. Information collected: cookie and Usage Data.
You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –> https://tools.google.com/dlpage/gaoptout .
DO NOT TRACK REQUESTS
Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.
We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Data by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site.
UPDATING PERSONAL DATA
Upon request, we will permit you to request or make changes or updates to your Personal Data for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Data in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her Personal Data without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted.
Your California Privacy Rights. Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase “California Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.
Directional Alpha, LLC
10411 Motor City Drive, Suite 750
Bethesda, MD, 20817. USA
Copyright © 2017-2019 Directional Alpha, LLC. All rights reserved.