Privacy Policy

Your privacy is very important to us. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

INFORMATION COLLECTED FROM ALL VISITORS

Like most standard websites, we use log files or “cookies” to collect certain information from users of the website. This may include, without limitation, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We and our service providers use this information for security purposes, to analyze trends, administer the site, track user movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to other personally identifiable information. Please see our Cookie Notice [provide link] for further information regarding our use of cookies.

Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes.  The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or device to delete and disable cookies and other tracking/recording tools.  Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

INFORMATION COLLECTED FROM ALL USERS WHO REGISTER ON THIS WEBSITE

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
  • We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • We will only retain personal information as long as necessary for the fulfillment of those purposes.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by using security safeguards designed to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information.
  • Upon your request, we will be happy to provide you with a summary of the information we collect about you. You will have the opportunity to correct, update or modify any of this information.

Sharing of Personal Information

We may provide your information to our affiliates or to service providers for purposes related to website administration (such as website hosting and moderating), mobile application hosting, data analysis, infrastructure provision, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services.

We may use and disclose personal information collected through this website as we believe to be necessary or appropriate: (a) as required by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce contractual terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Please note that we may share your information with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We may also use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Your California Privacy Rights

Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining products or website for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.  Please note that we do not, and do not intend to, share your information for such direct marketing uses.

International Users

We are a United States company and we follow the laws of the United States regarding the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories.   While this privacy policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to us (“Local Laws”) may require standards which are stricter than this privacy policy and, in such event, we will comply with applicable Local Laws.  Your personal information may be stored and processed in any country where we or our service providers have facilities. In all circumstances we will, as required by applicable law, ensure that your privacy rights are protected by organizational, technical, contractual and/or other lawful means.

EU Data Subjects

In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you.  The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to our use or disclosure of your Personal Data will mean that you cannot take advantage of certain products or services.

We may transfer your Personal Data outside EU to the United States or any country that we or our service providers may have operations. Such countries do not have the same data protection laws as EU. Any transfer of your personal information will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

Under the General Data Protection Regulation you may have a number of important rights free of charge. In summary, those may include rights to:

  • Fair processing of information and transparency over how we use your use personal information
  • Access to your personal information and to certain other supplementary information that this privacy policy is already designed to address
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure of personal information concerning you in certain situations
  • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • Object at any time to processing of personal information concerning you for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • Object in certain other situations to our continued processing of your personal information
  • Otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation (or other relevant guidance).

If you would like to exercise any of those rights, please email, call, or write to us with the following:

  • Enough information to identify you
  • Proof of your identity and address
  • The information to which your request relates

How to Complai

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in EU state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Otherwise, a complaint may be submitted directly to us:

  • By email at jbrown@dix-eaton.com; or
  • By mail at

Dix & Eaton, Attention: Jim Brown

200 Public Square, Suite 3900

Cleveland, Ohio 44114-2322

Compliance

We will use a self-assessment approach to verify compliance with this privacy policy and periodically verify that the privacy policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal information has been processed or disclosed in violation of this privacy policy, we encourage you to raise any concerns using the contact information provided in this privacy policy.  We will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

Minors

We do not intentionally collect information from individuals under the age of 13.  The website is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this website.

Modification to This Policy

We reserve the right to modify this policy, but in the event we do so we will maintain complete transparency — any changes to the policy will be promptly posted here, so be sure to check back for future information.

Contact Us

If you have any questions about this policy or our website in general, please contact jbrown@dix-eaton.com.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.