DTI Services, Inc. Privacy Notice for California Residents
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data or other qualifying research data;
- Personal Information and Sensitive Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Directly from you. For example, from forms you complete or products and services you purchase.
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information and Sensitive Personal Information to respond to your inquiry. If you provide your Personal Information and Sensitive Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information and Sensitive Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of DTI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information and Sensitive Personal Information held by DTI about our Website users is among the assets transferred.
- The categories of Personal Information and Sensitive Personal Information we collected about you.
- The categories of sources for the Personal Information and Sensitive Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information and Sensitive Personal Information.
- The categories of third parties with whom we share that Personal Information and Sensitive Personal Information.
- If we sold or disclosed your Personal Information and Sensitive Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information and Sensitive Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information and Sensitive Personal Information categories that each category of recipient obtained.
- The specific pieces of Personal Information and Sensitive Personal Information we collected about you (also called a data portability request).
- Complete the transaction for which we collected the Personal Information and Sensitive Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Calling us at 1-800-925-2573; or
- Emailing us at https://service.allbrightinformation.com/contact/inquiry/
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:
Identifying recently purchased items and the dollar amounts of recent purchases.
The dollar amounts of recent purchases.
You are able to provide information only you are likely to know.
Proof that you gave the agent signed permission to submit the request.
You directly confirm that you provided the authorized agent permission to submit the request. - Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
This Privacy Notice for California Residents (“Supplement”) supplements the information contained in the privacy policy of DTI Services, Inc.’s (“DTI”, “we” or “our”) d2pass.com website (“Website”). You can access the privacy policy at D2Pass Privacy Policy. This Supplement applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this Supplement to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. We prohibit people under the age of 18 from accessing the Website or from otherwise visiting, using or becoming consumers of the Website.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device and these types of information are classified in the charts below as Personal Information and Sensitive Personal Information. In particular, the charts below state whether the Website has collected information that falls within the following categories of Personal Information and Sensitive Personal Information from its consumers within the last twelve (12) months. (Where we state “YES” that information in a category has been collected does not mean that every piece of information described in the Examples has been collected. They are only examples.)
Personal Information
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. |
YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. |
YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. |
NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. |
NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. |
YES |
| G. Geolocation data. | Physical location or movements. Some Personal Information included in this category may overlap with other categories of Personal Information or categories of Sensitive Personal Information. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment- related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Sensitive Personal Information
| Category | Examples | Collected |
|---|---|---|
| A. Government Identifiers. | Government identifiers, such as your Social Security number, driver's license, state identification card, or passport number. Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
YES |
| B. Complete account access credentials | Access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password. Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
YES |
| C. Precise Geolocation | Precise physical location within a small area (1,850 feet radius). Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
NO |
| D. Racial | Race or ethnic origin information. Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
NO |
| E. Citizenship | Citizenship or immigration information. Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
NO |
| F. Religion | Religious or philosophical beliefs information. | NO |
| G. Union | Union membership information. | NO |
| H. Mail | Mail, email, or text messages contents not directed to us. | NO |
| I. Genetic | Genetic data. | NO |
| J. Neural data (Beginning January 1, 2025) | Information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information. | NO |
| K. Biometric | Unique biometric information used for identification. Some Sensitive Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
NO |
| L. Health | Health information | NO |
| M. Sexual | Sex life, or sexual orientation information Some Personal Information included in this category may overlap with other categories of Sensitive Personal Information or categories of Personal Information. |
NO |
Personal information and Sensitive Personal Information does not include:
DTI obtains the categories of Personal Information and Sensitive Personal Information listed above from the following categories of sources:
Use of Personal Information and Sensitive Personal Information
We may use or disclose the Personal Information and Sensitive Personal Information we collect for one or more of the following purposes:
DTI will not collect additional categories of Personal Information and Sensitive Personal Information or use the Personal Information and Sensitive Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information and Sensitive Personal Information
We may share your Personal Information and Sensitive Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information and Sensitive Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, DTI has disclosed Personal Information and Sensitive Personal Information for a business purpose to the categories of third parties indicated in the charts below. We do not sell Personal Information or Sensitive Personal Information.
Personal Information
| Personal Information Category | Category of Third-Party Recipients | |
|---|---|---|
| Business Purpose Disclosures | Sales | |
| A: Identifiers. | Service Providers, Parent or subsidiary organizations | None |
| B: California Customer Records personal information categories. | Service Providers, Parent or subsidiary organizations | None |
| C: Protected classification characteristics under California or federal law. | None | None |
| D: Commercial information. | Service Providers, Parent or subsidiary organizations | None |
| E: Biometric information. | None | None |
| F: Internet or other similar network activity. | Service Providers, Parent or subsidiary organizations | None |
| G: Geolocation data. | None | None |
| H: Sensory data. | None | None |
| I: Professional or employment-related information. | None | None |
| J: Non-public education information. | None | None |
| K: Inferences drawn from other personal information. | Service Providers, Parent or Subsidiary Organizations | None |
Sensitive Personal Information
| Sensitive Personal Information Category | Category of Third-Party Recipients | |
|---|---|---|
| Business Purpose Disclosures | Sales | |
| A: Identifiers. | Service Providers, Parent or subsidiary organizations | None |
| B: Complete account access credentials | Service Providers, Parent or subsidiary organizations | None |
| C: Geolocation | None | None |
| D: Racial | None | None |
| E: Citizenship | None | None |
| F: Religion | None | None |
| G: Union | None | None |
| H: Mail | None | None |
| I: Genetic | None | None |
| J: Neural data (Beginning January 1, 2025) | None | None |
| K: Biometric | None | None |
| L: Health | None | None |
| M: Sexual | None | None |
Sales of Personal Information and Sensitive Personal Information
We do not sell Personal Information and Sensitive Personal Information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information and Sensitive Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information and Sensitive Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity we will disclose to you:
Right to Delete
You have the right to request that we delete any of your Personal Information and Sensitive Personal Information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers and parent or subsidiary organizations to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with Personal Information and Sensitive Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information and Sensitive Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information and Sensitive Personal Information provided in the request to verify the requestor's identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at either:
Phone: 1-800-925-2573; orWebsite: https://service.allbrightinformation.com/contact/inquiry/
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information and Sensitive Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information and Sensitive Personal Information Sales Opt-Out and Opt-In Rights
We do not sell Personal Information and Sensitive Personal Information.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s and Sensitive Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice
We reserve the right to amend this Supplement at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about thisSupplement, the ways in which we collect and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at either:
Phone: 1-800-925-2573; or
Website: https://service.allbrightinformation.com/contact/inquiry/
If you need to access this Supplement in an alternative format due to having a disability contact us at either:
Phone: 1-800-925-2573; or
Website: https://service.allbrightinformation.com/contact/inquiry/