Data Privacy Policy

Last updated: August 2022

Introduction

This Data Privacy Policy (“Policy”) outlines how digitalproductkeys.ca (“DPKCA” or “We”) processes and safeguards personal data provided by you when you visit our website. For details on the processing of personal data within DPKCA Services, please refer to our Service Data Privacy Statement.

If your legal entity has a contractual agreement with DPKCA to utilize our Services (“Customer”), this Policy is integrated by reference in your Master Service Agreement (“MSA”). Your use of Services under the MSA is governed by this Policy. Unless explicitly defined otherwise in this Policy or the Service Data Privacy Statement, capitalized terms carry the meanings specified in the MSA.

At DPKCA, we are dedicated to ensuring the protection of your privacy. When you provide personal data to us while using this website, rest assured that it will be used in compliance with this Policy.

We may update this Policy from time to time by revising this page. Please check this page periodically to ensure your satisfaction with any modifications.

Scope of this Policy

This Policy is primarily concerned with personal data collected during your registration or authentication process for our Services. It does not encompass our security and privacy practices related to your access and use of DPKCA Services. Details about these security and privacy practices can be found in our Service Data Privacy Statement and our Master Service Agreement (collectively referred to as the “MSA”).

Information You Provide Us

Account Information

Customers are required to furnish specific personal information when registering for our Services, including name, address, telephone number, billing details (such as credit card information), and the type of personal computer used to access the Services. The personal data gathered during customer registration is used for managing the customer’s account, including billing purposes. We do not share this information with third parties unless expressly stated otherwise or in special circumstances. However, in cases where DPKCA and a Partner jointly promote the Services, DPKCA may provide the Partner with specific personal data, such as the names, addresses, and usernames of individuals who subscribed to the Services as a result of the joint promotion. This sharing is solely for the purpose of assessing the promotion’s results, and the Partner may not use the personal data for any other purpose. DPKCA may also create non-identifying and aggregate profiles from the personal data customers provide during registration (e.g., the total number of customers without disclosing their names). As explained in more detail below, we may use this aggregated and non-identifying information for displaying advertisements on our website and other platforms.

Other Submissions

We collect personal data that you voluntarily provide through our website, such as when you request a free trial or demo, seek information about our products or services, register for webinars, contact us, subscribe to our email newsletter, or download content (e.g., whitepapers).

Information We Collect from You on our Website

Cookies and Other Tracking Technologies

We, along with our authorized partners, may employ cookies and other data collection technologies for various purposes. These technologies may provide us with personal data, information about devices and networks used to access our websites, and insights into your interactions with our site. For a detailed explanation of how cookies and other tracking technologies are used on our website, please consult the “Cookie” section below.

Logs

We collect certain information and store it in log files when you interact with our website. This information may include internet protocol (IP) addresses, browser type, URLs of referring/exit pages, operating system, date/time stamp, search queries, locale and language preferences, identification numbers linked to your devices, and system configuration data. On occasion, we may combine personal data with information gathered in our log files, if necessary, to enhance our website and personalize your content. In such cases, we will handle the combined data in accordance with this Policy.

Analytics

We collect analytical information while you use our website to improve the website and related content. We may also share anonymous data about your website activities with third-party analytics service providers.

Information Collected from Third-Party Sources

We may obtain information, including personal data, from third parties when you request a free trial or demo of our Services, register for a DPKCA webinar, or download DPKCA content (e.g., whitepapers) from a third-party website that is related to or similar to our Services. We may combine this data with the information collected through our website.

Utilization of Collected Information

We may use the information we collect about you (including personal data, where applicable) for various purposes, such as:

  • Providing, operating, maintaining, improving, and promoting our Services.
  • Enabling your access and use of the Services.
  • Processing transactions, sending related information, including purchase confirmations and invoices.
  • Sending transactional messages, responding to comments, questions, and requests, providing customer service and support, and sending technical notices, updates, security alerts, and administrative messages.
  • Sending promotional communications, such as product and service information, features, surveys, newsletters, offers, promotions, special deals, contests, events, and other content we believe may interest you, via email or phone.
  • Customizing the website according to your interests.
  • Monitoring and analyzing trends, usage, and activities on our website and Services for marketing or advertising purposes.
  • Investigating and preventing fraudulent transactions, unauthorized access to the Services, and other illicit activities.
  • Personalizing the website and Services, including offering features or advertisements that match your preferences.
  • Other purposes for which we obtain your consent.

Legal Basis for Processing (EEA only)

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using personal data will depend on the specific context and the type of personal data involved. Typically, we collect personal data from you only when: (a) we have your consent, (b) we need the data to fulfill a contract with you (e.g., to provide the Services you requested), or (c) the processing is in our or a third party’s legitimate interests (not overriding your data protection interests or fundamental rights and freedoms). In some situations, we may have a legal obligation to collect personal data from you or may need the data to protect your vital interests or those of another individual.

If we rely on your consent for processing personal data, you have the right to withdraw your consent at any time. Please note that withdrawing consent does not affect the legality of the processing based on consent before the withdrawal.

If we request personal data to comply with a legal obligation or to perform a contract with you, we will clearly indicate this at the relevant time and advise you whether providing the data is mandatory, along with the potential consequences if you choose not to provide it. Similarly, if we collect and use your personal data based on our (or a third party’s) legitimate interests not already described in this Policy, we will inform you of those interests at the relevant time.

Protection of Personal Data

We are committed to ensuring the security of your personal data. To prevent unauthorized access or disclosure, we have implemented appropriate technical and organizational measures to protect and secure the personal data we process. Our website is built with industry-standard encryption and authentication tools to ensure data security.

We also employ technological measures, such as secure routers and firewalls, to safeguard personal data. Information collected through the website is encrypted before it is transmitted over the Internet, using industry-standard technology for secure online transactions. However, due to the inherent nature of the Internet, we cannot guarantee against the loss or misuse of personal data transmitted online.

In the event of a data breach, despite our best efforts to prevent it, we will take all necessary steps to minimize the damage. If a data breach poses a high risk, we will inform you about remedial actions to prevent further harm, depending on the circumstances. We will promptly notify the relevant supervisory authority or authorities as needed.

Cookies and Other Tracking Technologies

When you visit our website, we use cookies to store and retrieve information on your browser. A cookie is a small data file that a website requests your browser to store on your device. It helps the website remember information about you, such as your language preference or login credentials. These cookies may be first-party cookies, set by us, or third-party cookies from domains other than the one you are visiting, used for our advertising and marketing efforts.

More specifically, we use cookies and other tracking technologies for the following purposes:

  • Enhancing website navigation, improving your browsing experience, and personalizing content and advertisements.
  • Assisting with account creation, service subscription, event registration, login, and feedback submission.
  • Analyzing website usage to enhance our content.
  • Supporting promotional and marketing efforts, including behavioral advertising. We use traffic log cookies to identify popular and less-visited web pages, helping us analyze website traffic data and improve our site to meet customer needs. This information is used solely for statistical analysis.

In summary, cookies assist us in providing you with a better website experience by allowing us to monitor which pages you find useful or not. Cookies do not grant us access to your computer or personal data other than the information you voluntarily share with us.

Below is a detailed list of the cookies used on our website, categorized as follows:

  • Strictly Necessary Cookies
  • Performance Cookies
  • Functional Cookies
  • Targeting Cookies

These cookies are essential for the website’s proper functioning and cannot be disabled in our systems. They are typically set in response to your actions, such as service requests, privacy preferences, logins, or form submissions. Although you can configure your browser to block or alert you about these cookies, some parts of the website may not function correctly if you do so.

Examples:

  • Google Tag Manager
  • Microsoft.NET
  • digitalproductkeys.ca Performance Cookies

Performance cookies enable us to count visits and track traffic sources, helping us measure and enhance our website’s performance. They provide information about popular and less-visited pages and visitor movements on the site. The data collected is aggregated and remains anonymous. Blocking these cookies may result in an incomplete understanding of your visits to our site.

Examples:

  • Application Insights
  • Google Analytics
  • digitalproductkeys.ca Functional Cookies

Functional cookies enhance website functionality and personalization, offering features such as videos and live chats. These cookies may be set by us or third-party providers whose services we integrate into our pages. Disabling these cookies may affect the proper functioning of these features.

Examples:

  • Digitrust
  • Google
  • LiveChat Targeting Cookies

Targeting cookies are placed on our site by advertising partners and are used to gather information about your activities on our site and other websites. This information is utilized to create a profile of your interests and provide targeted advertising based on your browsing habits and interests on our site and others. These cookies uniquely identify your browser and device. Blocking these cookies will prevent you from experiencing targeted advertising on various websites.

Examples:

  • Google
  • Facebook
  • LinkedIn
  • Twitter
  • Yahoo
  • YouTube

Other Tracking Technologies

We may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. This information is used to improve reporting accuracy, enhance marketing effectiveness, and optimize our Services and websites for our users.

The following is an extensive compilation of the cookies utilized on our website. Our website undergoes regular scans with our cookie scanning tool to maintain an accurate list. We categorize cookies into four distinct groups:

Essential Cookies

These cookies are indispensable for the website to operate, and they cannot be disabled in our systems. They are primarily activated in response to actions taken by you, which essentially constitute a request for services. This includes actions like configuring your privacy preferences, logging in, or filling out forms. While you can configure your browser to block or provide notifications about these cookies, doing so may lead to certain parts of the website not functioning correctly. Notable Essential Cookies:

  • Google Tag Manager
  • Microsoft.NET
  • digitalproductkeys.ca Performance Cookies

Performance cookies permit us to count website visits and monitor traffic sources, enabling us to gauge and enhance the website’s performance. They aid in identifying the most and least visited pages and tracing user navigation. All data gathered by these cookies is amalgamated and, therefore, anonymous. Refusing these cookies would result in us being unable to determine when you have visited our website. Notable Performance Cookies:

  • Application Insights
  • Google Analytics
  • digitalproductkeys.ca Functional Cookies

Functional cookies empower enhanced functionality and personalization, including features like videos and live chats. These cookies may be set by us or third-party providers whose services have been incorporated into our pages. Disabling these cookies may hinder the proper operation of some or all of these functionalities. Notable Functional Cookies:

  • Digitrust Google
  • LiveChat Targeting Cookies

These cookies are set by our advertising partners via our website. They are designed to collect information about your activities on our website and other sites to construct a profile of your interests and propose advertisements according to your browsing activities and preferences on our site and other websites. These cookies work by uniquely recognizing your browser and device. If you choose not to allow these cookies, you will not experience our targeted advertising across various websites. Notable Targeting Cookies:

  • Google
  • Facebook
  • Linkedin
  • Twitter
  • Yahoo
  • Youtube

We may also employ clear gifs in HTML-based emails sent to our users to track email opens, enabling more precise reporting and enhancing the efficacy of our marketing efforts. Furthermore, we utilize Google Analytics, a web analysis service furnished by Google, to gain a deeper comprehension of your interaction with our website. Google Analytics aggregates data regarding the frequency of user visits, the specific pages they access, and their prior online destinations. Google utilizes this data to monitor and evaluate website usage, compile activity reports, and share them with other Google services. Google may also utilize this data to customize and contextualize ads within its own advertising network. The usage and sharing of information gathered by Google Analytics concerning your website visits are regulated by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers a web-based opt-out mechanism that can be accessed here.

Sharing Your Personal Data

We not to sell, distribute, or lease your personal data to third parties without your explicit consent or in situations necessitated by law. We may share and reveal your personal data in the following restricted circumstances:

Vendors, Consultants, and Other Suppliers

We may divulge your personal data to vendors, consultants, or suppliers engaged to deliver services on our behalf in connection with the purposes stated above. In such instances, these parties are obligated to utilize personal data exclusively according to our precise instructions and in accordance with the conditions established in this Privacy Notice. These entities encompass, for instance, our payment processing providers, marketing automation provider, website analytics companies, product feedback or help desk software providers, chat platform providers, CRM service providers, email service providers, and others. Legal Requests

We may disclose your personal data without your consent to the extent required by law, in association with legal proceedings or impending legal actions, and to affirm, execute, or protect our legal rights.

International Transfers

We may transfer the information we collect about you to countries distinct from the one where we initially collected it, for the purposes of data storage and processing, as well as for the operation of our services. These countries may not possess the same data protection laws as your own. However, when we do transfer your information to other countries, we pledge to safeguard it as articulated in this Privacy Notice and, when necessary, take actions to ensure compliance with pertinent laws.

Your Privacy Rights

You possess the right to request details of the personal data we hold about you. If you desire a copy of the information retained about you, please reach out to us at [email protected].

If you suspect that any personal data we have is incorrect or incomplete, please notify us as soon as possible at the aforementioned address. We will expeditiously rectify any inaccuracies or entirely remove your data from our systems.

Opt-Out

Marketing Communications

You can opt out of receiving marketing communications from us by adhering to the unsubscribe instructions included in our marketing communications.

Cookies

To learn how to opt out of each cookie category (excluding strictly necessary cookies), please refer to the Cookie Section in this Privacy Notice, specifically for individuals in the European Economic Area (EEA).

Retention of Your Personal Data

We commit to retaining your personal data only for the duration necessary to fulfill the objectives outlined in this Privacy Notice, unless a lengthier retention period is mandated or sanctioned by law, such as tax, accounting, or other legal requisites. The duration for which we retain your personal data hinges on the type of data and the purpose for which we process it. If there is no continuing legitimate business necessity to process your personal data, we will either erase or anonymize it. If erasure or anonymization is unfeasible, as might be the case if your personal data is stored in backup archives, we will securely maintain your data and disconnect it from further processing until deletion becomes viable.

How to Contact DPKCA

Please do not hesitate to reach out if you have any inquiries regarding DPKCA’s privacy commitments or practices. You can contact us at [email protected].

Service Data Privacy Statement

This Privacy Statement, last updated in August 2023, is intended to clarify and supplement the DPKCA Privacy Policy in regard to Personal Data processed on behalf of our Customers while delivering our Services. This Service Data Privacy Statement, herein referred to as the “Privacy Statement,” is incorporated by reference in your Master Service Agreement (MSA). The use of Services under the MSA is subject to this Privacy Statement. Unless explicitly defined in this Privacy Statement, capitalized terms have the meanings attributed in the MSA.

Definitions

Customer: Refers to a legal entity with whom DPKCA has an agreement to provide the Services. A Customer may act as a Controller or Processor of Personal Data. In cases where the Customer acts as a Processor of Personal Data, DPKCA processes Personal Data as a sub-processor on behalf of the Controller. Instructions regarding the processing of Personal Data are provided by the Controller through the Processor.

Controller: Denotes the natural or legal person, public authority, agency, or other entity that, either individually or jointly with others, establishes the purposes and methods of personal data processing.

Personal Data: Encompasses any information pertaining to an identified or identifiable natural person, referred to as a “Data Subject.”

Processing/To Process/Processed: Encompasses any operation or set of operations performed on Personal Data, whether executed automatically (e.g., collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other means of making data available), or via manual methods (e.g., alignment, combination, blocking, erasure, or destruction).

Processor: Signifies a natural or legal person, public authority, agency, or other entity that processes Personal Data on behalf of the Controller.

Service Data: Encompasses all data provided to DPKCA, stored on DPKCA’s servers, or utilized, posted, stored, transmitted, or transferred in connection with the Services. This includes but is not limited to text, sound, video or image files, materials, products, content, IP addresses, recordings, messages, software, Account Information, account-related settings, and may include Personal Data.

Third Party: Signifies a natural or legal person, public authority, agency, or entity other than the data subject, controller, processor, and individuals who, under the direct authority of the Controller or Processor, are authorized to process Personal Data.

Scope of this Privacy Statement

This Privacy Statement governs our security and privacy practices regarding your access to and use of DPKCA Services. It is important to note that this Privacy Statement does not apply to our security and privacy practices concerning your access to and utilization of DPKCA’s website (www.digitalproductkeys.ca). These practices are thoroughly detailed in and regulated by DPKCA’s Privacy Policy.

Customers utilizing our Services bear the responsibility for establishing policies and ensuring compliance with all applicable laws, regulations, as well as any privacy policies, agreements, or other obligations related to the collection of personal data in connection with the use of our Services by Data Subjects interacting with our Customers. If you are an individual interacting with a Customer using our Services, you will be directed to contact our Customer for assistance with any requests or inquiries regarding your personal data.

We collect information under the direction of our Customers and do not possess a direct relationship with individuals whose personal data we process in connection with our Customers’ use of our Services. If you are an individual who interacts with a Customer using our Services, and you wish to amend your contact information or no longer wish to be contacted by DPKCA, please communicate directly with the Customer you are interacting with.

Data We Process

DPKCA may process Personal Data about Data Subjects for purposes such as account creation, billing, usage tracking, and providing the Services on behalf of the Customer. Data that is not associated with an identified or identifiable natural person, including aggregated or de-identified data, is not considered Personal Data and is not addressed by this document.

Types of Personal Data

Account Information We may collect first and last names, email addresses, postal addresses, phone numbers, and similar contact data about authorized employees, consultants, or independent contractors of the Customer.

Payment Data We collect data necessary for processing payments, including payment instrument numbers (e.g., credit card numbers) and associated security codes.

Credentials We collect information related to authentication and account access, including passwords, password hints, and similar security data used for authentication.

Metadata

DPKCA’s servers automatically collect certain information when users access the Services, which includes data sent by web browsers or mobile applications. DPKCA has the capability to gather details about the devices used to access the Services, including device type, operating systems, device configurations, application IDs, unique device identifiers, and crash data.

Cookies and Alternative Tracking Technologies

Whenever a Customer or any Account Users interact with the Portal, DPKCA automatically receives and records information from the web browser. This information may encompass the IP address, “cookie” data, browser type, and device specifications used to access the Portal, such as screen resolution and browser language. These “cookies” are distinctive identifiers that DPKCA sends to the user’s browser or device, allowing DPKCA to identify the user and their device when accessing the Portal. DPKCA utilizes this information solely in an aggregated manner, ensuring that individual Account Users remain anonymous. For instance, aggregated data enables DPKCA to understand how frequently certain Portal features are used, thus aiding in enhancing the Services. Additionally, DPKCA employs an application session recording solution to capture user interactions with the Portal. These recordings may be associated with the Account User and the Customer Account to improve technical support services as per the Agreement.

Call Recording

DPKCA monitors and records calls to and from DPKCA related to the Services, including interactions with Technical Support and account managers. This recording is conducted for training, support, and quality control purposes.

Content

We process the content of Customer’s files and communications as needed to offer the Services. For example, when you receive an email via Hosted Exchange, we require access to the content of the email to deliver it to your inbox, display it, allow you to respond, and store it until you decide to delete it. Other data that we process for Customer Services include:

Subject lines and email body content. Text or other content from instant messages. Audio and video recordings of video or audio messages. Audio recordings and transcripts of voice messages you receive or text messages you dictate. Text or other content from files or data that Customers place on DPKCA’s servers, use, post, store, or transmit in connection with the Services.

Voluntary Customer Surveys

We periodically conduct customer surveys, both for businesses and individuals. We encourage our Customers to participate in these surveys as they provide valuable insights that help us improve our services and their delivery. Personal Data and survey responses remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is entirely optional. We amalgamate the information received from survey responses with those from other customers to create generalized, non-specific responses to survey questions, such as demographics (e.g., gender, age, location, hobbies, education, employment, industry sector). We utilize this aggregated information to enhance service quality and develop new services and products. This data may be shared with third parties in an aggregated and anonymous format.

Purposes of Data Processing

DPKCA processes the Personal Data mentioned above for the following purposes:

To operate our business. To provide and enhance our Services. To respond to Customer support requests. To send communications, including promotional messages. This policy does not impose restrictions on our use of data that has been aggregated and de-identified, as it can no longer be linked to an identifiable user or Customer of the Services and is thus not considered Personal Data.

Data Protection Measures

Concerning the Services and Service Data, DPKCA serves as a Processor on behalf of Customers. Customers bear the primary responsibility for interactions with Data Subjects, and DPKCA’s role is primarily to assist Customers as necessary. DPKCA processes Service Data solely upon a Customer’s instructions and is obligated to maintain the security and confidentiality of Personal Data, in accordance with agreements with Customers and applicable laws.

Security of Information

DPKCA places a strong emphasis on security. Various measures are implemented to safeguard Customer’s Service Data from loss, misuse, unauthorized access, or disclosure, taking into account the sensitivity of the Service Data and the current technological landscape. DPKCA maintains a dedicated information security team responsible for managing information security throughout the organization. The team includes an infrastructure team leader, infrastructure system administrators, and a senior security specialist, all of whom are responsible for enforcing DPKCA’s information security policies. These policies are reviewed annually by senior management.

In addition to security maintenance, the information security team monitors known incidents, patches, vulnerability assessments, and implements changes to policies and procedures as needed. These changes may include reassessing risk, revising incident response plans, and clarifying responsibilities for authorizing and monitoring access. DPKCA employs various technical and organizational security measures to protect Customer’s Service Data, including:

Logical access controls for electronic data access based on authority levels and job functions, utilizing unique IDs and passwords, and regularly reviewing and adjusting access. Password controls to manage password strength, expiration, and usage. Housing systems in secured data centers or server rooms, with controls to protect information assets. Operational procedures to ensure technology and information systems adhere to industry standards. System logging to proactively record user and system activity. Network security controls, including firewalls and Intrusion Detection Systems. Vulnerability management procedures to identify and protect against security threats. Change management procedures to ensure proper testing and approval of changes. Incident/problem management procedures for responding to events related to DPKCA’s technology and information assets. Organizational management for developing and maintaining information security policies, procedures, and standards. Audit and assessment procedures for monitoring compliance and reporting information security status to senior management.

Notification of Personal Data Breaches

If DPKCA becomes aware of Security Incidents involving Personal Data, it will promptly notify affected Customers, as permitted by applicable law. “Security Incidents” include unauthorized access to unencrypted Personal Data or loss, theft, unauthorized disclosure, or manipulation of unencrypted Personal Data with the potential to harm Customer systems, employees, information, or the Customer’s brand. Notification will be made via email to the designated Customer Account Contact(s) and will include a problem description, expected resolution time (if known), and the contact information of the DPKCA representative for updates. DPKCA will keep Customers informed of the progress and actions taken to resolve the Security Incident. DPKCA may also, at its discretion, notify relevant government authorities, such as those handling criminal acts, in these incidents.

Transparency and Cooperation with Customers

DPKCA commits to transparency in its Personal Data processing activities and offers cooperation to facilitate Customer’s data protection obligations regarding Personal Data. DPKCA will provide information on its processing activities affecting Customer upon request, subject to appropriate confidentiality agreements.

Sharing and Disclosure

This section outlines how DPKCA may share Personal Data with third parties in the context of the Services. DPKCA reserves the right to disclose or use aggregated or de-identified data for various purposes, including sharing it with partners or others for business or research purposes.

Sub-processing by Third Parties

DPKCA may engage third-party sub-processors to assist in processing Personal Data. The processing by these third-party sub-processors may involve data transfers, depending on their location. These sub-processors are required to process Personal Data in accordance with the Customer’s instructions outlined in the contract with DPKCA. Written agreements are in place between DPKCA and these sub-processors, meeting the necessary requirements. DPKCA maintains an up-to-date list of the names and locations of all third-party sub-processors, along with descriptions of their processing activities, which is available upon request.

Compliance with Laws

DPKCA may share or disclose data to comply with legal or regulatory requirements, respond to lawful requests, court orders, or legal processes.

Enforcing Our Rights, Preventing Fraud, and Safety

DPKCA may share or disclose data to protect and defend the rights, property, or safety of DPKCA or third parties, including enforcing contracts or policies and investigating and preventing fraud.

Changes to our Business Structure

DPKCA may share or disclose data in the context of various business transactions, such as mergers, acquisitions, bankruptcy, dissolution, reorganization, sale of assets, financing, acquisition of all or part of the business, or similar proceedings.

Location of Data

Service Data is hosted on DPKCA’s servers located in data centers in the United States. The default location is determined based on the Customer’s location and can be modified by the Customer after provisioning, subject to applicable fees.

Retention of Personal Data

DPKCA retains Personal Data as long as the Customer maintains an Account for our Services or as required to provide Services, comply with legal obligations, resolve disputes, and enforce agreements. If there is no ongoing legitimate business need for processing or retaining Personal Data, DPKCA will delete or anonymize the data. If deletion is not possible, such as when Personal Data is stored in backup archives, DPKCA will securely store and isolate it from further processing until deletion is feasible.

Data Subject Rights

DPKCA acts as a data Processor on behalf of Customers, who have primary responsibility for interacting with Data Subjects. DPKCA’s role is generally limited to assisting Customers as needed.

Access, Correction, Amendment, or Deletion Requests

DPKCA will notify the Customer if it receives a request from a Data Subject for access to, correction, amendment, or deletion of their Personal Data. DPKCA will not respond to such requests without the Customer’s prior written consent unless it’s to confirm that the request pertains to that Customer. DPKCA will cooperate with Customers and provide assistance in a reasonable timeframe regarding requests concerning Personal Data.

Regulatory Enquiries and Complaints

DPKCA will promptly notify the Customer if it receives an enquiry or complaint from a data protection authority naming the Customer. Upon the Customer’s request, DPKCA will cooperate and assist in any regulatory inquiry or complaint regarding DPKCA’s processing of Personal Data.

Legal Requests

In certain situations, DPKCA may be required to disclose Service Data in response to lawful requests by public authorities, subpoenas, court orders, or legal processes, or to establish legal rights or defend against legal claims. DPKCA may also share information with law enforcement agencies or public authorities when necessary for investigating, preventing, or responding to illegal activities, suspected fraud, potential threats to safety, violations of agreements, or as required by law.

Changes to this Statement

This statement may be revised from time to time, with any changes posted on this page. By continuing to use the Services after the changes take effect, you agree to the revised policy.

How to Contact DPKCA

Feel free to contact us if you have any questions about DPKCA’s privacy commitments or practices. You can reach us at [email protected].

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