Privacy Policy

Privacy Policy

PRIVACY POLICY

Last Updated: February 23, 2022

This Privacy Policy explains how Digital Infrastructure Inc. and its affiliates and subsidiaries (“DIMO,” “we,” “our,” or “us”) collect, use, and disclose information about you. DIMO is an open connectivity platform for IoT devices, primarily for vehicles. We are committed to privacy and this Privacy Policy applies when you use our platform, marketplace, website and other online products or devices (collectively, our “Platform”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, when material, we will provide you with additional notice (such as adding a statement to our website or sending you a notification) and consent as required under applicable law. Your continued use of this Platform after we make changes is deemed to be acceptance of those changes when permissible.  We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics 

Transfer of Information to the United States and Other Countries

Your Choices

Your California Privacy Rights

Additional Disclosures for Individuals in Europe

Contact Us

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 Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, see which areas and features of our Platform are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Platform and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.

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. 

ANALYTICS 

DIMO may allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Platform and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by DIMO and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Platform and other websites, and better understand your online activity

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.

YOUR CHOICES

 Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Platform. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

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.

Third-Party Links

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 distributorInformation,  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 distributorBrowsing history, search history, and information regarding interaction with an Internet website or application
Inferences – Vendors and service providers including foundation and token distributorUsed 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.

DIMO does not currently share information such that it is considered a sale under California law; however, it may do so in the future. DIMO hereby seeks your consent to sell such information. We do not knowingly sell personal information about consumers under the age of 16. If you opt out of these sales, you will be deemed to terminate your enrollment with DIMO and access to its products and services as described in the Terms of Use.

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.

Data Retention

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/ 

CONTACT US

If you have any questions about this Privacy Policy, please contact us at:

Email: [email protected]

Postal address: DIMO, 8 The Grn, Ste B, Dover, DE 19901-3618