Privacy Policy

COLLECTION OF INFORMATION

Personal Information You Provide to Us

“Personal information” is information that identifies an individual or relates to an identifiable individual. We collect personal information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, communicate with us via third-party platforms, or otherwise communicate with us. The types of personal information we collect include your name and email address, brand name, role, location, industry, and any other information you choose to provide.

Other Information We Collect When You Use the Services

When you access or use the Services or transact with us, we and our service providers automatically collect information about you, including:

• Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.
• Device Information: We collect information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: We may derive the approximate location of your device from your IP address.
• Information Collected by Cookies and Similar Tracking Technologies: We (and those that perform work for us) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory.

We use first and third-party cookies and similar technologies to collect such information as browser type, time spent on the Services, pages visited, language preferences, unique identifiers, content you view, click on, or share, screen gestures or actions, and other traffic data. We and our service providers use the information for security purposes, to power the interactive features of our Services, to facilitate navigation, to display information more effectively, to personalize your experience, to develop and improve the performance, functionality, and design of the Services, for advertising and marketing purposes, and to help keep the Services free of bugs or errors.

We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies and similar technologies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them to you. We do not currently respond to browser do-not-track signals.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that may be used, among other things, to track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

For more information about cookies and similar tracking technologies and how to disable them, see Your Choices below.

Analytics. We use third-party analytics services, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services collect and analyze user interactions with the Services, such as screens visited, pages and content viewed, screen actions and gestures, as well as browser and device details including type, version, model, and operating system. These services may also collect information regarding the use of other websites, apps, and online services.

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Merchant Customers

Disco provides the Services to merchants ("Merchants") who use the Services to offer their products and/or services to their consumers or users of other Merchant platforms (collectively, "Merchant Consumers") and/or to offer their Merchant Consumers third-party products or services that may interest them. Merchants are solely responsible for their privacy and security practices. Any and all information Merchants provide us from or about their Merchant Consumers is governed by the Merchant's privacy and security policies and practices. This Privacy Policy does not apply to any Merchant website, app, or services. Disco processes Merchant Consumers' information pursuant to the agreement we have with the respective Merchant.

If you are a Merchant Consumer and a California resident, please see the section below entitled “Additional Information for California Residents” to learn about the personal information we receive about you and your rights with respect to such information.

Information We Derive

We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.

We need to collect personal information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the data in accordance with this Privacy Policy.

USE OF INFORMATION

We use the personal information we collect to:

• Provide, maintain, and improve the Services.
  • Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests.
• Conduct marketing.
  • Communicate with you about products, services, and events offered by Disco and others, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time).
• Monitor and analyze trends, usage, and activities in connection with the Services.
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards.
• Process your application, when you choose to apply for a job with us.
• Accomplish our business purposes.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Disco and others;
  • Debug to identify and repair errors that impair existing intended functionality;
  • In connection with research and development activities;
  • In connection with our hiring activities;
  • Comply with our legal and financial obligations;
  • Create de-identified, anonymized or aggregated information; and
  • Carry out any other purpose described to you at the time the information was collected.

DISCLOSURE OF INFORMATION

We disclose your personal information in the following circumstances:

• To vendors, service providers, and consultants that perform services for us;
• In response to a request for information if we believe 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;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Disco or others;
• In connection with, or during negotiations of, any merger, sale of Disco assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Disco and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Disco 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 the Services and other websites, and better understand your online activity.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices, http://optout.networkadvertising.org/#/ or http://www.youronlinechoices.eu/.

YOUR CHOICES

Information

You may access, update, and correct certain information you provide to us at any time by emailing us at privacy@disconetwork.com or using your account settings page. If you wish to delete or deactivate your account, please email us at privacy@disconetwork.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time, as permitted under applicable law.

Cookies

Most web browsers are set to accept cookies by default. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Disco by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. This includes any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

USE OF SERVICES BY MINORS

The Services are not direct to minors under the age of thirteen (13), and we do not knowingly collect personal information from minors under 13.

CROSS-BORDER TRANSFER

Your Personal Data may be stored and processed in any country or region where we have facilities or engage service providers. By using the Services, you understand that your Personal Data will be transferred to countries outside of your country or region of residence, including to the United States, which may have data protection rules that are different from those of your country or region.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: privacy@disconetwork.com

SUPPLEMENTAL INFORMATION FOR U.S. CONSUMERS

Collection, Disclosure, Sale, Sharing, and Processing of Personal Information

The following chart details which categories of personal information about U.S. consumers we collect and process, as well as which categories of personal information we have collected and disclosed for our operational business purposes in the preceding 12 months. The chart also details the categories of personal information that we “sell” or “share” for purposes of cross-context behavioral or targeted advertising, including within the preceding 12 months.

Sources of Personal Information

We collect personal information from you, as well as from customers, affiliated entities, business partners, social media platforms, publicly available databases, joint marketing partners, data brokers and other marketing and advertising service providers, and background check providers as permitted under applicable law. If you are a Merchant Consumer, our Merchant Customer may provide us with additional types of personal information to those listed above. Please refer to the Merchant Customer’s privacy policy for details on its information sharing practices.

Purposes for the Collection, Processing, Disclosure, Sale, and Sharing of Personal Information

As described in detail above, under “USE OF INFORMATION,” we collect, process, disclose, sell or share personal information to operate, manage, and maintain our business, provide our products and services, and accomplish our business purposes and objectives. In addition, we use personal information collected about our job applicants for sourcing and recruiting talent, including to manage the applicant selection process, conduct reference checks, and analyze the diversity of job applicants, in accordance with applicable law.

We do not knowingly “sell” or “share” personal information, including Sensitive Personal Information, of individuals under the age of 16.

Retention Period

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we provide services to you or have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep copies of your transactions or application records for a certain period of time before we can delete them; or
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.

Individual Rights and Requests

If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Tennessee, Texas, Utah, or Virginia, you may make the following requests:

(1) Request to Know. You may request to know whether we process your personal information and to access the specific pieces of your personal information, including a copy in a portable format.

If you are a California consumer, you may also request that we disclose to you the following information:

• The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
• The business or commercial purpose for collecting, selling or “sharing” personal information about you;
• The categories of personal information about you that we sold or “shared” and, for each, the categories of third parties to whom we sold or “shared” such personal information; and
• The categories of personal information about you that we otherwise disclosed, and, for each, the categories of third parties to whom we disclosed such personal information.

If you are an Oregon or Minnesota consumer, you may also request that we disclose to you the categories of personal information we process about you and the third parties to whom we have disclosed your personal information.

If you are a Delaware or Maryland consumer, you may also request that we disclose to you the categories of third parties to whom we disclosed your personal information.

(2) Request to Delete. You may request that we delete your personal information.

(3) Request to Correct. You may request that we correct inaccuracies in your personal information.

To make a Request to Know, Correct, or Delete, please contact us at privacy@disconetwork.com or at our toll-free opt-out request number, 1-866-467-8688 (enter code 2258#). We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as email address, and full legal name, in order to verify your identity and protect against fraudulent requests. If you make a Request to Delete, we may ask you to confirm your request before we delete your personal information.

(4) Request to Opt-Out of Sale and/or Sharing. You may request to opt out of any future “sale” and/or “sharing” (for purposes of cross-context behavioral or targeted advertising as defined under applicable law) of your personal information by clicking here.

We also process opt-out preference signals, such as the Global Privacy Control. These signals set your opt-out preferences only for the particular browser or device you are using. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

(5) Right to Non-Discrimination. You have the right to be free from unlawful discrimination for exercising your privacy rights.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.

Appeals

If we refuse to take action on your request, you may request to appeal this refusal within a reasonable period after you have received notice of the refusal. You may file a request to appeal by using one of the methods listed above under “Individual Rights and Requests.” We will respond to your request consistent with applicable law.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.