This davidoni.global website is owned and operated by En Masse LLC (“En Masse“) (also referred to as “we”, “us”, this “website” or this “site”).
We use the term “services” in this Privacy Policy to refer both to services and products (tangible, intangible, and digital), as applicable.
This Privacy Policy describes our collection, use, and sharing of personal data.
Our Privacy Policy applies to all of the services offered by us and our affiliated entities, including services accessed by mobile devices and application programming interface (API), but excludes services that have separate privacy policies which do not incorporate this Privacy Policy.
We do not display personalized ads via third-party cookies on our website. (See below, No Personalized Ads Via Third-Party Cookies)
Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, web beacons (pixel tags), and other methodologies to serve personalized ads.
HOW WE MODIFY THIS PRIVACY POLICY
We may modify this Privacy Policy at any time without prior notice. Please check this page periodically for updates. If any update provides a material change regarding personal data, we will post the material changes here and notify you either by email or by notice on this site.
THE TYPES OF DATA WE COLLECT
Personal Data
We use the term “personal data” to refer to any information regarding a natural person that may be used directly to identify the person (e.g., name and email address).
Personal data also includes usage data that is automatically collected when you use this site including other interactions with us. Usage data that does not directly identify you by name or include your contact information, may be used to identify that a specific computer or device has accessed our site and which if combined with certain other information could be used to identify you. (See below, AUTOMATICALLY COLLECTED INFORMATION WHEN YOU USE THIS SITE)
HOW AND WHEN WE COLLECT INFORMATION
When You Provide Personal Information to Us
We collect personal data at the time you provide it to us. We may collect personal data through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest from this website. Personal data that we collect may vary with each sign-up or registration. As indicated above, we may collect publicly available personal data posted on social media profile information including photos both directly and through the use of contact management applications.
Automatically Collected Information When You Use This Site
We and/or our third-party service providers collect device information, IP addresses, and other usage data about your computer or device and usage data as you use this site and track across third-party websites, including your interactions with emails we send, and via social media platforms, third-party platforms, third-party websites, applications, and integrations, 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, and other similar methodologies. (See below, COOKIES AND WEB BEACONS)
OUR LEGAL BASIS FOR HANDLING YOUR PERSONAL DATA
What is Legal Basis?
Legal basis includes the legal grounds we rely on to collect, use, and share personal data.
Legitimate Interest
Generally, we handle personal data on the ground that it supports our legitimate interests in providing our services in a way that does not preclude the interests or fundamental rights and freedoms of the affected individuals. Our legitimate interests include: (i) providing our services with our clients; (ii) marketing our services; (iii) protecting the interests of our clients; (iv) monitoring, analyzing, and improving our services and business; and (v) complying with our legal, professional, and ethical obligations and issues.
Consent
Where required by applicable data protection laws and in some other cases, we handle personal data based on the ground of consent, either express or implied, given by the affected individuals.
Obligations to Our Clients
Regardless of whether our role is as data controller or as data processor (see below, PRIVACY CHOICES) we will handle personal data on behalf of our clients based on the ground of compliance with our contractual obligations as well as our legal and ethical obligations.
HOW WE USE AND PROCESS YOUR INFORMATION
Generally, we may use and process your personal data for the performance of the services or transaction for which it was given and for the basic purpose of this site.
We may use your personal data (i) in connection with our products, services, or promotions we may offer, (ii) our private, internal reporting for this site, and security assessments for this site to (iii) monitor and improve the operation of this site, market our services, improve the quality of our services; and (iv) for educational, research, analytics, networking, social, and other business purposes. We may also send you email messages related to site updates and certain site features or your activity on this site.
To assist us with these uses, we may supplement the data we collect from you with information from other sources including our clients, other referral sources, and publicly available sources (e.g., social media).
This Privacy Policy does not place any restriction on our use of anonymized, de-identified or aggregated information we may create based on information that you submit.
We use, process, and archive personal data including usage data in the United States and in other countries that may not have data protection laws as protective as those in your location.
We may also send you messages related to certain features or your activity on this site. We may also send you news or updates about changes to our site or services. By default, you will receive these messages via email.
INFORMATION SHARING AND DISCLOSURE
We may share your personal data with your consent and otherwise, as follows:
Within our Family of Companies
We and our subsidiary and affiliated companies may share your personal data among and between each other for the purposes described in this Privacy Policy.
In Connection with Business Transfers
If we sell or transfer a business unit (such as a subsidiary) or an asset (such as a website) to another company (including in connection with any bankruptcy or similar proceedings), we will share your personal data with such company and will require such company to use and protect your personal data consistent with this Privacy Policy. We may also share your personal data with companies that were formerly wholly or partly included in our family of companies to whom we provide services during a transition period following separation.
With Providers (See below, NO PERSONALIZED ADS VIA Third-Party Cookies)
We may retain other companies and individuals to perform services on our behalf and we may collaborate with other companies and individuals with respect to research, products or services, and marketing (collectively, “Providers”). These third parties may be provided with access to personal data needed to perform their functions, but they may not use such data other than on our behalf or subject to contracts that protect the confidentiality of the data. Examples of Providers include credit card processing companies, customer service and support providers, email and SMS vendors, data analytics firms, web hosting and development companies, and fulfillment companies. Providers also include our co-promote partners for products that we jointly develop and/or market with other companies. Some Providers may collect personal data on our behalf on our site.
To Comply with Law and Our Duty to Protect
We reserve the right to disclose your personal data as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of us, our customers, the public, or others.
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 data 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 Web site 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. (See below CONTACT US)
COOKIES AND WEB BEACONS
Cookies
“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.
We may use cookies and other data collection methodologies discussed below to collect personal data and usage data to assist with navigation, monitoring site usage, and web traffic, assist with our promotional and marketing efforts and personalized ads, and customize and improve our site and services.
Web Beacons
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.
No Personalized Ads Via Third-Party Cookies
We do not partner with third-party advertising networks to either display personalized ads on our website or to manage our advertising on other sites via the use of third-party cookies and other third-party tracking devices. We reserve the right to serve personalized ads that are based solely on first-party cookies and other tracking devices from this site.
How to Manage Cookies
You can control the placement of cookies and other data collection methodologies for purposes of opting out. 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/
Network Advertising Initiative (NAI)
Some companies that use cookies to collect information about your online activities are members of NAI, which offers a single location to opt out of receiving personalized ads from member companies. To opt out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, please visit the NAI consumer opt-out page: –> http://www.networkadvertising.org/choices/ .
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.
ANALYTICS
We may participate with third-party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site via third-party cookies. These third-parties place or recognize a unique third-party cookie on your browser, and they may use web beacons (pixel tags). (See above COOKIES AND WEB BEACONS)
Google Analytics is a third-party web analysis service that may use third-party cookies and web beacons (pixel tags). 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: personal data including usage data and cookie 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
We do not respond to “Do Not Track” signals at this time.
DATA SECURITY
We will implement and maintain administrative, technical, and physical safeguards to protect information that we collect. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. We do not, and cannot, ensure or warrant the absolute security of your information.
PRIVACY CHOICES
If We Act as Data Controller
If we act in the capacity as data controller, you may request that we: (i) provide access to and/or a copy of certain personal data (in some cases in portable form; (ii) prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling); (iii) update personal data that is out-of-date or incorrect; (iv) delete certain data that we possess about your; (v) object to our processing of personal data; (vi) restrict the way we process or disclose certain of your information; (vii) transfer your personal data to a third party, of (viii) honor a revocation of your consent for processing personal data (without retroactive effect).
How We Handle Your Requests
We will review and consider all requests and provide our response in accordance with time and other requirements of applicable law. Please understand that our obligations to comply may be restricted by applicable law (e.g., if we are required to retain and process your information for our legitimate interest or to comply with a legal obligation). We may request information sufficient to confirm your identity before responding to your request. Although you have the right to lodge a complaint with the applicable regulatory authorities, please contact us first so that we may assist with a prompt resolution of your concerns. (See below, CONTACT US)
YOUR DATA PROTECTION RIGHTS UNDER GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights, as summarized below. If you have questions or need assistance, contact Us. (see below, CONTACT US)
The right to access, update or to delete Your information
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.
RETENTION PERIOD
We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the site to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the site Terms of Use and other contractual obligations, applicable statutes of limitations, litigation or regulatory investigations).
ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE
Any personal data which we may collect on this site will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of personal data outside your country of residence to the United States.
UPDATING PERSONAL INFORMATION
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.
CHILDREN’S ONLINE POLICY
We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information 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 (see below, CONTACT US), and be sure to include in your message the same login information that your child submitted.
CALIFORNIA’S ONLINE “ERASER” LAW FOR MINORS
Minors who reside in California and are registered users for any service provided by this site may remove or request us to remove any content or information they have posted to this site. Please understand that any such removal does not ensure complete or comprehensive removal of the posted information (if, for example, the content or information is “invisible” to others but remains on our servers in some form. (See below, CONTACT US)
LINKS TO THIRD-PARTY WEBSITES
We do not review or control third-party websites that link to or from this site, we are not responsible for their content, and we do not represent that their content is accurate or appropriate. Your use of any third-party site is on your own initiative and at your own risk, and may be subject to the other websites’ terms of use and privacy policy.
CONTACT US
If you would like to exercise any individual rights, please contact us at 610-507-5723. We will respond to your request consistent with applicable law.
If you have any questions or concerns regarding this Privacy Policy, please contact us.
Attn: Compliance Officer
En Masse LLC
2329 HIGH St.
Reading, PA 19605
Email: _____
Phone: 610-507-5723
