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Privacy Statement

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by Direct Care.

Contacting Us

If you have general questions about your account or how to contact customer service for assistance, please visit our online help center at https://help.Direct Care.com. For questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at [email protected].

The data controller of your personal information is Direct Care. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Collection of Information

We receive and store information about you such as:

Information you provide to us: We collect information you provide to us which includes:

  • your name, email address, address or postal code, payment method(s), and telephone number. In certain countries, we collect a government identification number for purposes such as billing and tax compliance. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions;
  • information such as your account settings (including preferences set in the "Account" section of our website), or otherwise provide information to us through our service or elsewhere.

Information we collect automatically: We collect information about you and your use of our service, your interactions with us as well as information regarding your computer or other device used to access our service (such as gaming systems, smart TVs, mobile devices, set top boxes, and other streaming media devices). This information includes:

  • your activity on the Direct Care;
  • your interactions with our emails and texts, and with our messages through push and online messaging channels;
  • details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
  • device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information;
  • service activation information such as your email address or other contact information;
  • service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Statement;
  • payment service providers who provide us with payment information, or updates to that information, based on their relationship with you;
  • online and offline data providers, from which we obtain demographic, interest based and online advertising related data;

Use of Information

We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to:

  • prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining free trial eligibility);
  • analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;
  • communicate with you concerning our service so that we can send you news about Direct Care, details about new features and content available on Direct Care, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, and text messages.

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services.

Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing the Direct Care service to members and providing information about the availability of the Direct Care service. For example, depending on what Partner services you use, we may share information in order to facilitate:

  • Partner collection of payment for the Direct Care service for distribution to us;
  • Promotional offers: We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
  • Protection of Direct Care and others: Direct Care and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Direct Care, its users or the public, as required or permitted by law.
  • Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection.
You may also choose to disclose your information in the following ways:

  • certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device;
  • social plugins and similar technologies allow you to share information.

Social plugins and social applications are operated by the social networks themselves and are subject to their terms of use and privacy policies.

Access to Account and Profiles

For ease of access to your account, you can use the "Remember me on this device" function when you log in to the website. This function uses technology that enables us to provide direct account access and to help administer the Direct Care service without requiring reentry of any password or other user identification when your browser revisits the service.

To remove access to your Direct Care account from your devices: (a) visit the "Account" section of our website, choose "Sign out of all devices," and follow the instructions to deactivate your devices (note, deactivation may not occur immediately) or (b) delete your Direct Care settings from your device (steps vary by device and the option is not available on all devices). Where possible, users of public or shared devices should log out at the completion of each visit. If you sell or return a computer or Direct Care ready device, you should log out and deactivate the device before doing so. If you do not maintain the security of your password or device, or fail to log out or deactivate your device, subsequent users may be able to access your account, including your personal information.

If you share or otherwise allow others to have access to your account, they will be able to see your information (including in some cases personal information) such as your watch history, ratings, and account information (including your email address or other information in the "Account" area of our website). This remains true even if you use our profiles feature.

Profiles allow users to have a distinct, personalized Direct Care experience, built around the cyber security risk profile of the user. Please note that profiles are available to everyone who uses your Direct Care account, so that anyone with access to your Direct Care account can navigate to and use, edit or delete profiles. You should explain this to others with access to your account, and if you do not wish them to use or change your profile, be sure to let them know. Profile users may be offered the opportunity to add an email address, phone number or other information to the profile and will be provided with notice of collection and use at the time such information is requested.

Your Choices

Email and Text Messages.
 If you no longer want to receive certain communications from us via email or text message, simply access the "Communications Settings" option in the "Account" section of our website and uncheck those items to unsubscribe. Alternatively, click the "unsubscribe" link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your account transactions.

Push Notifications.
 You can choose to receive mobile push notifications from Direct Care. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off.

Your Information and Rights

You can request access to your personal information or correct or update out-of-date or inaccurate personal information we hold about you.

You can most easily do this by visiting the "Account" portion of our website, where you have the ability to access and update the information about your account, including your contact information, your Direct Care payment information, and various related information about your account. You must be signed in to access the "Account" section. You may also request that we delete personal information that we hold about you.

To make requests, or if you have any other question regarding our privacy practices, please contact our Data Protection Officer/Privacy Office at [email protected] We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the "Your Choices" section of this Privacy Statement for additional choices regarding your information.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your personal information.

Children

You must be 18 years of age or older to subscribe to the Direct Care service. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age in order to become a member. While individuals under the age of 18 may utilize the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Direct Care service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the Direct Care service. To see when this Privacy Statement was last updated, please see the "Last Updated" section below.

Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons), as well as resettable device identifiers, for various reasons. For example, we use these technologies to make it easy to access our services by remembering you when you return, and to provide and analyze our services. We also use cookies, as well as resettable device identifiers, to learn more about our users and their likely interests, and to deliver and tailor marketing or advertising. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do and your choices regarding their use.

What are cookies?
Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service personalization. 


Why does Direct Care use cookies?

  • Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we and our Service Providers may use these cookies to authenticate and identify our members when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service.
  • Performance and functionality cookies: These cookies are not essential but help us to personalize and enhance your online experience with Direct Care. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors' use of the Direct Care service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.
  • Advertising cookies and resettable device identifiers: Direct Care does not use advertising cookies and resettable device identifiers.

  • How can I exercise choice regarding cookies and resettable device identifiers? 

Since the only use we make of cookies is for the functioning of Direct Care services, you cannot opt out of this cookie use. The only remedy offered is to not use the Direct Care service. 

Since we do not track or store tracking information, we do not respond to Web browser "do not track" signals.

  • How Does Direct Care use Web Beacons and other Technologies? 

Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. We and our Service Providers may use them for similar purposes as cookies, such as to understand and enhance the use of our service and improve site performance. Because these technologies often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness associated with those cookies. 

We may use other technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, some of these technologies may store small amounts of data on your device. We may use these and various other technologies for similar purposes as cookies, such as to enforce our terms, prevent fraud, and analyze the use of our service. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser's help function or support area to learn more. Other technologies, such as Silverlight storage, may be cleared from within the application.

To see the prior version of this document, please go to dpcindividuaal.com/privacyupdates.

Last Updated: January 1, 2020