Privacy Policy

d1g1t collects your Personal Information to provide you with the Activities and other relevant information, and/or for the other specific purposes communicated to you at the time of the Personal Information collection.

We may also collect Personal Information to allow us to manage and develop our business and operations, including:

• informing you of, and providing you with information you specifically requested;
• enabling us to comply with applicable law or legislation; and
• any other reasonable purpose to which you consent.

The Personal Information that we collect in the course of our Activities may include, but is not limited to, your name, telephone number, and e-mail address.

We may also automatically collect general anonymous information through “cookies” related to your use of our Website, such as the date and time you visit the Website, and the pages you visited.

We may use third-party web masters to help us gather and analyze information about the areas you visit on our Website in order to enhance your user experience and to help us analyze the use of our Website. These third parties use “cookies” to collect and generate information about your visits to our Website (including your IP address) that is transmitted to their servers in an anonymous form for processing. We study patterns of website activity so we can improve our users’ experience on our Website. The use of these tools does not allow us or our analytics service providers to identify individuals.

“Cookies”

Cookies are tiny pieces of data that can be sent to your browser to be stored on your hard drive so that you are recognized the next time you visit our Website. We use two types of cookies:

‍Strictly necessary cookies (always active): They are necessary for the operation of the Site and cannot be deactivated. They are generally set in response to actions you perform, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block or inform you of the existence of these cookies, but some parts of the Website may be affected. These cookies do not store any personal information.

‍Performance cookies: They are important because they allow us to monitor the performance of the Website and content to provide you with a quality experience. The statistical information helps us to understand how our Website is used (e.g., identifying which pages or sections are most popular and the peak activity times), which assists us in planning for future improvements to the Website to better meet our user’s needs. We recommend that you activate these cookies, but if you don’t, your browsing experience will not be affected.

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We do not share or sell your Personal Information without your consent.

Access to your Personal Information is limited to our employees who have the necessary access authorizations or on a need-to-know basis to conduct our Activities. The processing of your Personal Information is done solely for the purposes described in this Policy.

The processing of your Personal Information may be done by using third-party service providers, which are essential to our Activities. Our service providers are required to protect your Personal Information from unauthorized access, collection, use, or disclosure and are bound by the same level of privacy protection as we are. Our service providers agree to maintain the confidentiality of the information and not to use it for any purpose other than to provide their services to us and not to disclose your Personal Information to any further third party.

We may have to disclose your Personal Information to third parties in the following cases:

• if expressly authorized, requested, or required to do so by law;
• if we are compelled to do so by a competent authority, regulation, subpoena, or court order;
• if it is necessary to protect our rights and property;
• if any emergencies occur or when the use is necessary to protect the safety of a person or group of persons;
• if the information is public personal information;
• if it is required by employees, contractors and consultants who require the information to assist us in establishing, maintaining and managing our relationship with you, including, for example, third parties that provide analytics or cloud hosting services to us or on our behalf or third parties that collaborate with us in the provision of services to you;
• If we have obtained your consent.

We may disclose Personal Information in connection with legal proceedings to protect our rights or those of our Users.

We work with external service providers specialized in security safeguards to ensure that we maintain best practices in cybersecurity, encryption and data governance which can include encryption protocols, access control, security data transfer mechanisms, network security limiting the access of information to authorized personnel only on a “need to know” basis based on their role and the principle of least privilege and policies. We work with a cloud infrastructure provider protected with firewalls, intrusion detection systems, and regular vulnerability assessments to defend against cyber threats.

Multiple safeguards and security measures have been put in place in respect of our Activities to protect the loss, misuse, and alteration of information under our control, including your Personal Information. Please note, however, that no data security measure can be guaranteed to be totally effective. Consequently, we cannot certify or guarantee the security of your Personal Information or other data held by us. You transmit Personal Information and other data to us at your own risk. In accordance with applicable laws, we have set up a confidentiality incident register.

We retain your Personal Information until our Activities no longer require us to hold it, or as required to comply with our legal and regulatory obligations. By agreeing to this Policy, you consent to our retention of your Personal Information. We will ensure that we store your Personal Information in accordance with applicable law and legislation.

Your Personal Information is stored on electronic media and servers operated by our service providers, who are bound by the same level of privacy protection as we are, and who undertake to use comparable security measures to preserve the integrity and confidentiality of the Personal Information.

In addition, according to agreements between us and our external service providers, your Personal Information may also be hosted and/or disclosed to and stored on external servers located outside of your jurisdiction as part of the services provided or Activities. By participating in our Activities, you consent to such disclosure, hosting, and storage of your Personal Information outside of your jurisdiction. In the event that we disclose your Personal Information outside of your jurisdiction to our service providers to use their services, we will comply with the requirements of any applicable law and legislation, such as conducting a privacy impact assessment.

Accessing and rectifying your data

As applicable in your jurisdiction, you may have the right to:

• ask us whether we hold any Personal Information about you, and to obtain a copy thereof if we do; and
• rectify any inaccurate, incomplete or equivocal Personal Information, or if its collection, communication or retention is not in compliance with or authorized by applicable law or legislation, demand that it be rectified.

If you wish to have access to your Personal Information, or if you want us to rectify certain Personal Information we hold about you that is inaccurate, incomplete or equivocal, you may send us a written request to the address of the Privacy Officer indicated at the end of this Policy.

We will respond to your request promptly (within a maximum of 30 days of receipt).

Right to withdraw consent

As applicable in your jurisdiction, if you wish to withdraw your consent to the processing and disclosure of your Personal Information, please notify us in writing at the Privacy Officer’s address listed at the end of this Policy.

Upon receipt of notice of revocation of your consent, we will stop using and/or disclosing your Personal Information promptly, which delay may vary depending on the Personal Information we have collected and the purpose for which we have collected it.

Please note that if you continue to use the Website or participate in our Activities, it will not be possible to prevent the collection, use, processing and/or disclosure of your Personal Information. The only way to stop such collection, use, processing and/or disclosure of your Personal Information is to stop visiting the Website and participating in our Activities.

Right to be forgotten suppression

As applicable in your jurisdiction, in some circumstances, you may request the suppression of the Personal Information we hold about you. To make such request, please notify us in writing at the Privacy Officer’s address listed at the end of this Policy.

We will comply with your request promptly (but not later than 30 days after receipt thereof) and destroy your Personal Information in accordance with any applicable law and legislation.

Please note that, in some circumstances, we may refuse a request to delete your Personal Information, for example when the Personal Information is required to comply with the law, with a contractual agreement between the parties or in connection with a claim.

If you continue to visit the Website, we will collect certain Personal Information about you.

Right to portability

As applicable in your jurisdiction, upon your written request, we shall give you, in a structured and commonly used technological format, any computerized Personal Information that we have collected from you. This communication may also, at your request, be made to a person or organization authorized to collect your Personal Information.

Verification

We reserve the right to verify the identity of individuals who request access to their Personal Information

If you have any questions or concerns about this Policy, the processing of your Personal Information, or if you wish to exercise your rights or file a complaint, please contact our Director, Information Security and Risk who has been appointed as Privacy Officer, directly by e-mail at privacy@d1g1t.com 

Our Privacy Officer is also responsible for, among other things, approving the privacy governance policies and practices we are required to establish and implement, and participating in the conduct of Privacy Impact Assessments (“PIAs”) when required by law.

Please note that we are committed to responding to your questions, concerns, or complaints as quickly as possible.

If we discover that our security measures have been breached and that there is a real risk of harm to you, we will contact you, unless prohibited by law.

Changes to the Policy

We may amend this Policy from time to time to reflect changes in our Personal Information management practices and to comply with applicable law and legislation. Any changes will be reflected in the updated Policy available on our Website. We will notify Users who have provided us with their Personal Information by e-mail of any material changes to this Policy.