This “Privacy Policy” describes the privacy practices of Disploy LLC (collectively, “Disploy”, “we”, “us”, or “our”) in connection with the disploy.com website, the Disploy content management system including digital signage software and associated applications, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information. Disploy may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service. 

Table of Contents 

• Personal Information We Collect 

• How We Use Your Personal Information 
• How We Share your Personal Information 
• Your Choices 
• Other sites, mobile applications and services 
• Security practices 

• International data transfers 
• Children 
• Changes to this Privacy Policy 
• How to Contact Us 
• Your Global (US & European) Privacy Rights 

• Cookie Policy 
• What are cookies? 
• What types of cookies and similar tracking technologies does Disploy use on the Sites? 
• Your choices 
• Changes 

• Questions 

Personal Information We Collect 

Information you provide to us. Personal information you provide to us through the Service or otherwise includes: 

• Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name. 
• Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload. 
• Profile information, such as your username and password that you may set to establish an online account with us. 
• Registration information, such as information that may be related to a service, an account or an event you register for. 
• Feedback or correspondence, such as the information you provide when you contact us with questions, feedback, or otherwise correspond with us online. 

• Demographic Information, such as your city, state, country of residence, postal code, and age. 
• Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us. 
• Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service. 
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications 
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection. 

Information we obtain from social media platforms. We may maintain pages for Disploy on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. 

If you choose to login to the Service via a third-party platform, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your email address, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). 

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers. 

Cookies and Other Information Collected by Automated Means 

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications. 

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our applications, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our applications. 

See our Cookie Policy for more information. 

Referrals 

Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them. 

How We Use Your Personal Information 

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection: 

To operate the Service. We use your personal information to: 

• provide, operate and improve the Service 
• provide information about our products and services 
• establish and maintain your user profile on the Service 

• facilitate your to login to the Service via third-party identity and access management providers 
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in 
• communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages 
• communicate with you about events and contests in which you participate 
• understand your needs and interests, and personalize your experience with the Service and our communications 

• provide support and maintenance for the Service 
• respond to your requests, questions and feedback 

For research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying user demographics and use of the Service. 

To send you marketing and promotional communications. We may send you Disploy-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below. 

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. 

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. 

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyse and improve the Service and promote our business. 

How We Share your Personal Information 

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy: 

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy. 

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, payment processing and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. 

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information. 

Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos which you may display using our digital signage software). We may make available settings through the Account management page that enables you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to other users or the public. 

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us. 

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above. 

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. 

Your Choices 

In this section, we describe the rights and choices available to all users. Users who are located within Europe and other users whose personal data is processed in the context of our operations in Europe can find additional information about their rights below. 

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. 

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails. 

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. For more details, see our Cookie Policy. 

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. 

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. 

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device. 

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed. 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means. 

Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Google permissions page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party. 

Other sites, mobile applications and services 

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use. 

Security practices 

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfers 

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States, United Kingdom, EU or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country. 

Users based in Europe should read the important information provided below about transfer of personal information outside of Europe. 

Children 

The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us. 

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service. 

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. 

How to Contact Us 

Please direct any questions or comments about this Policy or Privacy practices to support@disploy.com. You may also contact us via the channels provided on our website contact page: disploy.com/contact 

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

Controller and Data Protection Officer. Disploy LLC are joint controllers of your personal information covered by this Privacy Policy for the purposes of European data protection legislation. 

We have appointed a Data Protection Officer, whose contact information is: display.com 

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below. 

Legal basis to operate the Service Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request to administer events for research and development to send you marketing communications to display advertisements to manage our recruiting and process employment applications for compliance, fraud prevention and safety to create anonymous data these activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law) to comply with law processing is necessary to comply with our legal obligations with your consent processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service. 

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis. 

Sensitive personal information (or ‘special category’ data). We ask that you do not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service. 

Retention 

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Your rights 

The United States and European data protection laws give you certain rights regarding your personal information. However, we are a United States Company and we will respect our neighbours, but Unites States specifically the city of Philadelphia, state of Pennsylvania will be govern law. You may ask us to take the following actions in relation to your personal information that we hold: 

• Access. Provide you with information about our processing of your personal information and give you access to your personal information. 
• Correct. Update or correct inaccuracies in your personal information. 

• Delete. Delete your personal information. 
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice. 
• Restrict. Restrict the processing of your personal information. 
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. 

You may submit these requests by email to support@display.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here. 

Cross-Border Data Transfer 

If we transfer your personal information to provide an adequate level of personal information protection, the transfer will be performed: 

• Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules 
• Pursuant to the consent of the individual to whom the personal information pertains 
• As otherwise permitted by applicable United States, city of Philadelphia, State of Pennsylvania requirements. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information. 

Cookie Policy 

This Cookie Policy explains how Disploy, LLC (collectively, “Disploy”, “we”, “us”, or “our”) uses cookies and similar technologies in connection with the display website and any other website that we own or control and which posts or links to this Cookie Policy (collectively, the “Sites”), along with the Disploy Player and any other mobile applications that we own or control and which posts or links to this Cookie Policy (collectively, the “Apps”). 

What are cookies? 

Your choices 

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. 

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites. 

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative for Digital Advertising Alliance. Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms. 

If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed. 

For more information about how we collect, use and share your information, see our Privacy Policy. 

Changes 

Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.