Last Updated: February 23, 2022
Collection of Information
Use of Information
Sharing of Information
Advertising and Analytics
Transfer of Information to the United States and Other Countries
Your California Privacy Rights
Additional Disclosures for Individuals in Europe
COLLECTION OF INFORMATION
Information You Provide to Us
To use the Platform, you must enroll and agree to log-in to certain features through designated third-party provider accounts. In doing so, we collect information you provide directly to us. For example, you share information directly with us when you complete a digital form, submit or post content through our Platform, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, vehicle identification number (VIN), digital asset wallet address and any other information you choose to provide.
The Platform is not directed to children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with personal information without your consent, please contact us at [email protected] If we become aware that a child under the age of 16 has provided us with personal information, we will take reasonable efforts to delete such personal information.
Information We Collect Automatically When You Interact with Us
When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including:
- Activity Information: We collect information about your activity on our Platform and when you enroll or sign-up through our Platform.
- Transactional Information: When you make a purchase, we (and our service providers) collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
- Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
Information We Collect from Other Sources
We obtain information from third-party sources in order to provide business services. For example, we may collect information about you from identity verification Platform, data analytics providers, and/or mailing list providers. This information is required for the use of our services.Additionally, if you create or log into DIMO through a third-party platform (such as Google), we will collect to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address, VIN, or wallet address.
USE OF INFORMATION
We use the information we collect to provide, maintain, administer and/or improve the Platform. We also use the information we collect to:
- Provide services, content, material and other information on the Platform;
- Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
- Personalize and improve your experience on our Platform;
- Identify and/or diagnose problems on or related to our Platform;
- Send you technical notices, security alerts, and support and administrative messages;
- Provide requested information, technical support and/or integrations such as an application programming interface or API or information to support your eligibility for a token rewards program;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, Platform, and events offered by DIMO and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Platform;
- Target prospective customers with our products or services (with your consent, where legally required);
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of DIMO and others;
- Debug to identify and repair errors in our Platform;
- Comply with our legal and financial obligations;
- Carry out any other purpose described to you at the time the information was collected; and
- For other reasonable internal use or uses aligned with your relationship with us and the context in which we collected the information.
SHARING OF INFORMATION
We share personal information in the following circumstances or as otherwise described in this policy:
- We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as process orders, connect devices and integrate software, customer service, If you choose to use integrations we offer on our Platform, we share certain information with the integration partners.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of DIMO, our users, the public, or others.
- We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may share personal information in connection with, or during negotiations concerning, merger, sale of company assets, financing, bankruptcy, business closure, or acquisition of all or a portion of our business by another company. Additionally, as part of such an event, we may transfer or sell personal information to a third party. We will provide notice to you by email and/or a prominent notice on our Platform of any such sharing to a third party and any choices you may have regarding the sharing of your personal information.
- Personal information is shared between and among DIMO and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership (“corporate affiliates”). This information may be used to provide you with offers, services, or products that may be of interest to you and provide you with their products and services. Any such corporate affiliate may use your personal information only according to the terms of this Policy. If you are located in a jurisdiction where such sharing requires your permission, we will only share such information with your consent. If you decide you no longer wish to receive these promotional communications, please follow the instructions provided in Your Choices section below.
- We share personal information with your consent or at your direction for instance for the token reward program.
- We also share aggregated or de-identified information that cannot reasonably be used to identify you.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
DIMO is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers will transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
You may opt out of receiving promotional emails from DIMO by following the instructions in those communications or by emailing [email protected] If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Our Platform may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.
YOUR CALIFORNIA PRIVACY RIGHTS
California law, including the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83), afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
California Consumer Privacy Act
We will collect the following categories of personal information: identifiers, internet or other electronic network activity information and inferences. For details about the data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. We will disclose the following categories of personal information for business purposes to the following categories of recipients:
|Category of Personal Information & Recipient||Type of Information|
|Identifiers – Vendors and service providers including foundation and token distributor||Information, cookies, name, alias, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, VIN, wallet address or other similar identifiers|
|Internet or other electronic network activity information – Vendors and service providers including foundation and token distributor||Browsing history, search history, and information regarding interaction with an Internet website or application|
|Inferences – Vendors and service providers including foundation and token distributor||Used to create a profile reflecting a consumer such as: location and vehicle preferences|
California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which DIMO has shared personal information with third parties in exchange for valuable consideration. You will have the opportunity to opt-in to allow DIMO to share or “sell” personal information, with your consent at enrollment, so others may advertise products to you or for other uses as described herein. DIMO will only share personal information with your express consent and as agreed within DIMO’s terms of service. We may enable the “sale” of the following categories of personal information to the following categories of third parties.
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing us at [email protected] We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, account number and/or address. We will not discriminate against you if you exercise your rights under the CCPA.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact [email protected]
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at [email protected]
Do Not Track Signals
Our Services do not respond to “Do Not Track” signals communicated by your browser. We do not knowingly retain or sell tracking information collected about your online activity. For more information about Do Not Track, please visit www.allaboutdnt.com.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When DIMO processes your personal data, DIMO will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and Platform you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and Platform, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you enroll and opt in to receive marketing communications from us and our partners and/or enroll in the token rewards program). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.
We store personal data associated with your enrollment for as long as your use of our services and products remains active. In order to close your account, please contact us at [email protected] If you close your account and terminate your affiliation with DIMO, we will deactivate your account data within 30 days; otherwise, we will delete your account data after seven (7) years of inactivity. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Data Subject Requests
Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at [email protected]
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
Email: [email protected]
Postal address: DIMO, 8 The Grn, Ste B, Dover, DE 19901-3618