DNA Privacy & Cookie Notice



Introduction

At Digtal NTAG Authentication, INC aka DNA ®, we are committed to protecting personal information. In this Privacy   Cookie Notice ("Notice"), Digtal NTAG Authentication, INC and its affiliated entities ("DNA," "we," or "us") set out how we, as data controller, may collect, create, share and use personal information relating to identifiable individuals ("Personal Data") and provide you with information regarding your Personal Data rights and choices.

Scope of this Notice

This Notice describes DNA privacy practices for Personal Data collected by DNA websites ("Sites") as well as other activities, such as if you visit our offices, attend a DNA event or otherwise interact with DNA and provide Personal Data, such as corresponding by email, unless such activities are covered by our other notices outlined below. Please read this Notice in full. By using our Sites or participating in other activities with DNA described below, you consent to the collection, creation, sharing and use of information as described in this Notice, where consent is required by relevant law.

Personal Data we may collect

The Personal Data DNA may collect about you will depend on your interaction/relationship with us. It may include:

  • if you browse our Sites, data relating to your interaction with our Sites, such as location (e.g., IP address), cookie related information (see section 6 below), usage (e.g., mouse clicks, page visits, feature usage, view time, downloads) and other information, such as language preference;
  • if you complete a webform on our Sites (e.g., to attend a DNA event or create a DNA Account), attend a DNA event (online or in-person) or office, or otherwise send this data to DNA (e.g., by email, telephone, exchange of business cards), your name, job title, work email, organization/employer name, work telephone, and location information such as work address;
  • if you or your organization purchases DNA products or services, financial or billing data, such as name, address, credit card number or bank account information (though these will typically be those of your employer organization);
  • if you attend a DNA event (in-person or online) or our offices, your attendance details (e.g., entry time);
  • if you avail of DNA services, such as attend a training class or submit a technical support case, your activity with DNA to interact with and take part in these services;
  • your image and/or voice, such as for phone/video call recordings (for training, quality assurance and administration purposes), if you attend a DNA event (event recording) or office (e.g., CCTV), post an image/recording to a DNA Site (e.g., add a profile photo to DNA Community) or you otherwise send a recording/image to DNA;
  • health information, if you visit our offices or attend an in-person DNA event and, if due to local COVID-19 related requirements, you are required to provide information regarding your health, vaccination status and recent travel history; and/or if in the course of visiting our offices or attending a DNA event, if you choose to disclose to us disability-related health information for the purpose of us making an accommodation/adjustment.

We may also collect Personal Data about you from third parties, such as from colleagues of yours at your organization (e.g., when registering multiple participants at an organization/company for DNA training, or where your details are provided by a colleague as a contact for your organization’s account), public sources (e.g., your organization’s website, LinkedIn), vendors (e.g., web analytics tools, data enrichment providers) and DNA partners (e.g., where your contact details are provided to enable delivery of DNA software, for customer success purposes and/or in relation to maintenance/support, including renewal and/or cancellation of same). We also maintain social media pages and may collect Personal Data from you when you interact with these or communicate with us through our social media pages.

Use of Personal Data

Depending on your relationship with DNA, we may use your Personal Data for different purposes. Where required by applicable law in relation to the particular use, we will obtain your consent to collect and use your Personal Data. Otherwise, we will rely on another legal basis, such as in connection with a contract or for our legitimate interests, as set out below.

  • Perform a contract: We may process your Personal Data in connection with a contract with you or your organization, such as to process relevant payments, deliver (customer) or receive (vendor) products/services, manage our relationship with you as a DNA partner under our DNA partner agreement with you, and manage our relationship with you or your organization generally throughout the contract lifecycle, including managing renewals.
  • Operate our Sites: We may use your Personal Data to provide our Sites, content and offerings (e.g., downloads, registrations for accounts or profiles, such as a DNA Account), including necessary functionality, content customization (e.g., based on what we think will interest you), and functionality to enhance ease of use (e.g., make the Sites easier for you to use by not making you enter information more than once, etc.). Unless such processing is in connection with a contract or our legitimate interests, it will be on the basis of your consent.
  • Improve our Sites: We process your interactions with our Sites, content and offerings (e.g., DNA support) to assess and improve these and the user experience, such as by use of cookies (see section 6 below). This data is typically aggregated unless Personal Data is required for the particular processing operation. We process your Personal Data for this purpose for our legitimate interests of maintaining and improving our Sites and providing tailored content, or where required by law, on the basis of your consent.
  • Manage contact requests: We may use your Personal Data to reply to contact initiated by you, such as through a webform, chatbot, survey responses or DNA support (through DNA Community). We process your Personal Data for these purpose for our legitimate interest in replying to/fulfilling your request, collecting survey responses and to carry out our contractual obligations under the applicable terms (e.g., providing DNA support).
  • Other communications: We may use your Personal Data to otherwise communicate with you to manage our relationship with you/your organization, such as to manage our offerings, for customer success purposes, to contact you regarding updates to our offerings you may be interested in, and to run surveys and contests. Such processing will be to fulfil our contractual obligations, where necessary for our legitimate interests or, where legally required, with your consent.
  • Call recording: We may record phone or video calls (e.g., Zoom) for training, quality assurance and/or administration purposes. We process this Personal Data on the basis of our legitimate interests however, if required under applicable law, we will obtain your consent or give you the option to object to the call being recorded.
  • Marketing: We may use your Personal Data to contact you for marketing purposes, such as to alert you to product upgrades, special offers, updated information/services from DNA, and to contact you (e.g., by phone or email) regarding your interest in our offerings and/or invite you to DNA events. Such contact will be on the basis of legitimate interest or, where legally required, on the basis of your consent. To opt-out of marketing contact, please unsubscribe here info@dnatag.io.
  • Events: We may process your Personal Data to operate DNA events, including training/education related activities, in-person and online, that you have selected to attend. Such processing will be on the basis of our legitimate interests or to perform a contract with you under the applicable terms of service.
  • Manage premises: Where you attend our offices, we may process your Personal Data to administer our premises and fulfil our legal obligations regarding health and safety, and to manage the security of our premises to ensure there is no unauthorized access. Such processing will be on the basis of our legitimate interests and/or to carry out our legal obligations.
  • Compliance and Security: We process your Personal Data to comply with our legal obligations and to ensure compliant use/security, such as to ensure the use of our Sites, content and offerings in compliance with our terms and/or to ensure their security, to cooperate with courts, regulators or other government authorities to the extent processing/disclosure of Personal Data is required under applicable law, where it is necessary to protect our legal rights or those of others, or for other compliance purposes such as auditing, investigations and responding to legal processes or lawful requests. Where we process health related data for Covid-19 related reasons or to accommodate a reasonable adjustment for a disability, we will only do so to carry out our legal obligations relating to health and safety, under applicable law.

We may also combine Personal Data we hold about you. For example, we may combine your contact information with your usage data relating to our offerings and our Sites for the purposes above, such as to improve our Sites and our offerings, as well as to create more tailored experiences by providing content that may be of interest to you. We may also use your Personal Data to fulfil any other purposes disclosed to you at the time of collection or as otherwise required/permitted by applicable law.

Cookies and similar technologies

As is true of most websites, when you visit our Sites, cookies will be placed on your device (computer, mobile or tablet). A "cookie" is a small text file that is placed on your device by websites you visit. Some of the cookies we use are strictly necessary to operate our Sites. Others relate to the Site's performance, functionality and/or to advertising. Information relating to a cookie or similar technology may include identifiers such as IP address, and information like general location, browser type and language, and internet activity such as timestamps. DNA uses the following types of cookies and similar technologies on our Sites:

  1. Strictly Necessary: These cookies enable the Sites to function correctly and deliver the services and products you have requested. These cookies do not gather information about you that could be used for marketing or remembering other websites you have visited on the internet.
  2. Functional: These cookies do things like remember your preferred language, understand your preferences and associate users to forms submitted to enable pre-completion of subsequent forms as well as improve and customize your experience on our Sites.
  3. Performance: We use third-party analytics tools to help us analyze how our Sites and other electronic mediums are used, such as allowing us to compile reports on website activity, providing us other services relating to website activity and internet usage and whether email communications are opened or left unread.
  4. Advertising: These cookies may be set on our Sites by our advertising partners. They may be used to build a profile of your interests and show you relevant adverts on other sites. If you wish to not have your online information used for this purpose you can also visit resources such as https://optout.networkadvertising.org and/or https://www.youronlinechoices.eu (please note these and similar resources do not prevent you from being served ads as you will continue to receive generic ads). Cookies can be session-based (which disappear once you close your device or browser) or persistent (which remain on your device afterwards). DNA may also rely on cookies or similar technology operating on other websites, for example to display our adverts to you. You can generally disable the use of cookies by changing your browser settings. To disable non-essential cookies for DNA.com sites, and to view their retention periods and relevant third-party operators/recipients, you can use access our Cookie Preference Center. You may also adjust your browser settings, however if you choose to not have your browser accept cookies from the DNA Sites, you will not be able to experience a personalized visit and it may limit your ability to use some features on our Sites. For more information about cookies, visit http://www.aboutcookies.org. We may also use pixels, web beacons and similar technologies on our Sites and in emails, for example in a marketing email that notifies us if you click on a link in the email.

Protection of Personal Data

DNA takes appropriate precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Such measures may include (i) using security controls such as, passwords, firewalls and/or encryption, (ii) restricting Personal Data to those with a legitimate purpose in receiving/accessing it, (iii) deidentifying Personal Data, or assigning codes or pseudonyms when the personal identifiers are not required for the purpose at hand, (iv) using data retention controls to ensure that Personal Data is not kept for longer than is necessary, (v) providing training and internal policies to team members to embed privacy and security across our organization, and (vi) putting in place relevant procedures (such privacy and security vetting) and contracts relating to the use and protection of Personal Data with third parties.

How long we retain Personal Data

DNA will retain and process Personal Data for a period of time consistent with the purpose of collection (see section 3 above) and/or as long as necessary to fulfil our legal obligations. We determine the applicable retention period by taking into account the (i) amount, nature and sensitivity of the Personal Data, (i) relevant use, including whether we can achieve the use through other means (e.g., by instead using deidentified data); (iii) potential risk of harm from unauthorized use or disclosure of the Personal Data, and (iv) applicable legal requirements (e.g., statutes of limitation). After the applicable retention period, we will delete the Personal Data, hold it in a form that no longer identifies you or, if we are unable for technical reasons to delete/deidentify it entirely, will implement appropriate measures to prevent any further use of such Personal Data.

Your rights relating to your Personal Data

You may have certain rights relating to your Personal Data, subject to applicable privacy laws. For example, under the UK/EU GDPR and similar laws, you may have the right to:

  • request access to and/or obtain a copy of your Personal Data;
  • request corrections to your Personal Data if it is inaccurate;
  • request further information about the processing of your Personal Data by DNA;
  • request deletion of your Personal Data that is no longer necessary to fulfil the purposes for which it was collected, or does not need to be retained by DNA for other legitimate purposes;
  • where we process your Personal Data on the basis of consent, withdraw this consent at any time. If you withdraw your consent to DNA to processing your Personal Data, this will not affect any processing which has already taken place;
  • request a restriction or raise an objection to the processing of your Personal Data;
  • if applicable, that your Personal Data be transferred to another company/organization;
  • not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Please note that Automated Decision-Making currently does not take place on our Sites or other activities covered in this Notice;
  • if you feel that your request/complaint has not been dealt with satisfactorily, make a compliant to your relevant privacy/data protection authority; and
  • not be discriminated against for exercising the above rights.

These rights will depend on which privacy/data protection laws are applicable to your Personal Data (typically, where you are resident), the type of Personal Data involved and the reason it is processed. There may be circumstances when DNA is unable to accommodate requests, either wholly or in part, for reasons under local law. Depending on applicable law, this may include situations where the information contains Personal Data of other individuals and it is not possible to separate out your Personal Data, if DNA cannot validate the request, if you ask us to delete Personal Data which we are required by law or have compelling legitimate interests to keep, or where information cannot be disclosed for legal, security, or other reasons based on local law. DNA will endeavor to advise you of any reason for denying or restricting any Personal Data request. You should make the request by email to info@dnatag.io and DNA will respond to any legitimate requests in line with local laws. Further contact details are also available in section 11 below. We will contact you if we need further information, for example to verify your identity to authenticate your request. If your request is to opt-out/unsubscribe from marketing contact from DNA, please visit info@dnatag.io.

Contact Information

For privacy inquiries or complaints, or to otherwise contact DNA Data Protection Officer, please email info@dnatag.io. For California residents, you may alternatively contact us by calling 800.270.2003.

Changes to this Notice

DNA reserves the right to modify or update this Notice from time to time to reflect changes in technology, our practices, law and other factors impacting the collection/use of Personal Data. You are encouraged to regularly check this Notice for any updates. We may also collect, use and disclose Personal Data for other purposes otherwise disclosed to you at the time of collection/processing in a supplementary notice.

 

Last updated: May 20th 2022