Privacy Policy

1. Introduction

Distro, LLC (“Distro”, “we”, “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website (our “Website”), or any other services or offerings which may reference this Privacy Policy and our practices for collecting, using, maintaining, protecting, and disclosing that information and tells you about your privacy rights. By submitting information through our Website, you agree to the terms of this Privacy Policy, our Terms of Use as well as any other documentation referenced herein. If you do not agree you should discontinue use of the services immediately.

This policy applies to information we collect:

• On this Website.
• In email, SMS text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by us or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Information We Collect About You and How We Collect It

We collect the following types of information from and about users of our Website:

• That is about you but individually does not identify you; and/or
• By which you may be personally identified, such as name, e-mail address, age, mailing address, telephone number, username and password, or any other identifier by which you may be contacted online or offline (“personal information”);
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, referring URL, and information collected through cookies, pixel tags, web beacons, social media connectors and other tracking technologies, such as Google Analytics and Google Search Console.
• Directly from you when you provide it to us.
• From third parties, for example, our business partners.

3. Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at registration, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Any other data not specifically listed above regarding your use of the Website.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

4. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• When accessing the Website through a mobile device, the type of mobile device, your IP address, mobile operating system, unique device identifiers and browser type you use, and other diagnostic data.

This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not sell your personal information to third parties. However, like many companies, we use services that may collect your information (to deliver advertisements to you for example) and this may classify this use as a “sale” of your personal information; you can request to opt-out by submitting your request to support@distro.io.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

5. Information about Minors

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@distro.io. To learn about the Children's Online Privacy Act (COPPA), please visit https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see your California Privacy Rights for more information.

6. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website 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 website. 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.

Distro does not control these third parties' tracking technologies or how they may be used. When you access a third-party site through the links on this Website, the use of any information you provide is governed by the privacy policy of the operator of the third party site you are visiting. We encourage you to carefully review the privacy policies of any third party site you access so you know how they will use and share your information.

7. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• For marketing and advertising purposes to be used by third party analytics providers.
• To respond to requests by government authorities, court orders and regulations, or to perform other reporting obligations as required by applicable law.
• To provide you with notices about your account, including expiration and renewal notices and manage your requests.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our products and services is among the assets transferred.
• To deliver and facilitate delivery of services to you.
• To gather data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products and services, marketing and your experience and create anonymous, aggregated data.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

8. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy.

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Distro's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Distro about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Distro, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9. Retention of Your Information

• We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy unless otherwise required by law. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
• We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website or we are legally obligated to retain this data for longer time periods.

10. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by submitting a request to support@distro.io.
• Correspondence from Distro. If you do not wish to have your email address used by us to promote our own or third parties' products or services, you can opt-out by submitting a request to support@distro.io. If we have sent you an email, you may send us a return email asking to be omitted from future email distributions with the option to unsubscribe. This opt out does not apply to information provided to Distro as a result of a prior transaction.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by submitting your request to support@distro.io.
• SMS Text Messaging. By opting into SMS text messages from Distro, you authorize us and our service providers to receive text messages using automated means. You can opt out anytime by replying “STOP” or contacting support@distro.io. Message and data rates may apply.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website at http://www.networkadvertising.org/choices/.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to support@distro.io. However, please know we do not currently sell data triggering that statute's opt-out requirements.

11. Data Transfers

Distro is based in the United States. Depending on where you are located and the information provided to us, the information may be transferred to and maintained by us on servers located in the United States, which may not have the same data protection laws. However, we take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. By providing such information through the Website, you hereby expressly consent to such transfer and processing of your data into the United States.

To our European Union residents, it is sometimes necessary for us to share your personal information outside of the European Economic Area (“EEA”), as our offices are outside the EEA. The following circumstances may apply when these transfers are subject to special rules under European and UK data protection Law:

• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.

We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you would like further information, please contact us (see “How to Contact Us” below).

12. Legal Basis for Processing Personal Data under GDPR

To our European residents, we may process Personal Data under the following conditions:

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

Your Rights under the GDPR

Distro undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EEA, to:

• Request access to your Personal Data. The right to be provided with a copy of your personal information.
• Request rectification of the Personal Data. You have the right to correct any mistakes in your personal information.
• Object to processing of your Personal Data. The right to require us to restrict processing of your personal information in certain circumstances.
• Request restriction of your Personal Data. The right to require us to delete your personal information in certain situations including processing your personal information for direct marketing purposes or automated processing.
• Request the transfer of your Personal Data. The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the services that we provide.

Exercising Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to lodge a complaint with a supervisory authority in the EEA where you work, normally live, or where any alleged infringement of data protection laws occurred.

13. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us a request at support@distro.io to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or they might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

14. Your California Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

California's “Shine the Light” law (Civil Code Section § 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit your request in writing to support@distro.io.

15. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology and third-party payment processors.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

16. Changes to Our Privacy Policy

We may update this privacy policy periodically. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we may notify you either by posting a prominent notice of such changes or by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

17. How to Contact Us

If you have any questions or comments about this privacy policy and our privacy practices, contact us at support@distro.io.