Privacy Policy

Protecting Your private information is our priority. This Privacy Policy applies to DigitalDisbursements.com and Digital Settlement Technologies (collectively "DST") and governs data collection and usage. The DST website is a digital payments site. By using the DST website, You consent to the data practices described in this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Business, for the purpose of the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act of 2020 (the "CPRA"), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

Company or DST (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Digital Settlement Technologies, 520 Broadway, Suite 200, Santa Monica, CA 90401.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA but is presently outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Data Controller, for the purposes of the General Data Protection Regulation ("GDPR"), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with You or Your household.

Sale, for the purpose of the CCPA/CPRA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Digital Disbursements, accessible from DigitalDisbursements.com.

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as You are the individual using the Service.

GDPR Privacy

Collection of Your Personal Information

In order to better provide You with products and services offered on Our Site, DST may collect personally identifiable information, such as Your:

  • First and Last Name
  • Mailing Address
  • E-mail Address
  • Phone Number
  • Employer
  • Job Title
  • Computing and Internet access environment, such as your IP address for security confirmation and information related to how you access and use our services online so we may continually improve our services to you

You may be required to provide certain personal information to us when You elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) sending us an email message; (c) submitting Your credit card or other payment information when ordering and purchasing products and services on Our Site. We will use Your information for, but not limited to, communication with You in relation to services and/or products You have requested from us. We also may gather additional personal or non-personal information in the future.

Use of Your Personal Information

DST collects and uses Your personal information to operate its website(s) and deliver the services You have requested.

DST may also use Your personally identifiable information to inform You of other products or services available from DST and its affiliates.

Sharing Information with Third Parties

DST does not sell, rent, or lease its customer lists to third parties.

Tracking User Behavior

DST may keep track of the websites and pages our users visit within DST in order to determine what DST services are the most popular. This data is used to deliver customized content and advertising within DST to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about Your computer hardware and software may be automatically collected by DST. This information can include Your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the DST website.

Use of Cookies

DST currently does not utilize "cookies" on its websites. A cookie is a text file that is placed on Your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to Your computer. Cookies are uniquely assigned to You and can only be read by a web server in the domain that issued the cookie to You.

One of the primary purposes of cookies is to provide a convenience feature to save You time. The purpose of a cookie is to tell the web server that You have returned to a specific page. For example, if You personalize pages or register with a site or services, a cookie can help the website to recall Your specific information on subsequent visits. This simplifies the process of recording Your personal information, such billing addresses, shipping addresses, and so on. When You return to the same website, the information You previously provided can be retrieved, so You can easily use the features that You customized.

If DST, in the future, opts to utilize cookies to help You personalize Your online experience, we will provide you the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies if You prefer. If You choose to decline cookies, You may not be able to fully experience the interactive features of services or websites You visit.

Security of Your Personal Information

DST secures Your personal information from unauthorized access, use or disclosure.

DST uses the following methods for this purpose:

  • SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of Your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect Your personal information, You acknowledge that there are security and privacy limitations inherent to the Internet which are beyond our control.

Children Under Thirteen

DST does not knowingly collect personally identifiable information from children under the age of thirteen. If You are under the age of thirteen, You must ask Your parent or guardian for permission to use this website.

E-mail Communications

From time to time, DST may contact You via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and or other general communication.

If You would like to stop receiving marketing or promotional communications via email from DST, You may opt out of such communications by sending an email to privacy@digitaldisbursements.com.

External Data Storage Sites

We may store Your data on servers provided by third party hosting vendors with whom we have contracted.

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. T he right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Right to restrict processing of Your Personal Data. You have the right to request that We restrict the processing of your personal data, under certain conditions.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us at privacy@digitaldisbursements.com. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area ("EEA"), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device, and sensitive personal information, as defined in the CCPA/CPRA.

Personal and sensitive personal information does not include:

  • publicly available information from government records;
  • deidentified or aggregated consumer information; and
  • information excluded from the CCPA/CPRA's scope, such as personal Information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act ("GLBA") or California Financial Information Privacy Act ("CalFIPA").

We may have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Description
A. Identifiers A real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code ยง 1798.80(e)) A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (Some personal information included in this category may overlap with other categories.)
C. Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement
D. Geolocation data Physical location or movements
E. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
F. Sensitive Personal Information This may include your Social Security, driver's license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; your genetic data; your biometric information for the purpose of uniquely identifying you; your health information; and/or information related to your sex life or sexual orientation.

Sources of Personal Information

We may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You or Your agents. For example, from the forms you complete on our Service, preferences You express or provide through our Service.
  • Indirectly from You or Your agents. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
  • From Service Providers. For example, or other third-party vendors that We use to provide the Service to You.

Purposes of Collecting Information

We may collect personal information for one or more of the following business or commercial purposes. They include:

  • fulfillment of the reason(s) you provided the information, such as the:
    • provision of information, products, or services you request from us; and
    • processing of your requests, transactions, and payments;
  • provision of support and responses to your inquiries, such as investigating and addressing your concerns and monitoring and improving our responses;
  • prevention, detection, and investigation of security incidents that potentially compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted data;
  • resistance to malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
  • the carrying out of our obligations and enforcement of our rights arising from any contracts entered into between you and us;
  • support of our ongoing operations and to maintain all our services and products, including audits and analytics collection, processing, debugging, and research;
  • responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • evaluation or conducting of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; and
  • any other purpose described to you during collection of your personal information or as otherwise set forth in the CCPA/CPRA.

No Selling or Sharing of Personal Information to Third Parties

In the preceding twelve (12) months, we did not sell or share personal information to third parties.

No Selling or Sharing of Personal Information of Consumers Under the Age of Sixteen

We have no actual knowledge that we sell or share information of consumers under the age of sixteen (16).

No Disclosures of Sensitive Personal Information to Third Parties

In the preceding twelve (12) months, we did not disclose sensitive personal information to third parties. We only disclose personal information and sensitive personal information for a business purpose within our own company and to service providers/contractors with whom we enter a contract.

Retention of Your Information

Our retention periods are based on timeframes necessary to:

  • fulfill the completion of transaction(s) for which we collected the personal information;
  • take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • detect and mitigate security incidents, including malicious, deceptive, fraudulent, and illegal activity, or prosecute those responsible for such activities;
  • debug products to identify and repair errors that impair existing intended functionality;
  • engage in research in the public interest that adheres to applicable laws, if you provided informed consent;
  • enable our operations and solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • comply with a legal obligation or exercise a right provided for by law; and/or
  • make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Your Rights under the CCPA

The CCPA/CPRA provides consumers (California residents) with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  1. Right to Know - You have the right to know what personal information we have collected about you. This includes a request for any or all of:
    • specific pieces of personal information we collected about you;
    • categories of personal information we collected about you;
    • categories of sources from which the personal information was collected;
    • categories of personal information we disclosed or sold for a business purpose about you;
    • categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
    • the business or commercial purpose for collecting or selling personal information.
  2. Right to Delete - You have the right to have your personal information that we have collected from you deleted, subject to certain exceptions.
  3. Right to Correct - You have the right to have inaccurate personal information that we maintain about you corrected.
  4. Right to Freedom from Discrimination - You have the right not to receive discriminatory treatment by us for the exercise of privacy rights described here and in the CCPA/CPRA, as conferred by those laws. This includes an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA/CPRA rights.

How to Exercise Your Rights and What to Expect from the Process

In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

  • By email: contact@digitaldisbursements.com
  • By visiting this page on our website: ./contact.html

Verification of Your Identity

If you or your authorized agent submit a data privacy request, we will need to first verify your identity in order to protect your confidentiality. You or your agent may be asked to provide three or more pieces of information we have in our records associated with your account. Once we verify this information, we will proceed with processing your inquiry or request.

Response Timing and Format

We will confirm receiving your request to know, correct, or delete within ten (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. In the event we are unable to respond within 45 days, we may request this deadline be extended for an additional 45 days. We will inform you of the reason and extension period in writing.

The scope of personal information we are required to disclose is limited to the data collected over the 12-month period directly preceding the date we received a verifiable request. The response we provide will also explain the reasons we cannot comply with a request, where applicable. For data portability requests, we will select a format to provide your personal information to you that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Fees

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Policy

DST reserves the right to change this Privacy Policy from time to time. We will notify You about significant changes in the way We treat personal information by sending a notice to the primary email address specified in Your account, by placing a prominent notice on Our site and/or by updating any privacy information on this page. Your continued use of the Site and or Services available through this Site after such modifications will constitute Your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

DST welcomes Your questions or comments regarding this Statement of Privacy. If You believe that DST has not adhered to this Statement, please contact DST at:

Digital Settlement Technologies
520 Broadway
Suite 200
Santa Monica, CA 90401

Email Address:
privacy@digitaldisbursements.com

Effective as of December 31, 2022