Privacy Policy

Dotcom Distribution Privacy Shield Policy

Notice

.com Distribution Corp., DBA Dotcom Distribution, a Delaware corporation complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States pursuant to Privacy Shield.  DotCom Distribution has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Information Collection, Use, and Sharing

3^rd Party Fulfillment Services

Dotcom Distribution is a provider of 3^rd party fulfillment services. Data is collected, as part of our fulfillment services, solely for the purpose of fulfilling orders on behalf of our clients and maintaining contact information for potential clients. The types of personal data we collect for fulfillment services include: first name, last name, shipping address, telephone number, email address, and country. We are provided sufficient data by our clients about their customers to ship consumer orders via common carriers (UPS, FedEx, DHL, and USPS) and to third-party perform parcel audits across parcel carriers. Data obtained through fulfillment operations is not sold or marketed by Dotcom Distribution in any way.

Sales and Marketing

Dotcom Distribution processes or utilizes third-party organizations to processes personal information related to its sales and marketing efforts. Sales and Marketing data obtained by Dotcom is stored separately from that of fulfillment services and fulfillment information will never be used by sales and marketing during client engagement or sales prospection.

Personal information that we’ll process in connection with all of our products and services, if relevant, includes:

• Personal and contact details, such as title, full name, contact details and contact details history
• Your location, if needed for compliance or segmentation of data for compliance purposes
• Records of your contact with us such as via the phone number of our sales and marketing employees, contact forms that you have filled out on our website, registrations on any of our web apps, IP address and MAC address, and cookie data
• Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
• The usage of our products and services, any callouts and claims and whether those claims were paid out or not (and details related to this)
• Marketing to you and analyzing data, including the history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analyzing data to help target offers to you that we think are of interest or relevance to you. Offers may include content downloads, invitations to read more content on our website, or invitations to speak with us or tour our facility
• Information about your use of products or services held with our business partners, such as insurance policies, mortgage, savings or financial services and products
• Information we obtained from third parties, including information about your title, company, and your contact details
• Information about your employment status, if relevant
• Information we buy or rent from third parties, including information about your title, company, and your contact details, marketing lists, publicly available information, and information to help improve the relevance of our products and services
• Insights about you and our customers gained from analysis or profiling of customers

We use your personal data, including any of the personal data listed above, for the following purposes:

• Assessing an application for a product or service, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms
• Managing the product or service you have with us
• Updating your records
• Managing any aspect of the product or service
• To make automated decisions on whether to offer you a product or service
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business and that of our business partners
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To monitor and to keep records of our communications with you and our staff (see below)
• For market research and analysis and developing statistics
• Assessing and profiling aspects of your business
• For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our products and services, as well as to any other offers and advice we think may be of interest
• To provide personalized content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
• To develop new products and services and to review and improve current products and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
• To facilitate the sale of one or more parts of our business

We may share information with the following third parties for the purposes listed above:

• Business partners who are a part of providing your products and services or operating our business
• Organizations and businesses who provide services to us such as backup and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back-office functions
• Market research organizations who help us to develop and improve our products and services

In certain situations, DotCom Distribution may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

DotCom Distribution’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, DotCom Distribution remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless DotCom Distribution proves that it is not responsible for the event giving rise to the damage.

Security

Dotcom Distribution employs precautions to protect data from breach or uses other than those intended for providing our fulfillment services.

Access & Choice

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@dotcomdistribution.com. If requested to remove data, we will respond within a reasonable timeframe.

Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@dotcomdistribution.com.

Enforcement

Dotcom Distribution utilizes a periodic self-assessment approach to verify compliance with the Privacy Shield principles and reviews this privacy policy to ensure that it is accurate and complete.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, DotCom Distribution is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Recourse

In compliance with the Privacy Shield Principles, Dotcom commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact Dotcom Distribution at:

Email: privacy@dotcomdistribution.com

Or Write to:
Attn: MIS
300 Nixon Lane
Edison, NJ 08837

Dotcom Distribution has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

California Residents

In compliance with the California Consumer Privacy Act, Dotcom commits to respond to inquiries and resolve complaints about your privacy and our collection or use of your personal information within 45 days from the time an inquiry is submitted. California residents with inquiries or complaints should submit an inquiry by clicking here, or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 988#