Privacy Policy

This Privacy Policy (“Policy”) describes the policies and practices of DTEN Inc. (“we” or “us”) as to the collection, use, and disclosure of information that we collect from users (“you”) when you purchase our product(s), access your account through our portal, and/or visit, access, use, or download from our website and all other media forms, media channels, mobile websites, or mobile applications related or connected thereto. Together, this Policy refers to these products, related services, our portal, and our website as the “Services”. Please read this Policy carefully. By visiting, accessing, using, downloading, or purchasing the Services, you agree to be bound by our Terms of Use and any other policies referenced herein, and you acknowledge that you have read and understood this Policy. If you do not agree with the terms of this Policy, please do not access or engage with DTEN Services.  This Policy is not a contract and does not create any legal rights or obligations.  For purposes of European data protection laws, DTEN Inc. acts as the controller in connection with the certain personal information described in this Policy.

If you are a California resident, see Section 8 for additional information pursuant to the California Consumer Privacy Act, including information on how to submit requests that we not “sell” your personal information by emailing support@dten.com.

Section 1: We Collect Information From and About You

We (and the vendors we hire to perform business functions on our behalf) may collect and receive various categories of personal information about you depending on the nature of your interactions with us:

• Contact Information. We might ask you to provide your name, shipping address, email address, telephone, and other contact information.
• Purchase and Preference Information: We collect information about your preferences or purchases when using the Services.  For example, we collect information about your order history and your preferences about our Services and platforms, as well as which pages and content you interact with.
• Internet and Network Activity Information. When you use the Service, we and our service providers (as enumerated below) automatically collect information about those interactions, including but not limited to the Internet Protocol (“IP”) address of your computer; web pages that you access within the Service; web pages that you access directly before and/or after accessing the Services; geographic information; a unique user ID; your access times; the type of browser, device, or operating system you use; search information; and usage and browsing information (such as what areas of our sites you visit and for how long, what search terms you enter, and what products or content you view and click on). If you access the Services through a mobile device, we will also collect certain device information, such as your mobile device ID, model, and manufacturer.

Section 2: How We Use Your Information

We use the above-referenced categories of personal information for the following purposes:

• Create and manage your account.
• Process and manage purchases, orders, payments, and other such transactions related to our Services.
• Email regarding your account or order.
• Enable user-to-user communications which may include third party services like Zoom Video communications.
• Generate a personal profile to make subsequent use of our Services more personalized.
• Increase the efficiency and operation of our Services.
• Analyze and improve our products and the Services.
• Send notifications of updates to the Services.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• For marketing purposes, such as delivering information on new products and services, recommendations, advertising, coupons, newsletters, and other information regarding promotions.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Request feedback regarding the use of our Services.
• Connect your DTEN account with opted-in third-party applications (e.g. video conferencing).
• Communicate with you as described elsewhere in this Policy.
• Verify your identity if you make requests pursuant to this Policy.

Section 3: We Collect Information From Various Sources

We collect information about you from various sources, directly and indirectly, including from the following sources:

• Directly from you. For example, we may ask you to provide certain information if you create an account, make a purchase, or otherwise engage or use our Services.  We may also ask for information if you participate in a promotion, contact us, or sign up to receive communications from us.  We will collect any personal information you provide when you post a comment, make a request, or complete a survey.
• Automatically from your devices. We use tracking tools like browser cookies and web beacons to automatically collect information about you when you interact with our websites, our ads, or our emails that we or our vendors send to you. To learn about your choices for these tracking tools, read Section 6 of this Policy.
• Vendors we hire to work on our behalf. For example, vendors that host or maintain our websites or send promotional emails for us may give us information. Our employment and recruiting vendors also give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information.
• Other sources. These other parties might include business and marketing partners, and social media platforms that give us the information they have collected either directly or indirectly from you.

Section 4: We Disclose and Share Information With Others

We may share or disclose each of the above categories of your information in the following circumstances:

• Business partners, affiliates, and marketing companies. We might share information with business partners or affiliates who co-sponsor a promotion or promote our services. We may also share the above categories of personal information with companies that help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal information received by our partners and other parties may also be subject to their privacy policies.
• Service providers. We use various service providers to help us operate the Services, such as analytics, payment processing, customer support, data analysis, customer service engagement, email delivery, cloud hosting services, and marketing assistance. Examples include Google Analytics and Amazon Web Services (AWS).
• For safety, security, or legal compliance purposes.  For example, we may share your information in response to a court order or where required by law, or to prevent, detect, or investigate suspected fraud, violations of our Terms of Use, harassment, or illegal conduct.
• Mergers or Reorganizations.  We might share your information with another company in the course of a business acquisition, merger, or sale of assets. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.

We may also share information for other reasons we may describe to you from time to time as permitted by law.

Section 5: Cookies and Other Tracking Technologies

We (including some of our service providers) use tools to collect information about how you use our Services. These tools include cookies, web beacons, tracking pixels, or other storage technologies that store users’ IDs or passwords to personalize web pages and provide website analytics. These tools help customize the Services and improve your experience, as well as analyze our performance and marketing activities. Please note that most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies completely.  Please see Section 6 below to learn more about your choices about these tracking tools.  If you choose to block cookies, our Services might not operate the way it was intended and any preferences you save may be lost.

Some content or links, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-party tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Please see Section 6 below to learn more about your choices about these tracking tools.

Section 6:  You Have Certain Choices About How We Use Your Information.

• You can opt-out of receiving our marketing emails. To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us. Even if you opt-out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.
• You may be able to block or remove cookies through your browser settings. You can delete cookies by going to the preferences, tools, or options menus of your Internet browser. If you choose to do so, some features of the website may not function properly.  Selections you make are device-specific and browser-specific, meaning that you may need to make your selections on each browser and on each device you use to access the Services.  To control flash cookies, which we may use on certain sites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
• You can opt-out of having your online behavior recorded and used for online behavioral advertising purposes.  To opt-out from receiving interest-based advertising from participating companies, visit the opt-out mechanisms of the Digital Advertising Alliance (United States), the Network Advertising Initiative (United States), and the European Interactive Digital Advertising Alliance (European Union). Choices you make are both browsers- and device-specific, meaning that you should exercise your preference on each browser and each device you use. If you clear cookies from your browser, you may need to exercise these choices again.
• Our Do-Not-Track Policy.  Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting that you can activate. This signals your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will do so accordingly.

Section 7: Your EU Privacy Rights

Since your privacy is important to us, we want you to be fully aware of the potential data protection rights under applicable law, including the EU General Data Protection Regulation (“GDPR”) if applicable to you. Information we collect may be sent to and stored on servers located in the United States of America, People’s Republic of China (China), or elsewhere outside the European Economic Area (“EEA”), and may be processed by personnel operating outside the EEA. As a result, this information may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. The standard of data protection in the United States, China, and in certain other countries where we may process your information is considered by the European Commission to be not adequate when compared to the data protection standards of the EU and EEA. By using our Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States, China, and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

Lawful basis for processing your EEA personal data.

We process personal data on the following legal bases:

1. Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
2. Legitimate Interests: We are permitted to process your personal data if it is based on our legitimate interests. In relation to the general inquiries and complaints you send us, our legitimate interest is to provide you with the information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
3. Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
4. Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of EEA Data Subjects

Users accessing Services from the EEA are entitled to the following rights:

1. The right to be informed – You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.
2. The Right to Access – You have the right to request access to your personal data that is within our possession. This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The Right to Rectification – You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request that we complete the personal data if you believe it is incomplete.
4. The Right to Erasure – This is also known as the “right to be forgotten.”  You have the right to request that we erase your personal data, if there is no compelling reason for us to keep using it or if it is no longer necessary in relation to the purposes for which it was originally collected or otherwise processed.  This is not a general right to erasure; there are exceptions.
5. The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data. If you choose to restrict DTEN from processing such data, DTEN may not provide you with Services.  We may keep lists of people who have asked to restrict processing in order to make sure the restriction is respected in the future.
6. The Right to Object to Processing – You have the right to object to certain types of processing of your personal data, in particular, processing based on our legitimate interests.  You also can object at any time to your personal data being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
7. The Right to Data Portability – You have the right to request that we transfer the personal data we have about you to another organization, or directly to you, in a format that is easily readable and transferrable.
8. The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to the processing of your personal information at any time with effect for future processing.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to your data protection authority.

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal data as described in this Policy, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements.

Section 8: Your California Privacy Rights, California Supplemental Privacy Notice

This California Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to the personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone).

If you are a California resident, you may ask for a list of third parties that have received your information for direct marketing purposes during the previous calendar year. If we have shared your information, this list will contain the types of information shared, and we will provide this list at no cost. To make such a request, contact us by emailing support@dten.com or sending us a letter to the address below.  Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

If you reside in California, you can make the following more specific requests with respect to your personal information:

• Access – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months.
• Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
• Do Not Sell My Personal Information – You can request that we not sell your personal information by emailing support@dten.com. For purposes of this Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions. Please note that if you make a request to opt-out of sale, if you would like to opt-out of cookie-based tracking for advertising purposes, you will need to separately visit www.aboutads.info/choices and https://optout.privacyrights.info to opt-out of certain uses of cookies for advertising purposes. Your selections are specific to the device, website, and browser you are using. Your selections are also deleted whenever you clear your browser’s cache.

DTEN will not discriminate against you because you made any of these requests.

If you would like to exercise any of these rights, please submit a request by  or emailing support@dten.com. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Except as otherwise provided by applicable California law, note that for purposes of these requests under this Section, personal information does not include information about job applicants, employees, and other of our personnel; or information about employees and other representatives of third-party entities we may interact with.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us.

California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

For purposes of California residents making these requests, please also note the following regarding how we collect, use, and share your personal information as described in this Privacy Policy, including in the previous 12 months:

• We or our service providers may collect the following categories of personal information for our business or commercial purposes (as those terms are defined in applicable law): Identifiers; payment and customer records information; commercial information; professional or employment information; and internet or other electronic network activity information. See Section 1 of this Policy for additional detail.
• We collect and use the above categories of personal information for the business and commercial purposes described in Section 2 of this Policy.
• We collect the above categories of personal information from the sources described in Section 3 of this Policy.
• We may disclose each of the above categories of personal information for the business and commercial purposes described in this Policy to the extent permitted by applicable law to the categories of third parties as described in Section 4 of this Policy.
• We may “sell” categories of personal information, including: Identifiers; commercial information; internet or other electronic network activity; and geolocation data. We may “sell” these categories of personal information to the categories of third parties described in Section 4 of this Policy.

Section 9: Security

DTEN is committed to being transparent about our security practices and uses industry standard security measures designed to protect your data at rest and in transit. We will continue to review and, where necessary, improve our security posture to support our commitment to protecting your data. Having said that, the Internet is not 100% secure, and we cannot promise that your use of our Services will be completely safe. Any transmission of your data to our websites is at your own risk. We encourage you to use caution when using the Internet. We keep personal information as long as it is necessary or relevant for the practices described in this Policy, or as otherwise required by law. Personal information may be accessed by persons within our organization, or our third-party vendors, and those other parties described in this Privacy Policy, including those who require such access to carry out the purposes described in this Privacy Policy, and such other purposes as permitted or required by applicable law.

Section 10: The Services Are Not Intended For Children Under the Age of 13

To access or use our Services, you must be at least 18 years old and have the requisite power and authority to understand and consent to the practices described in this Policy.  We do not knowingly market, direct our Services, or collect information from anyone under the age of 13 years old. If and when we discover the contrary, we will promptly delete the information from all of our databases.

Section 11: Third Party Links

Our Services may contain links to third-party websites and other applications of interest, including advertisements and external services that are not affiliated with us. Once you use these links to leave our Services, this Policy does not cover any information you provide to these third parties. We cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from our Services.

Section 12: How to Contact Us

If you have any questions about this Policy, the information we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us:

Call: 1-866-936-3836

Write: 97 E. Brokaw Road, Suite 180 San Jose, CA 95112

Please note that once you contact us to exercise any of your rights, we may require additional information and documents, including personal data, in order to authenticate and validate your identity and to process your request. We will then retain such additional data for legal purposes (e.g. as proof of the identity of the person submitting the request).

Section 13: Changes

From time to time, we may change this Policy. Any material changes, modifications, additions, or deletions will be effective immediately as soon as we give you notice of them, which we may do by means including but not limited to issuing an email to the email address listed by registered users and/or posting the revised Policy on this page. It is your responsibility to review this Policy periodically and to be aware of any modifications. Unless otherwise given an opt-in screen notification, your continued use of the Service after any modification means that you acknowledge the change and understand the practices that we disclose in this Policy.