INTRODUCTION

This policy covers the processing of personal data by Dollar Driver, whose registered address is at 5753 Hwy 85N, Crestview, Florida, USA, and its associated Group companies (“Dollar”, “we” or “us”). Dollar is committed to protecting the privacy of your personal information whilst striving to provide the very best user experience. We want our websites to be safe and enjoyable for everyone. Under the UK General Data Protection Regulation 2021 (GDPR), the Data Protection Act 2018 and related laws, we have a legal duty to protect the personal information we collect from you. GDPR says that ‘personal data’ is any information relating to a living individual who can be identified, either directly or indirectly, from that information. This could include your name, email address, postal address or telephone number, or information collected online and used to identify you.

For the purposes of GDPR, the ‘Data Controller’ for Dollar services based in the US is Dollar Driver. For all services based in the United States, the Data Controller is Dollar Driver, and in Australia it is Dollar Driver. As Data Controller we are responsible for, and control, the processing of your personal data for the purposes of Dollar’s services. 

CONTACT DETAILS

We have appointed a Data Protection Officer (DPO) and Privacy Officer to oversee our data protection and privacy practices. If you have any comments, concerns or questions, including any requests to exercise your legal rights, our DPO and Privacy Officer can be reached as follows:

If you are in the UK/EU/US/Canada/Australia:

• By email: privacyofficer@dollardriver.org
• By mail: Privacy Officer, Dollar Driver, 5753 HWY 85N, Crestview, Florida, 32536.

It would be very helpful for us if you could include your full name, your postcode, details of the service you are using and/or magazine subscription information when contacting us.

WHAT DATA DO WE COLLECT AND HOW DO WE USE IT?

Information you provide to us	When you participate in, access, purchase or sign up to any of our services, activities, online accounts or online content, such as magazine subscriptions, newsletters, surveys, vouchers, competitions, events, webinars, white papers or community forums we receive personal information about you which we use to provide these services. This may consist of data such as your name, email address, postal address and telephone number. We will use this to provide the specific products and services you are seeking, and will ensure we have a lawful basis for doing so, in accordance with the country in which you reside.
Ordering a product or service from us	If you order a product or service from us, you will need to provide certain personal details, including payment information, so the order can be fulfilled. This may be collected, for example, as part of the registration process or when creating an account. In some cases, we will use or direct you to a third party who will collect this information from you and fulfill your order. For example, if you order a subscription to our services or publications, you may be able to access those products through a digital medium like the internet or mobile device.
Attending an event	If you attend one of our events, awards or conferences we may receive personal information about you, including your name and contact details and any dietary and accessibility requirements. If you attend one of our events remotely, we may share your name and contact details with the platform hosting the event.
Content you share with us	When you choose to share comments, photos, videos and other content with us we may receive personal information about you, for example when you interact with us on social media.
Information we collect automatically when you use our sites/services	We may collect technical and/or behavioral information about your use of our websites or other content online, and the device(s) you use to access the services. For example, this information may include details about how you browse our website and the devices and technology you use to browse our website. This may also include unique online identifiers such as device ID, device type, IP address and approximate location at the time of browsing. This may also include video viewing data and may link to your activity on other sites and allow us to recognise you or your device. We may use this to build a more detailed profile of you and your interests. We may also provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data.Please see What data is collected on our websites? and our Cookies Policy for further details about how we use this data and information on opting out.
Information for analysis, reporting and research	We also collect statistical and analytical data about your visits and activity on our sites, such as the pages you view, how long for, and which links are followed. This helps us to improve the way we deliver content and the products and services offered to you. We also use this anonymised data to report on our performance and to sell advertising. In addition, we may need to contact you about your experience of a product or service we provide you.
eCommerce	Some of our websites contain links to products and services offered by third-party websites. If you click on those links we will use data collected about your activity on our site to direct you to the third party site. We and the third party may collect data to show us that you have clicked on the link and whether you purchased any products and services. We may receive a commission from the third party if you link to their site from a Dollar site and purchase goods and services from them.
Direct marketing	We use the information you provide us with, such as email, address, or phone number, to send you marketing communications, either based on your consent or where we have legitimate grounds to do so. You can update your marketing preferences at any time. If you would like to unsubscribe (or opt-out) of receiving these emails please click the links on the emails you receive or contact our DPO.
Email tracking and online behaviour	We use web beacons in our emails to track the success of our marketing campaigns so if you open an email from us, we can see which of the pages of our website you visited. Our web beacons don’t store any information on your computer but, by communicating with our cookies on your computer, they can tell us which emails you’re interacting with and how you’re interacting with them. For example, we will know when you have opened an email from us and the devices used. We may keep track of the emails that we send you and may use the information we collect to personalise the emails we send to you. We also keep a record of the communications you have selected to receive or not to receive, for example whether you would like to only receive brand marketing from a particular brand, or that you have agreed to receive emails deemed of interest to you from other brands within the Group. We may also use your email in a hashed, unidentifiable form to help us understand your online behaviour. This may in turn be used for analytics and targeting. For use of your email for advertising purposes, see below..If you would like to opt out of receiving such emails  or your email being used in this way, please contact our DPO.
Data matching, to recognise you or your device, and to serve targeting advertising	We may share information that we collect from you (for example, when you browse through our websites or use our mobile applications), such as your email (in hashed, pseudonymous form), IP address, your mobile advertising ID or information about your browser or operating system, with our partners, and their group companies, who use this information to create an online identification code for the purpose of recognising you on your device. This code does not contain any of your identifiable personal data and cannot be used to re-identify you. We place this code in our first-party cookie or use a partner’s cookie, and allow it to be used for online and cross-channel advertising. This hashed, pseudonymous code may be shared with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them. For example, one of these third parties is LiveRamp who acting as “joint controllers” (as applicable and defined in the GDPR) use the information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you. To opt-out of this activity with LiveRamp, click here; https://liveramp.com/opt_out/We also work with other parties, for example The Trade Desk who acting as “joint controllers” (as applicable and defined in the GDPR) use your email to create an Encrypted Code (called a European Unique Identifier or EUID). This non-identifiable code is then used to recognise you on your device and is also shared with different sites and advertisers who have permission to process the  Encrypted code. As a result other websites, apps, advertisers, and advertising companies are able to show you relevant advertising. To opt-out of this activity with Trade Desk, click here; https://www.transparentadvertising.eu/You have the right to withdraw your consent or opt-out of processing your personal data at any time. If you would like to withdraw your cookie consent you can do so via the consent management pop-up. To opt-out of your hashed email address being shared for profile-based online advertising, please email dpo@dollardriver.org using the subject line ‘opt-out of hashed email ad profiling’. Where we have your email address, We and our partners will store and/or access information on your device and will use the unique advertising identifiers and other personal information for personalized ads and content, ad and content measurement, audience insights, and to develop and improve our products. To do this, personal information may be used to match and combine offline data sources.
When you contribute articles and content	If you write for us, or provide us with content in return for payment, through one of our sites, we may collect your social media profiles, such as Facebook and Twitter, on registration.  This allows us to show links to your social media profiles within the content that you write, allowing other users of the site, and yourself, to share your content with others. This may also involve giving you access to the areas of a website that directly interacts with or makes use of YouTube APIs. This enables us to collect other information needed to upload content such as the source of the video, (for example, from an existing article or original content or playlist), also analytical data such as view counts, and how long watched. We will also use the information you provide us with, such as bank details, to ensure we pay you the correct fees for the content you provide for us.
Research surveys	We may use the information you provide to invite you to participate in surveys and focus groups about our products, clients and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services.
Information from other sources, including Group companies	We may receive information about you from other sources (for example, missing information about your postal or email addresses) and add it to the personal information we hold about you. We may also receive data from other sources, such as our business partners, Group companies and social media platforms. For example, when you visit one of our Facebook pages. Other information, such as inferred data and demographics data, may also be collected and used to match, combine and enrich profile information we hold on you. For example, linking your contact or subscriber information with your activity across our sites. In addition, if you opt-in to receive marketing from our Group companies, you may receive emails deemed of interest to you from other brands within the Group.
Business specific data	Some of our websites also collect business data, for example when signing up for a webinar or when downloading a white paper. This may include professional or employment information, such as company name, job title,  job function, level in organisation, company type, company revenue and number of company employees, business phone number, business address, business email, corporate website, employment history, professional designations and educational information. Also location information, such as country, and state (or county), and ZIP code (or postcode).  We typically collect this information directly when you complete registration forms or when you provide other information through our Website or via email. When we collect this information directly, we let you know if providing the information is optional or if it is required to provide our Services.Occasionally we may purchase business data from third-party suppliers which may include, for example, business email address, business job title and business postal address. This may result in you receiving communications from Dollar regarding your business sector or business interests without you having directly supplied your information to us. For example, we may email you to encourage you to sign up to a webinar. We keep clear records of the data suppliers and provide an unsubscribe option at every contact.For information on the third parties we work with or If you have any queries concerning the use of business data we hold about you please email dpo@dollardriver.org (UK/EU consumers) or privacyofficer@dollardriver.org.com (US/Canadian Consumers)

WHAT LAWFUL BASIS DO WE RELY ON FOR PROCESSING?

In order to process your personal data, we must have a lawful reason for doing so. GDPR sets out six lawful bases under which organisations can collect, use and store personal data. We rely on four of the lawful bases:

Necessary for the performance of a contract

If you are our customer, for example a subscriber of a magazine or an attendee at one of our events, we will process your personal data on the basis that it is necessary for us to provide our products and services to you.

Consent

In some instances we rely on your specific consent to process your personal information. This is where you have actively agreed and ‘opted-in’, for example to receive marketing communications from us, and you have the right to withdraw your consent at any time.

Compliance with laws

We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons.

Legitimate interests

In some situations we rely on our legitimate business interests in order to collect and use your personal data. In these situations, we have conducted a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied there is no negative impact on you. We rely on Legitimate Interests for the following activities:

• providing, maintaining, improving and developing our products and services;
• sending direct marketing communications about our products and services to customers, which may, for example in the US,  include content we send on behalf of advertisers;
• sending marketing communications related to the products and services of carefully selected companies in a business-to-business context;
• managing suppression and unsubscribe requests;
• researching publicly available business contact details;
• managing certain aspects of our events;
• analysing the use of our products and services;
• using aggregated, non – personally identifiable statistical and analysis data to identify usage trends, such as your visits and activity on our sites, and to determine the effectiveness of campaigns;
• allowing you to comment on our sites, provide feedback or take a survey;
• dealing with queries and complaints;
• notifying you of product recalls or providing other information concerning products you have purchased;
• personalising your experience on our sites;
• Improving merchandise selections and your overall shopping experience;
• using your data in hashed non-identifiable form to help find you or similar audiences through Facebook’s audience function and Google customer match; 
• identifying fraudulent behaviour and ensuring our websites and systems are secure; 
• building and enriching profiles of users based upon, for example, product selection and online behaviour; and
• sharing the information you provide and other information held about you within our Group companies, for the purposes of this policy.

If you object to our reliance on Legitimate Interests for any purpose please contact our DPO.

WHO MAY WE SHARE YOUR DATA WITH?

Agents

We use third parties to perform certain functions on our behalf including fulfilling orders, sending emails, organising and managing events, running competitions and promotions, conducting surveys or polls, removing repetitive information from customer lists, comment hosting, website analysis, data analysis, and processing credit card payments. They will have access to your personal information if necessary to perform their function but they cannot use it or disclose it for any other purpose unless you have specifically given them consent to do so.

Auditing organisations and other professional advisors/companies

We may share your personal data with any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts. We may also share your data with our own professional advisors and auditors for the purpose of seeking professional advice and services  or to meet our audit responsibilities.

Aggregate Information

We may share aggregated, non-personally identifiable information, such as demographics and website usage statistics, with advertisers, sponsors, and other organisations. This may include, for example, tracking your cookie ID,  IP address and engagement metrics, when you are online in the course of business,  which is then aggregated to create a profile of a company, not an individual.

Products or services offered in partnership with third parties

Certain products or services available through this website may be provided to you in partnership with a third party (“ Co-Branded Areas”) . That third party may require you to disclose personal information to them in order to receive such products or services. If you request a product or service offered in partnership with a third-party, the identity of the third party will be disclosed to you and your personal information will be transferred to that third party.

Also, if you sign-in to a Co-Branded Area with a username and password obtained on the Site, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  

Alternatively, when you register for an event, webinar we may share data with the sponsors of the event or webinar, and other partners and advertisers (collectively, “Sponsors”).  This will be in accordance with the privacy laws in the country in which you reside.  For more information see Webinar and Event Registration.

We are not responsible for such third-party’s data collection or practices and you should look to such third-party privacy policies for more information. 

Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions (any, a “ Promotion”) through the Site that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

Group companies

Dollar Group companies may use and share the information you provide, and other information held about you, for the purposes set out in this Policy. For more information about Dollar Driver please see the Dollar Driver website. For more information see  How we work with group companies.

Changes in ownership

If we sell any parts of our business, for example a website or a magazine, we may have to share your personal data with the purchaser. For example, to enable them to continue providing a subscription or other service to you. The new owners will use your personal data as set out in their Privacy Policy. 

Ad serving plus measurement and reporting services

We may use a third-party network advertiser to serve the advertisements on this website. Network advertisers are third parties that display advertisements based on your visits to this website and other websites you have visited. This third-party ad serving enables us to target advertisements to you for products or websites you might be interested in. We may also use an audience or traffic measurement service to analyse the traffic on this website. Audience and traffic measurement services allow us to collect traffic and behavioural information from the website by monitoring anonymous visitor activity. This website’s advertisers, sponsors and/or traffic measurement services may themselves set and access their own cookies on your computer if you choose to have your cookies enabled in your browser. Please see What data is collected on our websites? and our Cookies Policy for further details and information on opting out.

Advertisers and advertising networks

We may also share de-identified information and/or aggregated information with a third party who is helping us select and deliver interesting and relevant advertising to you and/or other potential customers. This includes sharing data with advertising networks and search engines, in order for us to deliver relevant advertising to you, based on what you appear to be interested in. For example when you are searching for information or browsing other sites.

This could also be in the form of an anonymous data segment or an online identification code called a privacy-protective identifier. (A privacy-protective identifier is where we convert the original information, such as an email address or phone number, into a value to keep the original information from being revealed). These third parties may use this code to link demographic or interest-based information you have provided in your interactions with them in order to limit the number of times you see a particular ad, enable interest-based content or provide you with targeted advertising. You have the right to express a choice regarding our sharing of this data for the above purposes; of the creation of this code or of our sharing of the code with our advertising partners. 

Behavioural remarketing services

After you have visited our site, we may use remarketing services provided by companies such as Facebook and Google and Bing, to show you advertising on third-party websites, based on your browsing patterns and interactions. For this purpose, visitors are grouped by certain actions on our services, for example, by duration of visit. This enables us to understand your preferences and to show you personalised advertising even if you are currently on another website within the network.

Social media

We may also share de-identified information with social media platforms for advertising purposes. For example, we may share a hashed, non-identifiable version of your email with, for example, Facebook or Google, with the aim of showing you advertising on those platforms. Alternatively, we may use this data with the aim of excluding you from seeing our advertising on those platforms. We only share data in this way if you have agreed to receive marketing communications from us. Our ability to subsequently tailor (or exclude) ads in this way are determined by your account settings on those platforms. 

Some of our sites enable our users, and contributors, to share information with sites such as Youtube. On these occasions, our websites interact directly with YouTube (via its APIs), and make use of YouTube API services, for example interacting periodically with the YouTube APIs in order to keep any analytical data previously gathered up to date and complete.

By using these services, users are agreeing to be bound by the YouTube Terms of Service, which can be found at https://www.youtube.com/t/terms. In addition to our normal procedure for deleting stored data, users can revoke access to their data as it relates to the YouTube API by visiting the Google security settings page at https://security.google.com/settings/security/permissions.

When we share information with third parties, we only permit them to process this data for specified purposes. We do not share more information with them than is necessary for the relevant purpose and we require them to treat this information with at least the same protection we do.

WHAT DATA IS COLLECTED ON OUR WEBSITES?

‘Cookies’ are small data files which are sent to your computer, mobile phone or other device so that the website can remember information about your browsing activity. We use cookies on our websites for a variety of purposes:

Information storage and access

The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.

Content selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.

Measurement

When you visit our site we may collect information about your use of the content, and combine this with previously collected information, in order to measure, understand, and report on your usage of the service. This may include collecting certain personal data about you for an online audience measurement project that analyses internet users’ behaviour and profile across different websites, applications and devices in the US, working with IPSOS, a specialist research agency.

This does not include personalisation, or the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other services, such as websites or apps, over time.

Personalisation

The collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, to help us to personalise your experience and show you more relevant content and advertising.

Ad selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. 

This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.

Please see our Cookies Policy for more information.

HOW WE WORK WITH GROUP COMPANIES

Dollar receives information from, and shares information with, other companies within the Dollar Group to help operate, provide, improve, understand, customise, support, and market our services and their offerings. This includes:

• helping improve infrastructure and delivery systems;
• understanding how our services or theirs are used;
• promoting safety, security and integrity across the Dollar Group e.g. securing systems and fighting spam, threats, abuse, or infringement activities;

In addition, a key way we share data across systems and Group companies is for advertising and targeting purposes. This can be based on your online behaviour on our sites, for example:

• When you go onto one of our brand sites we can track your behaviour on those sites, or any of our other sites across our Group companies, and use this to target advertising or email content to you. 
• This also applies if you open an email from us and this takes you online as we can use the information from your online behaviour to later target marketing to you. So for example if you subscribe to marketing emails on one of our women’s sites and we see you have looked at phone content on our other sites we may provide you with phone related content in your marketing emails from the woman’s site. You can unsubscribe from emails at any time.
• We may also upload emails (in hashed, pseudonymous form) straight to the advertising data system and this enables us to identify the same non-identifiable user across devices. So we know, for example, that the person who looks at Dollar home content on their phone and then Dollar fashion content on their desktop, is in fact the same non-identified person. You can unsubscribe from emails at any time. 
• We may also use the other data you have provided to us, combined with your online behaviour, to personalise your email campaigns. You can unsubscribe from emails at any time.

Please note in the above scenarios where marketing is involved, the emails you receive will only be from Dollar, unless you have opted in to receive marketing from Group Companies.

LINKS TO OTHER WEBSITES

Our websites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and, when you leave our website, we encourage you to read the privacy notice of every website you visit. We may monetise some of these links through the use of third-party affiliate programmes. These affiliate links help pay the costs of producing our websites and ensure that the content is free to you. However, it doesn’t mean that we are in any way indebted to Amazon or any other company. Nor do they or any other company have any influence over editorial coverage, how we rate products, or whether they get a positive review.  Notwithstanding such affiliate programmes, we are not responsible for the content or privacy policies of these websites or for third-party advertisers, nor for the way in which they use the information they collect about you.

STORAGE AND RETENTION OF DATA

We hold personal data for a variety of different purposes and the length of time we keep your data will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. 

Once that purpose has been fulfilled, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.

DATA SECURITY

We are committed to protecting the personal data we hold and keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. 

Where we use third-party service providers to store data, we have appropriate agreements in place to ensure that your personal data is protected. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. We also require any third parties to whom we may transfer personal data to have appropriate security measures in place. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

Our websites may permit you to create an account, or have the facility for an account to be created on your behalf. When this happens, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account. If you believe your account has been compromised, please contact us at dpo@dollardriver.org.

INTERNATIONAL DATA TRANSFER

We operate a global business, so your personal data may be processed in a country other than your country of residence. For example, if you are UK citizen you may find your data is processed by  a supplier or service based outside the UK or EEA, such as in the United States. If such a transfer requires us to apply additional safeguards to your personal information under, for example, UK or European data protection laws, we will do so. These steps may include implementing the UK’s International Data Transfer Agreement clauses or European Commission’s Standard Contractual Clauses, with additional UK-specific clauses for transfers of personal information to our service providers and business partners. To the extent applicable, we may rely on derogations as set forth in Article 49 of the GDPR for the transfer and onward transfer of personal information collected from individuals in the UK or EEA to the United States, and other countries that the EU views as not providing adequate data protection. Specifically, we may transfer such information to another party in accordance with our lawful basis for processing.

By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer, storage and processing of your personal information outside your country of residence, including out of the  EEA, in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred in this way you should not use our website, applications or services.

PROTECTING CHILDREN’S PRIVACY

We recognise the need to provide further privacy protections with respect to personal information we may collect from children in connection with our products and services. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

• Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
• In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;
• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
• Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

SOCIAL MEDIA ACCOUNTS

We operate accounts on different social media platforms. If you visit one of our social media accounts we can usually only see information stored in your public profile on the social media platform, when you are logged in to your profile, while visiting our social media account; although we may process data that you provide to us when you contact us (for example: if you create a post, or send us a private message via Facebook).

If you visit one of our social media accounts, the operator of the social media platform also processes your data, regardless of whether you yourself have a profile on the platform. The social media platform also provides us with anonymous usage statistics, which we use to improve user experience. We do not have access to the usage data that the operator of the social network collects to create these statistics.

Certain sites offer services that require you to set up an account prior to receiving such services. To create a secure account you can use your email address and a password or, if the site offers a Facebook single-sign-on service, you will be able to register for and log-in to your account using your Facebook account. If you choose to use the Facebook single-sign-on service, you are granting permission to Facebook to share certain profile information with us. This may include your name, profile picture, and list of friends and any other information notified to you by Facebook prior to you completing the single-sign-on authorisation process. You control what social information you allow us to have access to using the privacy settings on the applicable media platform and any permissions you give as part of the single-sign-on authorisation process.

In addition, some social media platforms, such as Facebook, use cookies that are stored on your terminal device when you visit our social media account, even if you do not have your own profile in the network or are not logged in. These cookies enable the social media platform to create user profiles based on your preferences and interests and to show you advertising tailored to these).  For information on the cookies we use, please click here

WEBINAR AND EVENT REGISTRATION

When you register for an event, webinar or content item on any of the websites we may add your information to our mailing lists and share information, including personal data with the sponsors of the event, webinar or content item and other partners and advertisers (collectively, “Sponsors”). This will be in accordance with the privacy laws in the country in which you reside. For example, in the EU/UK,  you may have actively given specific consent for marketing from Dollar brands, and separately for your data to be shared with a ‘named sponsor’. Whereas in the US, by registering for a webinar or other event, you may be deemed to have consented to receive marketing communications via phone and/or email from Dollar, and the event Sponsors; for example if the event was free and you agreed to your data being shared and/or used in accordance with this Privacy Policy.

Wherever you are located, you can unsubscribe from our communications at any time, by following the unsubscribe instructions on the correspondence you receive, by amending your marketing preferences, or by emailing our DPO or Privacy Officer giving your email address, the brand name, and details of the information you no longer wish to receive. You can also withdraw consent (opt-out) of your data being shared by emailing our DPO or Privacy Officer by stating ‘Opt-out of Sharing’ and providing your email and the brand details as above.

Our DPO and Privacy Officer can be reached as follows:

• DPO: If you are from the UK/EU please email  dpo@dollardriver.org 
• Privacy Officer:  If you are from the US/Canada please email privacyofficer@dollardriver.org

Please note the use of your personal information by Sponsors, will be subject to their own privacy policy and practices, for which we are not responsible.

WEBSITE NOTIFICATIONS (POP UPS)

We provide news and updates about our sites via push notification messages or ‘pop-ups’. This is a free service. The notifications are only sent to you if you have clicked on a button to allow it (you may have accidentally selected to receive notifications).

We have no control over your subscription to notifications as it is controlled by your browser and device.  We do not store any recognisable data about you or your device in connection with the push notification service.

If you need additional assistance in relation to push notifications, please contact the team at push.notifications@dollardriver.org.

PRIVACY RIGHTS – UK AND EU CONSUMERS 

You have the right to request:

• Access to the personal data we hold about you.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of your personal data.
• That we stop using your personal data for direct marketing if you object to it.
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• The right to request a transfer of your data to another service provider.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. Remember, you can always stop direct marketing messages by clicking on an unsubscribe link in any of our emails or by contacting our DPO.

This also applies if you have elected to receive marketing from Group companies.  

Exercising your rights

If you wish to exercise any of your rights please contact the Data Protection Officer:

By mail: Dollar Driver, 5753 Hwy 85N, Crestview, Florida, 32536 USA; or

By email:

If you are a consumer, email dpo@dollardriver.org.

If you are a contributor, email privacy@dollardriver.org

It would be very helpful for us if you could include your full name, your postcode, details of the service you are using and/or magazine subscription information when contacting us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. If this is the case, we will notify you and keep you updated.

No fee usually required

You will not usually have to pay a fee to access your personal data (or to exercise any of the rights), however, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we choose not to action your request we will explain to you the reasons for our refusal.

PRIVACY RIGHTS – US AND CANADIAN CONSUMERS (BY STATE)

Privacy legislation in the US and Canada is evolving and as a result there are special rights for residents of certain states. This section details the existing state laws and consumer privacy rights and will be updated as the new laws are introduced.

We have appointed a Privacy Officer to oversee our data protection and privacy practices, in the US and Canada. Our Head of Data Privacy holds this position. If you have any comments, concerns, or questions, including any requests to exercise your legal rights, you can contact our Privacy Officer as follows::

• By email: privacyofficer@dollardriver.org
• By post:  Privacy Officer, Dollar Driver, 5753 Hwy 85N, Crestview, Florida, 32536

It would be very helpful for us if you could include your full name, your postcode, details of the service you are using and/or magazine subscription information when contacting us.

US Privacy Rights by State

The following section details your rights if you are a resident of California, Virginia, Colorado, Connecticut or Nevada.

California Privacy Rights 

This section applies only to California residents.  It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  

For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”)and amended by the California Privacy Rights Act of 2020 (”CPRA”). It does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA/CPRA. 

On some occasions,  in order to provide our Services to our clients, we may process service data that we receive from or on behalf of our clients. If you are a California resident, you may have certain CCPA rights with regards to this information. Under the CCPA, when we act as a “service provider” (as opposed to a “business” or a “third party”) over such information, we only process your information in a way required to provide our services to our clients, at our clients’ direction. If you wish to exercise any of your rights under CCPA regarding such information, please contact the relevant business that collected the information from you, as they controls and determine how your information is processed.

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. 

• Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.  
• Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months. 
• Deletion.  You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales.  Dollar does not “sell” any of your personal information in exchange for money. However, the term “sell” has a broader meaning under the CCPA/CPRA than would ordinarily be understood in a non-legal context. If we “sell” your Personal Information, you can opt-out. In addition, if you direct us not to “sell” your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. 

In the past 12 months, we have shared your Personal Information with third parties in the following circumstances, which California law classifies as a “sale” of your Personal Information:

• supplying your data to third parties with your express consent (e.g. where you opt-in to receive third party marketing or where you have requested to be contacted by a third party);
• with third-party marketing partners, including list brokers, for commercial use; 
• supplying attendee data to third parties who provide services in connection with our events, and sending your data to suppliers of certain products and services (where you have consented to hear from such third parties); 
• promotional partners, such as when you enter a promotion, contest or sweepstake;
• like many companies, we use services that help deliver interest-based ads, content and services to you and may transfer personal information to business partners for their use.  California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you. 

• Opt-in.  If we know that you are younger than 16 years old, we will ask for your parent or guardian’s permission to sell your Personal Information before we do so.
• Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.  

How to exercise your right to information, access, deletion 

You may exercise your California privacy rights by emailing privacyofficer@dollardriver.org quoting ‘California Privacy Rights-(insert name of Dollar Group brand)’ in the subject header and state which right(s) you wish to exercise. 

How to exercise your right to opt-out of the “sale” of your Personal Information

For internet and mobile users (online third parties). If you do not wish for us or our online third-party partners (such as advertising networks) to sell or share your personal information with others, please click on the “Do Not Sell or Share My Personal Information” link in the footer of the relevant website. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers. 

Alternatively to opt out of “sales” or “sharing” of personal information you can toggle your cookies off in the cookie preference center or enable Global Privacy Control (“GPC”) on your browser. To learn more about GPC, please visit http://globalprivacycontrol.org.

For subscribers (offline third parties): If you want to opt-out of all offline third-party sales, please email privacyofficer@dollardriver.org quoting

“California Privacy Rights – [insert name of Dollar Group brand]” in the subject header and state ‘opt-out of third-party sales’.

We will need to confirm your identity and California residency to process your requests to exercise your rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the CPRA allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension.

Virginia, Colorado, and Connecticut Privacy Rights

This section applies solely to individual residents of the States of Virginia, Colorado, and Connecticut. 

Privacy laws in these states, namely the Virginia Consumer Data Protection Act (CDPA), Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act (CTDPA),  give residents certain rights with respect to their personal data. 

These rights include:

• Access.  You can request a copy of the Personal Information we collected about you.
• Right to correct. You have the right to correct inaccuracies in the personal information we collect from you, taking into account the nature of the personal information and the purposes for which we process it.

• Right to delete. You have the right to delete personal information that you have provided by or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception to this right set as provided by the relevant law. Additionally, if you request the deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the relevant legislation.
• Right to data portability. You have the right to access and obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. 
• Right to opt out of targeted ads, sales to third parties, or profiling. You have the right to opt-out of the processing of your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As described in this privacy notice:
  • We DO process personal information for the purposes of targeted advertising;
  • We DO NOT sell your personal information in exchange for monetary consideration;
  • We DO NOT engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you.

How to exercise your right to information, access, and deletion 

You may exercise your privacy rights by submitting an email to privacyofficer@dollardriver.org quoting ‘US Privacy Rights-(insert name of Dollar Group brand)’ in the subject header and detail which right(s) you wish to exercise, and  the US state you live in.

How to exercise your right to opt-out of the “sale or sharing” of your Personal Information

For internet and mobile users (online third parties). If you do not wish for us or our online third-party partners (such as advertising networks) to sell or share your personal information with others, please click on the “Do Not Sell or Share My Personal Information” link in the footer of the relevant website. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers.

For subscribers (offline third parties):
Please submit an email to privacyofficer@dollardriver.org quoting “US Privacy Rights – [insert name of Dollar Group brand]” in the subject header and state ‘opt-out of third-party sale or share. We will need to confirm your identity and where you live to process your requests to exercise your rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the legislation allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension.

Residents of Virginia, Colorado and Connecticut may appeal a refusal to take action on a request by contacting us by emailing privacyofficer@dollardriver.org.

Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information. 

Although Dollar does not currently sell your personal data, as defined by Nevada Law, for monetary compensation to third parties for their own purposes. Nevada residents, may request that we include their name on a do-not-sell list in the event we were to do so in the future. Please email us at privacyofficer@dollardriver.org if you want to place your name on the do not sell list.

POLICY CHANGES

We review this Privacy Policy annually and may also amend it from time to time, so we encourage you to check it periodically. If we make material changes we will endeavour to provide you with appropriate notice before such changes take effect.

FURTHER INFORMATION

General information about data protection may be found at the Information Commissioner’s website: https://ico.org.uk/

For more information about cookies please visit http://www.allaboutcookies.org/ and for more information about how to manage cookies please refer to our Cookies Policy.

Information about direct marketing may be found at the Direct Marketing Association’s website: https://dma.org.uk/

To unsubscribe from all emails contact: dpo@dollardriver.org

If you feel you need to, you also have the right to make a complaint at any time to the ICO, the UK data protection supervisory authority (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact our DPO in the first instance.