Distro is committed to protecting the personal information of its users – customers, sellers and other visitors browsing the Site (“users”) as well as affiliates, influencers and other collaborators interacting with Distro. We believe that you have a right to know our practices regarding the information we collect when you visit and/or use the Site. This Policy explains our privacy practices for the Site and services provided by Distro as well as privacy practices that apply to affiliates, influencers and other collaborators who are individuals. By accessing and/or using the Site and its related sites, applications, services, goods and/or registering for an account and/or registering to our affiliate or influencer or similar program, you acknowledge that you understand how we process your personal data in accordance with this Policy, including our collection, use, disclosure, processing and retention of personal information. You can also learn how to limit sharing of information in this Policy.
Information You Provide. When you register to the Site, use it, complete forms, participate in skills tests or surveys, or use the Site as collaborator, and/or register to our affiliate or influencer or similar program, we ask you to provide certain personal information, including a valid email address. We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, telephone number or other contact details, transactional information, payment information (for example, in certain cases we process your payment method and ACH information), taxpayer information and forms, details about other social networks linked accounts, details about your job listings, purchases, education, profession and expertise, information and files uploaded by you to the Site, and additional authentication information. We also collect information about or contained in your communications with Distro as well as any of your posts on our blogs or forums and your communication with other users of Distro.
Additionally, in order to improve your online experience at Distro, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier, HTTP request data like, user agent, IP, host, URL, country/continent from which request made, browser info, device/operating system/operating system version.
Information We Receive from Third Parties. We receive information from third party vendors and/or other commercially available sources, such as:
- Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from advertising and marketing partners in order to manage and measure our campaigns.
- If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the basis that:
- you have provided your consent for us to use your personal information for a specific purpose;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
- the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
- the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
We will use your personal information for the following purposes:
- to provide you with quality service and security, to operate the Site, to perform our obligations to you and to develop and improve our service. For example, we use personal information to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with other members, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyze our performance as well as your preferences and performance and to customize and personalize our service and enhance your experience (including by making job suggestions, ranking search results, etc.).
- to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioral analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the Distro marketplace, other users, our community, or third parties, automated processes may restrict or limit your ability to use Distro. If you would like to challenge any such decision, please contact us at email@example.com.
- to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy.
- to promote and advertise the Site, our services and the Distro marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you, to organize and facilitate referral programs, contests or other promotional activities or events.
- to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
We will ask for your consent before using information for a purpose other than those set out in this Policy.
- We use your personal information to send you direct marketing communications about our products, services or promotions from Distro that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.
- Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted according to applicable laws. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to firstname.lastname@example.org
We apply a general rule of keeping personal information only for as long as is required to fulfill the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes:
- as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and
- in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
We share your personal information with third parties as detailed below:
With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes photos you upload, your published portfolio, job information, ratings, and additional information you may choose to add to your profile.
We also offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users.
- When you publish your information and/or share your data with other Distro users, you do so at your own risk. If you choose to share personal information with other users, including Sellers providing you a service via Distro, such personal information is shared with other users as separate controllers. While Distro our Terms of Service require Sellers to keep the information shared with them confidential, Distro cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards.
- With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions;
- For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Distro, our customers, or the public;
- For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site and securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
- With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook and Google, to promote our services or the Distro marketplace. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies.
- With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are a customer we may share certain limited information about you (such as the fact it is your first purchase on Distro) with the Seller to ensure the services you receive from the Seller will fit your needs; such sharing of information is limited in scope, and is only intended to improve the services provided by the Seller and your user experience;
In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Distro’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective customer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective, such as the United States. With regard to data transfers to such recipients outside of the EEA we provide appropriate safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer safeguards. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
We implement technical and organizational measures to maintain the security of the Site, our services and personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. Among other things, we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification (with respect to payment by credit cards), as required. In addition, we contractually ensure that any third party processing your personal information equally provides for confidentiality and integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party.
This section of the Policy applies to you if you are in the EU, the European Economic Area (EEA) or UK.
Under applicable EU regulation, you have the following rights in respect of your personal information:
- to obtain information about how and on what basis your personal information is processed and to obtain a copy;
- to rectify inaccurate personal information;
- to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
- to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
- to object to decisions which are based solely on automated processing or profiling;
- where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
- to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.
We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
This section of the Policy applies to you, if you are a California resident.
During the last twelve (12) months we have collected the following categories of personal information from users:
- Information that you chose to upload or otherwise provided by you to Distro, which may include: (i) Identifiers and personal information, such as name, postal addresses, online identifiers, email addresses, passport number or driving license number, social security number; (ii) characteristics of protected classifications, such as gender; facial image; audio, electronic or similar information; (iii) professional or employment-related information; (iv)education information; (v) commercial information; (vi) Audio or other sensory information, for example if you provide audio-based services on Distro.
- Information we collect when you use Distro, including (i) Identifiers and personal information, such as online identifiers, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions; (ii) commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (iii) Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; (iv) Location information.
- Information that we collect or receive from third parties, such as service providers, advertisers, and third-party accounts you link with Distro, including: (i) Identifiers and personal information, such as name, online identifiers, email addresses, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions; (ii) Professional or employment-related information; (iii) Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; (iv)Commercial information; and (v) Location information.
Inferences drawn from any of the information identified above to create a profile about you.
We use the personal information that we collect or receive for the business purposes as described above under the Section titled “How Do We Use the Information Collected?”.
As previously mentioned in this Policy, we do not “sell” (as such term is defined in the CCPA) personal information.
You are entitled to the following specific rights under the CCPA, subject to certain exceptions, in relation to personal information related to you:
- You have a right to request access to the personal information we have collected about you over the past 12 months, including: (i) the categories of personal information we collect about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) the categories of third parties with whom we have shared your personal information; (v) the specific pieces of personal information that we have collected about you.
- You have a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions.
- You also have a right not to be discriminated against for exercising your rights under the CCPA.
- You also have a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: (1) be a person or business entity registered with the California Secretary of State to conduct business in California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
To make such requests, we kindly ask that you open a Customer Relations ticket here: email@example.com
We will verify your request using the information associated with your account, including email address. Government identification may also be required.
To exercise any of your rights in connection with your personal information, we kindly ask that you firstname.lastname@example.org. Please include all the relevant details, so your ticket can be handled correctly.