Last updated: 08/01/2024

1. Introduction

This Privacy Policy provides notice of our information collection and use practices by DirectHub, and its affiliates (together, “DirectHub,” “us,” “our,” or “we”) in relation to DirectHub.com (the “Website”), including where you are a Website visitor, in relation to our DirectHub solution, a user of the DirectHub application and associated Products and through offline means such as at DirectHub events (all together collectively, the “Services”).

2. Personal Information Collected

Personal information generally means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you. Personal information does not include information that is publicly available, de-identified, or aggregated.

We may obtain your personal information from the following sources:

• Directly from you. Such as when you subscribe to email notifications; communicate with us; fill out a webform; participate in our events; or apply for a job.
• Our vendors. Our vendors may provide us information related to you in the process of providing us their services. For example, if you apply for a job, we may use vendors to perform background checks.
• Tracking technologies. When you visit the Website, we use first-party and third-party technology integrations (such as cookies, pixels, and web beacons) that help facilitate and personalize your visit to the Website or to other online services.
• Other external sources. Such as data resellers, from your employer, and from referrals or business professionals in your network. This does not include our vendors.

Personal information we process about you may differ based on how you interact with us, but may include:

• This includes names, contact information, addresses, Internet Protocol address, or other similar identifiers.
• Personal Records. This includes your telephone number and employer.
• Commercial Information. This includes records of services purchased, obtained, or considered purchasing.
• Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, mobile network, browser type, operating system details, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with the Website.
• Geolocation Data. This includes global latitude and longitude of your location.
• External Service Information. We may obtain information about you from external services, such as where you choose to use a Website feature provided by an external party. We may also supplement certain information that we collect from you with outside records. External parties may provide us with information about you in connection with a co-marketing agreement or in connection with a tracking technology.
• Inferences. We may process inferences drawn from any other personal information we process to create a profile about you reflecting your preferences.

3. Cookies and Other Tracking Technologies

We and our vendors may use a variety of tracking technologies, such as cookies, that collect certain information whenever you interact with the Website, such as device identifiers, your IP address, location, other unique identifier, all of the areas within the Website that you visit, and the length and time of the visit.

Types of tracking technologies we may use:

• Operationally Necessary. These tracking technologies are used for the core operations of the website. Without these tracking technologies, the performance of our website may fail or not work properly. For example, ensuring the website’s security, or that your cookie preferences and settings are respected.
• Functional. These tracking technologies allow us to provide website features to enhance your experience and to assess and address the website’s performance through measurements analytics (such as which functions of the website could be updated for performance efficiency). For example, these tracking technologies may allow you to enable certain embedded features. Without these tracking technologies, some or all of these features may not function properly.
• Analytics Cookies. These tracking technologies allow us to assess how users navigate and interact with our website allowing us to measure and improve our services based on consumer interests and tendencies (such as knowing which parts or features of the website are the most and least popular).
• Advertising Cookies. These tracking technologies help us, and other parties, personalize ads that are shown to you on our website, as well as on other online services. If enabled, these tracking technologies allow you to receive cross-context and targeted advertising across online services over time. For example, if you show interest in one of our products shown on our website, you may receive an advertisement for that same product on a different online service.

Please note that we (or other parties) may collect personal information about your online activities over time and across different devices and online websites when you use the Website. We may use third-party technologies (such as Meta Pixel and Google Analytics) in connection with your activity on the Website, including for advertising purposes and to analyze your interactions and experiences with our websites, and including the features you engage with and how you navigate the Website.

You may be able to opt-out of certain tracking technologies using the settings, such as Do Not Track settings, on your browser. In addition:

• For more information on Microsoft’s data collection practices, please visit: microsoft.com/en-us/privacystatement.
• For more information on how Google Analytics uses the data it collects, visit: com/policies/privacy/partners. To opt-out of Google Analytics, visit: tools.google.com/dlpage/gaoptout. To adjust your Google advertising settings, visit: adssettings.google.com.
• To change your privacy and advertising settings with Meta, you may login to your Facebook account and navigate to your account settings.
• To opt-out of interest-based advertising from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit com/control and optout.networkadvertising.org.

We are not responsible for other parties’ opt out mechanisms.

4. How We Use and Disclose Personal information

We collect, use, and disclose to affiliates and vendors personal information, as described above, for the following purposes. Unless otherwise noted, the description below covers our activities in the twelve months preceding the Last Updated Date, as well as our current practices.

We use and disclose to affiliates and vendors personal information for the following reasons:

• Provide Services, including by maintaining products or services you ask for; operating and maintaining our online and offline goods and services; enabling external party features, such as embedded features on the Website; giving you information about our Services; communicating with you about our Services; book demos; and responding to your requests and questions.
• Necessary and Appropriate Internal Functions, including records maintenance; and developing or improving the Services.
• Research and Development, including to develop new features and to create new products or improve existing ones.
• Security and Integrity, including protecting our Services from cyber risks; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other liabilities; verifying identity; enforcing our policies and terms; protecting our rights; and generally providing you with a secure experience when using our Services.
• Quality, Safety, and Internal Research, including evaluating how our Services perform; repairing or improving the quality of our Services; tracking and responding to quality and security issues; and developing new or enhanced products and service offerings.
• Advertising and Marketing, including measuring the use of our Services and effectiveness of our advertising and marketing, including targeted advertising; to communicate with you about products or services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of services we think may be of interest to you; and uncovering insights to improve our Services and provide our users with enhanced features and functionalities, such as personalized experiences.

We may combine your personal information with data we obtain from the Services, other individuals, or other companies. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law.

Co-Branded Services. From time to time we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features on the Services. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “Co-Branded Services”). Any information, including personal information, that you provide on one of these Co-Branded Services may be shared with these partners. By participating in activities or providing your information on these Co-Branded Services, you consent to our providing your information to those partners. Separate privacy policies may apply to these partners’ uses of your personal information.

Business Transactions. In the event of a business transaction, we may disclose personal information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.

Legal Compliance and Safety. We may also disclose personal information for legal compliance, law enforcement, and public safety purposes. For example, to law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to: (1) comply with applicable law, court order, or governmental regulations, or other legal obligations; (2) assist in an investigation, regulatory requests, litigation, or arbitration; (3) protect and defend our rights and property, or the rights or safety of third parties, (4) enforce our terms, this Privacy Policy, or agreements with third parties, (5) comply with health and safety obligations; or (6) prevent crime.

5. Other Online Services

The Services may contain links to, or features facilitated by, other online services. For example, you may be able to share content from the Website to your social media profile on an external online service. This Privacy Policy does not apply to the practices of companies that we do not own or control. We provide these external links merely for your convenience and we have no control over, do not review, and are not responsible for external online services.

6. Your Choices

If you receive marketing emails from us, you may opt-out through the email’s instructions, as provided. Please note that regardless of your email preferences, we may send you notifications pertaining to the performance of our Services, such as transactional communications relating to products or services you have purchased or use.

7. Data Retention

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Privacy Policy or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. This generally means holding the information for as long as one of the following apply: 

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
• Your personal information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• We are otherwise required or permitted to keep your personal information by applicable laws or regulations.

To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal information from our systems and records. 

Where your personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. 

8. Data Security

We implement appropriate administrative, technical, physical, and organizational safeguards to protect against unauthorized or unlawful processing of personal information and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal information. DirectHub limits access to internal systems that hold personal information to individuals who need access for a legitimate business purpose.

9. Additional Information for California Residents

This section provides additional information on our processing of personal information related to California residents.

If you are a California resident, you have certain rights to the personal information that we have collected about you and you may exercise those rights independently or through an authorized agent. We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person that is the subject of the privacy request. Following verification of your identity, we will notify you if we are able to fulfill your request and if we are unable to fulfill your request, we will outline the reasons we are unable to honor your request.

Right to Know: You have the right to know about your personal information. You also have the right to obtain a transportable copy of your personal information. Your right to know request may be made no more than twice in a 12-month period.

Your right to know request may encapsulate the following:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information was collected
• Our business or commercial purposes for collecting, selling, or sharing your personal information
• The categories of third parties to which we disclosed your personal information
• The categories of personal information we sold or shared about you and the categories of third parties to which each category of personal information was sold or shared
• The categories of personal information we disclosed about you for a business purpose and the categories of persons to which it was disclosed
• The specific pieces of personal information we have collected about you

Right to Correct Personal Information: You may request that we correct personal information that we maintain about you if you believe such personal information is inaccurate. 

Right to Request Deletion of Personal Information: You may request that we delete your personal information that we have collected directly from you and are currently maintaining.

Opt-Out Rights: We do not sell or share for cross-context behavioral advertising purpose personal information outside of the context of tracking technologies or where we provide marketing lead lists to vendors for advertising purposes.

To opt out of the sale and sharing for cross-context behavioral advertising purposes through tracking technologies, click on the “Do Not Sell or Share My Personal Information” link in the footer of the Website.

We will not discriminate against you, including retaliation, if you choose to exercise any of your privacy rights under California law.

10. Additional Information For Those Located Outside the United States

If you are located outside of the United States, you acknowledge that we collect, process, and store personal information in the United States, and that the data protection and privacy laws in the United States may not offer the same level of protection than the applicable laws in your jurisdiction. Where we transfer your personal information to an entity outside of your location, we take steps to comply with law in respect of that transfer, for example by ensuring that your personal information is protected by comparable safeguards to those provided under the law of your location.

11. Updates to Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. We may provide more specific reasonable notice at our discretion (e.g., a banner, pop up, or email to you) if we materially change this Privacy Policy. Any changes to this Privacy Policy will be effective as of the “Last Updated” date at the top of this page, unless otherwise expressly indicated.

12. Contacting Us

You may contact us at (800) 949-3326, dataprivacy@directhub.com or:

Attn: Legal Counsel/Privacy 865 Albion St Suite 400, Denver, CO 80220