Investment Café Privacy Policy

eFrontInvestment Café®Investment Café Privacy Policy

Privacy Policy

Only for the Website located at http://www.investmentcafe.com/

Last Updated: September 29, 2014

INVESTMENT CAFÉ PRIVACY POLICY

DMLT, LLC (“DMLT”, “We”, “Us”) an affiliate of eFront Financial Solutions, Inc. and wholly-owned subsidiary of eFront Luxembourg SA, recognizes that privacy is important and accordingly we maintain the following Privacy Policy to protect personal information that is provided to us by you online or otherwise via our CLIENTS. This Privacy Policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information.  If you have any questions about this Privacy Policy, please feel free to contact us at information@dmlt.com.

This privacy policy covers our processing, collection, use, and disclosure of information we collect through our website at http://www.investmentcafe.com/ , http://www.dmlt.com  and our Investment Café Services Platform (the “System”) via the domain http://secure.reportingsystem.com

DMLT,LLC  has received TRUSTe’s Privacy Seal signifying that this privacy policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal.

The TRUSTe program covers our collection, use and disclosure of information we collect through our website, www.investmentcafe.com, www.dmlt.com and our Platform. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged DMLT.

If you have questions or complaints regarding our privacy policy or practices, please contact us at information@dmlt.com. If you are not satisfied with our response or your complaint has not been resolved by us, we agree to participate in the dispute resolution procedures of TRUSTe. You can contact TRUSTe at http://feedback-form.truste.com/watchdog/request.

TRUSTe European Safe Harbor certification

EU and Swiss Safe Harbor

We self-certify
compliance with:

safeharbor logo

DMLT is committed to handling personal information within the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the processing, collection, use, and retention of personal information from European Union member countries and Switzerland. DMLT has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view DMLT’s certification, please visit http://www.export.gov/safeharbor/

PROCESSING AND USE BY THE SYSTEM via http://secure.reportingsystem.com

Collection and Use of Information

The use of information collected through the System shall be limited to providing hosting and ongoing administration for which CLIENTS have engaged us via separate service provider agreements.  The System processes information under the direction of our CLIENTS, and accordingly we have no direct relationship with the individuals whose personal data we process for our CLIENTS.  We work with our CLIENTS to help them provide notices to their customers concerning the purpose for which personal information is collected.
The System processes the following kinds of personal information provided by our CLIENTS:

  • Contact Information such as name, email address, mailing address, phone number
  • Information regarding profile, login and content viewing activities and access rights
  • Unique Identifiers such as user name, account number, password
  • Other personal information

CLIENTS use this information to:

  • Send you requested product or service information related to your account
  • Respond to customer service requests
  • Administer your account

DMLT also collects the following information from our CLIENTS:

  • Information about your business such as company name, company size, business type

Choice/Opt-Out

The System processes information for our CLIENTS. If you are an Authorized User of one of our CLIENTS and would no longer like to be contacted by that CLIENT, please contact that CLIENT directly. If you are a CLIENT and would like to update information within your account please feel free to email information@dmlt.com.

Service Provider, Sub-Processors/Onward Transfer and other Third Party Sharing

We may transfer personal information to third party companies that help us provide our services to CLIENTS. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our CLIENTS.

We use sub-processors in order to host our servers and allow CLIENTS to send communications through those servers. These sub-processors may not use any personal information for their own purposes.

We also reserve the right to disclose your personal information as required by law, and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or similar legal process, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Furthermore, we may share personal information with our affiliates solely to help us provide our services to CLIENTS. Our affiliates will treat such information in accordance with the provisions in this Policy.

Updates to Data Controlled by our CLIENTS

Because we have no direct relationship with our CLIENTS’ Authorized Users whose personal data is being processed by the System, an Authorized User who seeks access, correct, amend, or delete data should direct their query to the CLIENT. These activities can either be performed by the CLIENT, or the CLIENT can request assistance from us by emailing information@dmlt.com. We will respond to the CLIENT’S request within 30 business days.

Security

The security of your personal information as an Authorized User and our CLIENTS’ information is important to us. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). We have implemented a number of security features throughout the System to prevent the unauthorized release of or access to personal information.

Please be advised, however, that although we have endeavored to create a secure and reliable System for you, the confidentiality of any communication or material transmitted to or from the System via the Internet or e-mail cannot be guaranteed. When disclosing any personal information, you should remain mindful of the fact that it is potentially accessible to the public, and consequently, can be collected and used by others without your consent. We have no responsibility or liability for the security of information transmitted via the Internet. If you have any questions about security in our System, you can email us at information@dmlt.com.

Data Retention

The System will retain your personal data and the personal data that it processes on behalf of our CLIENTS for as long as our CLIENTS provide services to you, and as needed to provide services to our CLIENTS. In addition, we will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Sites

The System may contain links to other third party sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you when you leave the System to read the privacy policies of each and every website that collects personal information.
WEBSITE COLLECTION AND USE PRACTICES at http://www.investmentcafe.com/

Collection and Use of Information

When you visit our website, we will only collect your personal information (such as, but not limited to, your name, email address, or telephone number) if you provide it on the website willingly. We use this information to contact you for the information or services that you have requested.

From time-to-time, we may provide you with the opportunity to participate in surveys on our website. If you participate, we may request certain personal information from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes, but is not limited to, contact information (such as name and email address). We use this information to improve our website and services.

Communications from the Site

We will occasionally send you information on our products and services. Out of respect for your privacy, we present the option not to receive these types of communications. Please see the “Choice/Opt-Out” section listed below.

We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.

We post CLIENT testimonials on our website which may contain personal information. We obtain the CLIENT’S consent via email prior to posting the testimonial. If you wish to update or delete your testimonial, you can contact us at information@dmlt.com.

Choice/Opt-Out

We provide you with the opportunity to ‘opt-out’ of having your personal information used for certain purposes. For example, if you no longer wish to receive our promotional communications, you may opt-out of receiving them by following the instructions included in each promotional communication or by contacting us at information@dmlt.com.

Third Party Sharing

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.

We may provide your personal information to companies that provide services to help us with our business activities such as, but not limited to, a hosting provider and communications service provider. These companies are authorized to use your personal information only as necessary to provide these services to us.

We also reserve the right to disclose your personal information as required by law, and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or similar legal process, protect your safety or the safety of others, investigate fraud, or respond to a government request,
Furthermore, we may share personal information with our affiliates to help us communicate with you for the information or services that you have requested. Our affiliates will treat such information in accordance with the provisions in this Policy.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Tracking Technologies (Cookies, Beacons, etc.)

Technologies such as: cookies, beacons, tags and scripts are used by DMLT and our partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings, and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

We employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personal information.

We use clear gifs and unique URL strings in our HTML-based emails to let us know which webpages or emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Choice/Opt-Out” section of this policy.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

We use Local Storage Objects (LSOs) such as HTML5. Various browsers may offer their own management tools for removing HTML5 LSOs.

The use of tracking technologies by our tracking utility company is not covered by our privacy policy. We do not have access or control over these tracking technologies.

At any time, while accessing our site, any user, while online, may decline participation in any activity that asks for information (i.e., survey email). Your choice not to participate will in no way affect your ability to use any other feature on our site.

Security

The security of your personal information is important to us.

Please be advised, however, that although we have endeavored to create a secure and reliable public website for you, the confidentiality of any communication or material transmitted to or from the public website via the Internet or e-mail cannot be guaranteed. When disclosing any personal information, you should remain mindful of the fact that it is potentially accessible to the public, and consequently, can be collected and used by others without your consent. We have no responsibility or liability for the security of information transmitted via the Internet. If you have any questions about security in our website, you can email us at information@dmlt.com.

Data Retention

We will retain your personal data and the personal data that you provided to us via this website for as long as needed to communicate with you. In addition, we will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Sites

This website may contain links to other third party sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you when you leave our site to read the privacy policies of each and every website that collects personal information.

Updates to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire interact our website, you may correct, update, or delete the information by emailing us at information@dmlt.com. We will respond to your request within 30 business days.

Social Media Widgets

Our website includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button of interactive mini-programs that run on our website. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy policy of the company providing it.

CONCLUSION

Your Consent and Changes to this Policy

By using our website and the System, you consent to the processing, collection, use, and disclosure of this information by us in accordance with this Privacy Policy. We may update this policy from time to time. If we make any material changes we will notify you by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date, prior to the changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information
Investment Café by eFront
DMLT, LLC
11 East 44th Street, 15th Floor
New York, NY 10017
information@dmlt.com