Privacy Policy

This Privacy Policy was last revised and shall become effective as of February 1, 2021.

Welcome to directtoconsumer.co (the “Site”). The Site is an Internet property of Pilothouse Digital Ltd. and its affiliated companies (“Pilothouse”, “our”, “we” or “us”). Pilothouse is committed to protecting your privacy. We have prepared this privacy policy (“Privacy Policy”) to describe to you and to outline our practices and policies associated with any information (such as Site Data, Anonymous Data, and Personal Data, each as defined below) that we may collect from you, or that you may share with us when you access or use the Site, or when you use any of the related products and/or services being made available to you through the Site.

BY ACCESSING THE SITE, OR USING ANY PRODUCTS AND/OR SERVICES MADE AVAILABLE TO YOU THROUGH THE SITE, YOU HEREBY ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY IN ITS ENTIRETY.

In summary:

  • We collect information about you and how you use the Site and any of the products and services made available to you through the Site or through any of our affiliated website(s).
  • If you opt in to our newsletter(s), we’ll send you emails and other stuff that may be of interest to you. You can unsubscribe from our marketing emails at any time.
  • We collect Personal Data, Site Data, and Anonymous Data (as defined below) to make the Site and any of our affiliated website(s), including any of our products and services, more useful to you.
  • If we do collect Personal Data (as defined below), we will only use this information for lawful purposes and will store and retain this information for as long as required by applicable law.
  • You can contact us at any time to update or remove any Personal Data that we have collected and stored about you.

Lawful Basis for Processing Data

In certain jurisdictions, the processing of your Personal Data (as defined below) is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:

  • Consent. By using the Site, or otherwise submitting your Personal Data to us, you consent to our collection, use and sharing of your information as described in this Privacy Policy.
  • Legitimate Interest. We will process your Personal Data based on Legitimate Interest, and particularly where it is used for marketing and business purposes, and to contact you to start a conversation regarding your use of the Site or any newsletters that you wish to join.
  • Legal Obligation. We may also process your Personal Data based on other lawful basis such as where the processing is necessary to comply with applicable law.
  • Contract. We may process your Personal Data where such processing is required in order to fulfill an agreement or contract with you.

How We Collect and Use Personal and Anonymous Data

When you access the Site, register for any associated products and/or services made available to you through the Site, or opt-in to receive newsletters and other communications from us, we may collect Personal Data and Anonymous Data from you. We may also collect Personal Data and Anonymous Data when you directly contact us. 

“Personal Data” means data that allows someone to identify or contact you, including, for example, and without limitation:

  • your name;
  • your Internet Protocol (IP) address;
  • your physical address (address, state/province, ZIP/postal code, country);
  • your electronic mail (email) address;
  • your phone number; 
  • your account username; and
  • your geographic location or geolocation.

Personal Data may be used for the purposes of recording the transaction when you access the Site, or when you use any of the associated products and/or services being made available to you through the Site. Pilothouse does not knowingly collect any sensitive personal data or any data defined under special categories of the applicable law(s). We do not (knowingly) collect personal information from persons under the age of (18) eighteen. 

We may also use Personal Data for the following purposes:

  • to fulfill your requests to access the Site, and to access and use any associated product(s) and/or service(s) that are being made available to you through the Site;
  • for use relating to internal business analytics;
  • to prevent fraud;
  • to send you information about technical notices, updates, security alerts, and support and administrative messages;
  • to engage with third-party service providers so that you can access and use the Site and any associated product(s) and/or service(s);
  • to respond to your communications with Pilothouse;
  • to communicate with you about products and services offered by Pilothouse, its affiliated companies, and its selected partners;
  • to contact you to resolve problems that you may encounter with the Site and any associated product(s) and/or service(s); and
  • to periodically conduct product and market research regarding your use of (i) the Site; (ii) any associated product(s) and/or service(s) that are being made available to you through the Site; and/or (iii) any associated product(s) and/or service(s) that are being made available to you through any of our affiliated companies.

If and when we use a third-party technical support provider or third-party hosting provider, we ensure that the same privacy criteria as defined herein with respect to Personal Data are in place with such providers.

“Anonymous Data” refers to data about you that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. If and when we use a third-party technical support provider or third-party hosting provider, we ensure that the same privacy criteria as defined herein with respect to Anonymous Data are in place with such providers. We do not (knowingly) collect Personal Data from persons under the age of (18) eighteen.

To make the Site more useful to you, our servers (which may be hosted by a third-party service provider) may collect Personal Data or Anonymous Data from you such as browser type, operating system, Internet Protocol (IP) address, domain name, Site usage and statistics, and/or a date/time stamp of your visit to the Site. We may also use cookies and navigational data like Uniform Resource Locators (URL) and referring URLs to gather information regarding the date and time of your visit. We may also use Personal Data and Anonymous Data for market research purposes and to improve our products and services and the Site. 

We may share Anonymous Data with selected third parties and business partners, however, we will not share any Anonymous Data if such information is, contains, or will be linked to your Personal Data, unless we have given you notice, as described in this Privacy Policy, and you have given us authorization to do so. Pilothouse will use Personal Data and IP addresses to identify users of the Site if and when we feel it is necessary to enforce compliance with the Site’s policies or to protect our products and services, the Site, or other users of the Site and/or the products and services being made available through the Site.

We offer you choices regarding the collection, use, and sharing of your Personal Data. We will periodically send you newsletters and emails that directly promote the use of the Site and any associated product(s) and/or service(s), or other third-party products and/or services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive, or by contacting us directly (please see contact information below). Should you decide to opt-out of receiving future mailings from us, or from any of our affiliated companies, you may continue to receive future mailings from third parties that you have requested to receive information from. If you do not wish to receive future communications from third-party providers, you should notify them directly of your choice regarding their use of your Personal Data. To opt-out of having future third-party marketing communications sent to you, you will be required to unsubscribe with the applicable third-party providers. Despite your request to no longer receive future newsletters or promotional and marketing communications from us, we reserve the right to continue to send you notices of any updates to the Site, our products and services and the products and services of our affiliate companies, our Terms of Use, and our Privacy Policy.

How We Collect and Use Site Data

“Site Data” refers to data about how you use the Site. We may collect certain information from you including, but not limited to, User IP addresses, OS version, OS localization, device type, etc. We obtain this information from third-party traffic monitoring service providers. Other than User IP address, the Site does not, and will not, collect any other Personal Data from you without your prior approval. The Site Data we collect is primarily used to report Site usage and statistics, to improve the Site, and to track the performance of various marketing initiatives. Site Data may also be used by Pilothouse to answer questions about the general use of the Site and/or any associated product(s) or service(s).

Sharing of Personal Data

We will never sell, trade, or rent any Personal Data, Site Data, or any Anonymous Data that may contain Personal Data, to any third party without your explicit consent.

In certain special cases, we may disclose Personal Data when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to you, or is otherwise injuring or interfering with our rights, property or operations, other users of the Site or any associated product(s) and/or service(s), or anyone who could be harmed by such activities. We may also disclose your Personal Data and any Site Data when we believe the law requires it or in response to any demand by law enforcement authorities in connection with criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.

If we determine, in our sole discretion, that you have engaged in conduct that might be considered unlawful, fraudulent, or might harm or damage the reputation or standing of Pilothouse with either the general public or with a business partner or potential business partner of Pilothouse, we reserve the right to release your Personal Data to such persons or third parties, as we consider necessary, to prevent you from causing injury to, or otherwise injuring or interfering, now or in the future, with our rights, property or operations or otherwise the rights, property or operations of anyone which could be harmed by such conduct.

Your Rights with Respect to Your Personal Data

This section applies if you are located in the European Union (EU) or European Economic Area (EEA). In accordance with applicable privacy law, you have the following rights in respect of any Personal Data that we may hold about you:

  • Right of access and portability. The right to obtain access to and to receive your Personal Data.

 

  • Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that personal information is inaccurate or incomplete.

  • Right to erasure. The right to obtain the erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.

  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, and for a period time that would enable us to verify the accuracy of such Personal Data.

  • Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Data, and to object to processing of your Personal Data for direct marketing purposes, to the extent it is related to such direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy. You also have the right to lodge a complaint with your local data protection authority.

 

California Residents: Your California Privacy Rights

California Consumer Protection Act

Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what Personal Data we collect from you, to delete such Personal Data, and to opt-out of the sale of your Personal Data (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.

Right to Know

If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:

• The specific pieces of Personal Data we have about you;

• The categories of Personal Data we collected, sold, or disclosed for a business purpose about you within the last twelve (12) months;

• The categories of sources from which the Personal Data was collected;

• The purposes for which the Personal Data was collected or sold; and

• The categories of third parties to whom the Personal Data was sold, disclosed for a business purpose, or otherwise shared.

If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to contact Pilothouse.

Right to Delete

If you are a California resident, you may submit a verifiable request for us to delete the Personal Data we have collected about you. The easiest way to submit a request for deletion is to contact Pilothouse.

Right to Opt-Out

California residents may opt out of the “sale” of their Personal Data, as defined by the CCPA. This does not include when:

• You direct us to disclose your Personal Data or use us to interact with a third party and the third party does not sell the personal information;
• We use or share an identifier solely to alert a third party you have opted out of the sale of your Personal Data;
• Your Personal Data is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
• We use or share your Personal Data under a written contract with a service provider necessary to perform a business purpose. Here, the service(s) that the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your Personal Data for any purpose other than for the specific purpose identified in the contract.

In these cases, the disclosure of your Personal Data would not be considered a “sale” under CCPA. We use and share your Personal Data as described in this Privacy Policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold Personal Data about you in the last twelve (12) months and currently have no plans to do so in the future. However, we have provided you with a system to record your preference that your Personal Data not be sold in the future. You may make this request by contacting Pilothouse.

Right to be Free from Discrimination

We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our owned and/or operated websites.

Authorized Agents

If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.

Cookies and Similar Technologies

A cookie is a small piece of text that is sent to your web browser by the Site. The cookie helps the Site remember information about your visit, which makes your next visit to the Site easier and the Site more useful to you. We also use cookies for tracking and reporting purposes, to make the ads that you may see more relevant to you, and to count how many visitors we receive to a page on the Site. The information collected by cookies is used to enhance your experience with on the Site, for marketing analysis, for targeted and display advertising, and for quality improvement of the Site and our products and services. No personally identifiable information is collected or stored by Pilothouse during this process. We may use your IP address to identify your general location for traffic monitoring purposes. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site functionality.

Do Not Track

If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs third-party service providers not to track your future activities when that cookie is detected (a “do-not-track” cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a “do-not-track” cookie cannot be set on your computer. Also, if you subsequently erase “do-not-track” cookies, use a different computer or change web browsers, you will need to opt-out again. We currently do not respond to browser "do-not-track" signals.

Third-Party Relationships

Third-party Links. The Site, our newsletters, and our product(s) and/or service(s) may contain links to other third-party owned and/or operated websites and, where you request information from third-party providers, we may transfer you directly to the websites of such third-party providers. Pilothouse is not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be required to provide certain information to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such third-party website. These third-party entities are independent third parties and are not affiliated with Pilothouse.

Third-party Offers

Pilothouse may provide you with the opportunity to receive special offers, products and/or services from third parties. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your Personal Data that was provided during that information collection process will be shared with the applicable third party so that such third party may provide their products and/or services to you without the need for you to complete another information collection form in order to purchase or receive that product or service. Clicking on any third party offers may add and place cookies on your computer prior to directing you to the applicable third party’s site. These third parties have separate cookie polices and Pilothouse has no responsibility or liability relating to them. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site functionality.

Third-party Technology/Software/Service/Solutions Providers

The Site, and any product(s) and or service(s) being made available through the Site, may contain certain software technologies and services licensed from third-party providers. Pilothouse may engage with certain third-party services and solutions providers such as data hosting service providers, payment processing service providers, and email marketing service providers. These third-party providers have separate privacy and data collection practices and policies, and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of the terms and conditions of any third-party privacy policies. These third-party entities are independent third parties and are not affiliated with Pilothouse.

Pilothouse may be using or sharing your Personal Data for Legitimate Interest purposes with third parties service providers, which may include, without limitation:

Security of Data

Pilothouse is committed to protecting the security of any Personal Data that it collects and stores. We use a variety of industry-standard security technologies and procedures to help protect any Personal Data from unauthorized access, use, or disclosure. Despite these measures, no method of transmission over the Internet, or method of electronic storage is 100% secure. Pilothouse cannot fully eliminate security risks associated with the collection and storage of any Personal Data, including without limitation, any mistakes and security breaches that may happen. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the unlikely event of a data breach where your Personal Data has been compromised, Pilothouse will promptly notify you, the applicable authorities and supervisory authorities or data protection authorities.

If you are located in the EU/EEA and Pilothouse is required to transfer your Personal Data in accordance with this Privacy Policy, we exert commercially reasonable efforts to ensure that any transfer of your Personal Data outside of the EU/EEA is protected under industry-standard contractual clauses and any subsequent data protection safeguards. Where EU Data Protection Law applies, Pilothouse shall not process its collected Personal Data (nor permit its collected Personal Data to be processed) in a territory outside of the EU/EEA unless it has taken such measures as are necessary to ensure the transfer is in compliance with EU Data Protection Law. Such measures may include (without limitation) transferring its collected Personal Data to a recipient in a country that the European Commission has decided provides adequate protection for Personal Data, to a recipient that has achieved binding corporate rules authorization in accordance with EU Data Protection Law, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.

Data Retention Period

Any Personal Data that is collected and stored by Pilothouse will be retained only for as long as required in order to provide certain products and/or services to you, or as required by applicable law. Any Personal Data that is no longer required by Pilothouse will be destroyed.

Contact Information

If you have any questions regarding this Privacy Policy, would like to review, update or remove your Personal Data, or would like more information on our data collection, usage, and privacy practices, please contact us at:

Pilothouse Digital Ltd.

1011 Government St. 

Victoria, BC V8W 1X6

Canada

team@directtoconsumer.co

We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you have failed to provide us with sufficient information to verify your identity.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to modify, update and change this Privacy Policy from time to time without prior notice to you. Notice regarding any Privacy Policy changes will be placed in a prominent location on the Site and will take effect immediately upon posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site following the posting of changes to this Privacy Policy will constitute your acknowledgment and acceptance of any and all changes.