1. Information We Collect. Our primary goals in collecting information are to provide and improve our Service, to administer your orders, to communicate with you, and to enable users of the Site to enjoy and easily navigate the Site. When you wish to contact us, create an account on the Site, edit account details, purchase products or services via the Site, use some of our Services, or when you join our mailing lists, we will ask you for certain Personal Information. When we refer to your “Personal Information” in this Privacy Policy, we mean information that identifies, describes, relates to, references or is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. We may also collect other information generated when you use our Site or Services that is not linked or otherwise associated with you, and such information is not subject to the terms of this Privacy Policy. Depending on how you use our Site and/or our Services, we may directly collect the following types of Personal Information from you:

• your name;
• e-mail address;
• shipping address;
• billing address;
• credit card account number;
• IP address;
• telephone number; and
• online identifiers you use, such as your username, social media handles, and other similar  types of identifiers.

2. Information from Social Networking Sites. Our Service may include interfaces that allow you to connect with social networking sites. If you connect to them through the Site, you authorize us to access, use and store the information that you agreed that could be provided to us based on your settings. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable tools.

3. Information Automatically Collected. When you visit our Site, some information is automatically collected. For example, when you visit our Site your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the Site you visited before our Site are logged automatically (“Usage Information”). We also collect information about your usage and activity on our Site.

4. Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to better assist SSI in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for SSI’s use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. 

5. Information Collected from Other Third Parties. We may receive your Personal Information from third party business partners, such as social media sites, ad networks and analytics providers. We may also receive your Personal Information from others that refer you to our Sites and/or Services.

6. Use of Information. We use your Personal Information collected for the purposes described in this Policy. Specifically, we may use your Personal Information to:

• operate and improve our Site and Services;
• understand you and your preferences to enhance your experience;
• track, collate, and analyze your use of our Site and Services;
• process and deliver contest entries and rewards;
• respond to your comments and questions and provide customer service;
• provide and deliver products and Services you request;
• to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• facilitate your participation in participate in surveys, promotional offers, contests or sweepstakes;
• communicate with you about new contests, promotions, rewards, upcoming events, and other news about products and Services offered by us and our selected partners; and
• link or combine it with other Personal Information we get from third parties, to help understand your needs and provide you with better service.

7. Sharing of Information. We do not share your Personal Information with third parties except in the following circumstances:

• Affiliates and Subsidiaries. We may share your Personal Information with our affiliates and subsidiaries with the understanding that they will treat such information consistent with this Privacy Policy.
• Third Party Service Providers. We may share your Personal Information with our third party vendors, consultants and other service providers who work for us and need access to your information provide you with products, services, or information that you request. For example, we use Mailchimp (https://mailchimp.com/legal/privacy/) to facilitate our email communications, ZenDesk (https://www.zendesk.com/company/customers-partners/privacy-policy/) to provide customer support, and Zoom Video Communications, Inc. (https://zoom.us/privacy) to conduct online classes.
• Other Third Parties. We may share your Personal Information with appropriate third parties if we believe it is necessary, in our reasonable discretion, to (i) comply with laws or to respond to lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (ii) protect the rights and property of us, our agents, customers, members, and others including to enforce our agreements, policies and terms of use; or (iii) in an emergency to protect the personal safety of SSI, its customers, or any person.
• Corporate Restructuring. We may share your Personal Information in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another entity.
• With Your Consent. We may share your Personal Information with third parties where you have provided consent to such sharing.

We may also share aggregated anonymous or de-identified information. When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the Personal Information we receive about you and other individuals whose Personal Information we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

7. Payment Card Information. We do not collect, store, or process any payment card information. Instead, we rely on Stripe to facilitate any payment card transactions. For more information about Stripe’s privacy practices, please see: https://stripe.com/us/privacy.

8. Email Opt-Out and Disabling Cookies.

A. Email Opt-Out. You may opt out of receiving promotional emails from us by following the instructions in those emails or sending a message with your request and the subject line “EMAIL OPT OUT REQUEST” to info@dhafr.com. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

9. Third Party Sites and Links. Our Site and Services may contain links to third party sites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them.

10. Children’s Information. Our Site and Services are not directed children under the age of 16. If you are under 16, you may not access, attempt to access, or use our Site or Services. We do not knowingly collect or allow the collection of Personal Information via the Site or Services from persons under the age of 16, pursuant to applicable law and regulations. If we learn that we have collected the Personal Information of someone under the age of 16, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 16 and discover that your child has submitted Personal Information to us, you may contact us at info@dhafr.com and ask us to remove your child’s Personal Information from our systems.

11. Information Security. We take reasonable organizational, technical and administrative steps to help protect Personal Information against loss, misuse, unauthorized access or disclosure. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure.

12. Your California Privacy Rights. If you are a California resident, you have the right to request information from us regarding the manner in which SSI shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you.  The designated email address for these requests can be found at:  info@dhafr.com

Additionally, if you are a California resident and are under the age of 18 and you have posted content or information to our Site or Services, you can request that we remove content or information that you have posted to our Site or Services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by other individual).

Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

13. European Users’ Rights. If you are located in the EU or Switzerland, you have certain rights with respect to your Personal Information. Following is a summary of those rights and additional information applicable to our collection and use of your Personal Information.

A. Data Controller. When you provide us with your Personal Information through the Site and/or our Services, we serve as a data controller. When we act as a data controller we determine how your Personal Information will be utilized, in accordance with this Privacy Policy.

B. Legal Basis for Processing Information

• If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:
• The processing is necessary to perform our contractual obligations, such as to provide you with our Services;
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims; and
• The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our Site and Services, marketing new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about or would like further information concerning the legal bases on which we collect and use your Personal Information, please contact us by emailing  info@dhafr.com

C. Rights Under the General Data Protection Regulation

If you are located in the EU or Switzerland, you have the following rights in respect of your Personal Information that we hold:

• Right of access. The right to obtain access to your Personal Information.
• Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information 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 Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• Right to portability. The right to portability allows you to move, copy or transfer Personal Information easily from one organization to another.
• Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please email us at  info@dhafr.com You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

D. Retention of Personal Information. When reserve the right to retain any Personal Information as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Information; and (2) comply with applicable law.

E. Obligations to Data Protection Authorities (DPAs)

We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Information, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

F. Contacting Our Data Protection Officer

To contact our designated Data Protection Officer, please send an email to:  info@dhafr.com

15. Changes to This Policy. We may change this Policy from time to time. If we make any changes to this Policy, we will change the “Effective Date” date above. If we make any material change(s) to the Policy, we will post a notice on our Site prior to such changes(s) taking effect. Your continued use of the Site and/or any of our Services after the changes have been made will constitute your acceptance of the changes. Therefore, please read any such notice carefully. If you do not wish to continue using the Site or our Services under the new version of this Privacy Policy, please stop using the Site and our Services.

16. Contacting Us. If you have any questions about this Privacy Policy, please contact us at  info@dhafr.com