Privacy policy

Last updated: July 17th, 2023

Statement

DMS CD (Netherlands) B.V. d/b/a CDG, the company registered at 1 Locatellikade, 1076AZ Amsterdam, Netherlands, company number 865068495 (hereinafter referred to as “Company”, “us”, “we” or “our”), operated this website (hereinafter referred to as “Website”) respects your privacy herein. The following describes the overall Сompany privacy policy in relation to use and disclosure of information you share via this Website (hereinafter referred to as “Privacy Policy”). The Privacy Policy was created to inform you what information we collect when you visit our Website and your choices about use and disclosure of your information. If you do not agree with this Privacy Policy, please discontinue your use of the Website immediately. We encourage you to read this Privacy Policy carefully when using our Website or services or transacting business with us. By using our Website, you are accepting this Privacy Policy. If you have any questions about this Privacy Policy, please refer to the end of this Privacy Policy for information on how to contact us.

Personal information

Personal Information means any information about an identified or identifiable individual and any device information that may be linked with an identifiable individual.

When visiting our Website or when registering for participation in one of our promotional campaigns or a newsletter or if you are already a participant of us, we register your personal details only after you have given a specific and informed consent thereto by means of a clear affirmative opt-in.

Personal Information is information the Company may ask you to provide and you can provide it solely by your own discretion. It may include your name, email address, street address, zip code/postal code, telephone number. When you provide PRI through our Website, the information may be sent to servers located in the United States and other countries.

To be particular, information we process are:

Information you provide: We may collect and store any personal information you enter on our Website. It is at your discretion and determination whether to provide personal information to us. When you join CDG you are opting in to receive emails from us or about CDG, other brands, one of our affiliates, or one of our 3rd party marketing partners. Your telephone number can be used to initiate and offer you certain services and to conclude and execute agreements. If you have indicated that you are interested, we, one of our affiliates, or one of our 3rd party marketing partners can also use your mobile phone number to communicate with you and keep you informed about offers. You can opt-out of notifications by replying to emails you have received, using the unsubscribe link in the email, or contacting us via email at: contracts@customerdirectgroup.com. Note: you cannot opt out of receiving certain administrative or legal notices from us.

Information from other sources: We may also obtain both personal and non-personal information about you from business partners, contractors and other third parties, such as updated delivery and address information, purchase history, and demographic information.

Cookies and Web Beacons. The Company uses Cookies and Web Beacons to associate certain Internet-related information about you with information about you in our database. A cookie is a small amount of data stored on the hard drive of your computer that allows us to identify you with your corresponding data that resides in our database. A web beacon is a programming code that can be used to display an image on a web page, but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. Thus, we use various technologies to collect information from your computer and about your activities on our site. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, and the referring Website address. We may allow third-parties, including our authorized service providers, advertising companies, and ad networks to display advertisements on our site. These companies may use cookies to collect information about users who view or interact with their advertisements. Our Website does not provide any personal information to these third parties.

Log Information. When you log-in to access your account, our servers may automatically record and archive certain information that web-browsers send whenever visiting the Website. These server logs may include information vital to validating your authorization to access the account. Information, such as a web request, Internet Protocol (the "IP") address, browser type, browser language, referring pages, exit pages and visited URLs, platform type, click counts, pages viewed and in what order, time spent, the date and time of the request, and other important data is necessary to validate and authorize your entry and activity on the Website

BY PROVIDING PERSONAL INFORMATION TO US VIA WEBSITE, YOU VOLUNTARILY CONSENT TO THE COLLECTION, USE, TRASFER AND DISCLOSURE OF SUCH PERSONAL INFORMATION AS SPECIFIED IN THIS PRIVACY POLICY.

Collection and Use of Information

We collect from you only limited amount of information necessary to use the Website and provide related services to you. The Company does not seek any personal information by illegal means. We will only use your personal information if we have a lawful basis to do so in accordance with the rules or principles of the applicable Information privacy laws such as:

when it’s our legal duty,
if we have your consent,
when it’s necessary to perform our contractual obligation and/or otherwise within our legitimate right to do so, including business or commercial purpose (Relevant Purpose). The Company`s Relevant Purposes are: including: enhancing the Company's products and services; fraud prevention; analytics; advertising enhancement; any other purpose not prohibited by applicable laws or privacy regulations, including the GDPR, CCPA and other data protection laws.

Use of Information

The Company will only use information provided by you for the reason that you have provided this information for.

Your Personal Information will be used to establish your account, to communicate with you and for ongoing record keeping, required by the Company.

Your other Information including cookies, web beacons, etc, will be used only for system administration and for improvement of our services

Your log information is necessary to validate and authorize your entry and activity on the Website.

Other reasons to use your information are:

Provide products and services that you have requested;
Manage your account and provide you with customer support;
Perform research and analysis about your use of, or interest in, our products, services, or content;
Communicate with you by email, postal mail, telephone and/or mobile devices or send newsletters, promotional offers, customer feedback surveys, and other relevant legal notifications about products or services that may be of interest to you either from us, our affiliates, our partners or third parties;
Communicate with you via phone or email with regard to partially completed service requests;
Develop and display content and advertising tailored to your interests on our site and other sites;
Perform background screening, which may include the use of third parties or service professionals;
Enforce our terms and conditions as stated in our Terms of Use;
Enforce our terms and conditions as stated in our Terms of Use;
Manage our business;
Perform functions as otherwise described to you at the time of collection.

Aggregated and Non-Personal Information

We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with third parties and affiliated companies to develop and deliver targeted advertising on our Websites and on Websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors.

Sharing personal information

Information we collect may be shared with a variety of parties depending upon the purpose for and context in which that information was provided. In all cases where we share Personal Information with third parties, we will use a minimum necessary standard to disclose only that information required for satisfying the purpose of or performing the service for which the information is disclosed. We may share your Personal Information with other parties including direct mail partners. From time to time, we may share our postal mailing list with selected providers of goods and services that may be of interest to you. We may share your Personal Information with third parties for marketing or adverting purposes, as permitted by law.

In order to streamline certain business operations, develop products and services that better meet the interests and needs of you, we may share your personal information with any of our current or future affiliates, affiliated entities, subsidiaries and parent companies. You hereby agree to our sharing some or all of your information with Company’s affiliates.

We will share your Personal Information in accordance with your consent for us to do so.

Please note, in limited circumstances, we may without notice to you or your consent, access and disclose your Personal Information any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person.

Transfer

Our Website may be accessed from anywhere, and users from aby country may submit their Personal Information to us via forms, comment fields, or other input mechanisms as explained above. If you are accessing the Website or submitting your Personal Information to us you understand that your Personal Information may be transferred to, stored, or processed in the different country of your jurisdiction and maintained on computers or servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective those in your jurisdiction. By accessing our Website, you understand and consent to the transfer of your information.

Your Choices About Collection and Use of Your Information

(Opt-Out/Unsubscribe/ Sign Out)

At any time, you can choose to no longer receive commercial marketing or promotional emails or newsletters from us by accessing your user account and opting out. You also will be given the opportunity, in any marketing email that we send to you, to opt out of receiving such messages in the future, or by replying to any of these emails. Be sure you include your name and email address. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. If you prefer not to have us share your email address & other information with selected providers of goods and services that may be of interest to you, you can notify us at any time by emailing us at contracts@customerdirectgroup.com.

How You Can Access Your Information

If you have an online consumer account with us, you can access and review your personal information by logging into your account. You can also review and update your personal information by contacting us. You can also choose to have your account disabled by contacting email contracts@customerdirectgroup.com. After you deactivate your account, you will not be able to sign in to our Website or access any of your personal information. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Website or our users, or take other actions otherwise permitted by law.

Security

Security of your information (Personal Information and other Information) is our utmost priority. We take many strict measures in order to protect our data from unauthorized access, unauthorized disclosure or destruction of data. Our data is only stored in centers that provide the highest quality security for your information. We want you to feel confident using our Website to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Thus, any transmission of data at or through the Website, or otherwise via the Internet or wireless networks, is done at your own risk. Please refer to the Federal Trade Commission’s website at https://www.consumer.ftc.gov for information about how to protect yourself against identity theft.

Children’s privacy

We are sensitive to the issue of children’s privacy. We understand the importance of protecting the privacy of children, especially in an online environment. Therefore, Website is neither developed for, nor directed at children. In particular, our Website is a general audience site, and we do not knowingly collect personal information from children under the age of 13. If you become aware that a child has provided us with personal information without parental consent, please contact us at contracts@customerdirectgroup.com and we will take steps to remove such information and terminate the children’s account. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Third-party sites

Our Website may contain links to third parties’ websites. Such third parties have their own policies that govern their collection, use, and disclosure of information. We suggest that you read their privacy policies to learn about their practices. Thus, we are not responsible for the privacy practices or the content of such websites and we have no responsibility or liability relating to them.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Website.

Retention

We retain personal information only as long as required to fulfill the purposes described above, or as required by law as necessary to comply with our legal obligations or to resolve disputes. We may store any information about your activity on our Website or any information created, posted or shared by you on our Websites for as long as we deem it necessary or until you provide specific instructions to delete it.

Transferring of Assets and Rights

We may also share your information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending an email to the email address you most recently provided us in your account, profile or registration (unless we do not have such an email address), or by prominently posting notice of the changes on our Website. We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Contact

If you have any questions about this Privacy Policy or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, or if you would like to fill a complain about this Privacy Policy please contact us by email or postal mail as follows: Privacy Policy Inquiry, DMS CD (Netherlands) B.V. d/b/a CDG, the company registered at 1 Locatellikade, 1076AZ Amsterdam, Netherlands, company number 865068495;

or email us at contracts@customerdirectgroup.com

Additional Notice for European Economic Area (EEA) Residents

Among other rights in your Personal Information, you have the following data protection rights:

The right to access, correct, update or request deletion of your personal information.

The right to object to processing of your personal information; ask us to restrict processing of your personal information or request portability of your personal information.

The right to opt-out of marketing communications we send you at any time.

The right to withdraw your consent at any time if we have collected and processed your personal information with your consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

You may also request additional information about: the purpose of the processing; the categories of personal data concerned; who else outside us might have received the data from us; what the source of the information was; and how long it will be stored.

If you wish to exercise any of these rights, please contact us here contracts@customerdirectgroup.com. We may ask you to verify your identity, or ask for more information about your request.

We will process your requests as soon as possible but not later than within 45 days from the day of the receipt. If necessary, we will also notify you and a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

Legal basis for processing Personal Information

If you reside in the EEA, we will normally collect personal information from you (1) where we need the personal information to enter into or perform a contract with you, (2) where we have your consent to do so, (3) where the personal information is needed to comply with a legal obligation or requirement, or (4) where the processing is in our Relevant Purposes or the legitimate interests of others (as described herein), and not overridden by your rights.

This Privacy Policy applies to personal data which is collected and/or used by us in its capacity as a data controller as that term is defined in the GDPR and similar privacy laws.

Transfer

For transfers of personal information to countries outside EU, we rely on the European Commission’s adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en and their Standard Contractual Clauses, available here https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en

Additional Notice for California, Colorado, Nevada, Virginia residents

For California residents:

We collect a variety of Personal Information from you. “Personal Information” under CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include deidentified or aggregated consumer information. We comply with the CCPA in its capacity as a “business”.

We collect Personal Information for business and commercial purposes outlined herein and any other purpose not prohibited by applicable laws or privacy regulations, including the CCPA.

CDG has collected the following categories of Personal Information from users within the last twelve (12) months:

A. Identifiers. A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. YES

C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO

E. Biometric information. Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO

F. Internet or other similar network activity. Browsing history and search history within our Website; information on a consumer's interaction with a Website and advertisement. NO

G. Geolocation data. Physical location or movements. NO

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO

K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

L. Sensitive personal information. Race or ethnic origin, religion, political affiliations, sexual orientation, criminal history. NO

IN THE PRECEDING TWELVE (12) MONTHS THE COMPANY HAS DISCLOSED AND SOLD OBTAINED PERSONAL INFORMATION TO THIRD PARTIES, CONTAINED IN THE LIST IN THE END OF THE PRIVACY POLICY, FOR BUSINESS AND COMMERCIAL PURPOSES.

Rights in Personal Information:

You may ask us to disclose what Personal Information we have about you and what we do with that information, to delete it and not to sell it. Thus, you may request us stop selling your personal information (please use “opt-out” or contact us).

You may also request us disclose to you what Personal Information We have collected, used, shared, or sold about you, and why they collected, used, shared, or sold that information. Specifically, you may request that we disclose:

The categories of Personal Information collected
Specific pieces of Personal Information collected
The categories of sources from which collected Personal Information
The purposes for which used the Personal Information
The categories of third parties with whom we share the Personal Information
The categories of information that we sell or discloses to third parties

You may request that we delete personal information we collected from you (within exceptions mentioned herein).

Please note, you can opt-out at any time by emailing us: “Do Not Sell or Share My Personal Information.”

If you wish to exercise any of these rights, please contact us here contracts@customerdirectgroup.com. We may ask you to verify your identity, or ask for more information about your request.

We will process your requests as soon as possible but not later than within 45 days from the day of the receipt.

Additional Notice for Mainland China, Hong Kong and Macau residents

You have the right to access your Personal Information by yourself, unless otherwise stipulated by laws and regulations. You can also exercise this right by contacting us.

You are entitled to request us to make corrections if you find any of your Personal Information processed by us is wrong. You can log in to your account and correct your Personal Information.

You can request us to delete Personal Information

You can log in to your account and obtain a copy of your Personal Information. You can also exercise this right by contacting us.

You entitled to receive a response to your above requests.

If you wish to exercise any of these rights, please contact us here contracts@customerdirectgroup.com. We may ask you to verify your identity, or ask for more information about your request.

We will process your requests as soon as possible but not later than within 45 days from the day of the receipt.

Do Not Call Policy

The Company takes its responsibilities about customer information and customer service very seriously. In support of this commitment, CDG has adopted the following Do Not Call Policy.

No employee or agent of the Company shall engage in telemarketing practices that violate the terms of the Telephone Consumer Protection Act of 1991, the FTC Telephone Sales Rule, or state law or regulation.

The Company maintains a record of the name and telephone number for consumers who do not wish to be called. If you don’t want to receive sales calls from CDG, just ask us to place your name on our Do Not Call List. We will note your request immediately, and will remove your information from active lists within 30 days.

You can make your request in writing by mailing us at DMS CD (Netherlands) B.V. d/b/a CDG, the company registered at 1 Locatellikade, 1076AZ Amsterdam, Netherlands. When you make a request, you must include your name, address and telephone number(s) you want to be included on our list. If your information changes, please notify us of the new name, address, and telephone number(s) in order to remain on our Do Not Call List. If you would like us to remove you from our Do Not Call List in order to receive our telephone solicitations, notify us by contacting us at the above address or telephone number.

All Company’s personnel involved with telemarketing and/or telephone solicitation for CDG are trained, informed, and directed to comply with the Company Do Not Call Policy.