DFND ANALYTICS, LLC

PRIVACY POLICY

DFND Analytics, LLC (“DFND”) is a Delaware limited liability company.

Privacy and data security are important to us. We have developed this Privacy Policy (the “Policy”) to inform you how DFND will collect, process, and/or use the information you submit and/or we collect from you (“Personal Information”). This Policy governs your use of the website [www.dfnd.net] (the “Website”) and associated websites, applications, data, documentation and software with the DFND (the “Service”), and applies when you submit, or we collect from you, Personal Information, including via the Internet, telephone, email, mail, or facsimile.

This Policy is governed by United States law. Please read it carefully.

YOUR CONSENT
By visiting the Website, accessing the Service, submitting Personal Information, or otherwise interacting with DFND, you agree to the terms of this Policy and you expressly consent to the processing of your personal information according to this Policy. We suggest you review this Privacy Policy periodically, as it may be updated from time to time.

The Service is directed to persons in the United States, and this Policy applies only to activities in the United States. If you are visiting the Website, accessing the Service, submitting Personal Information, or otherwise interacting with DFND from outside the United States, you explicitly accept that your information may be transferred to, stored, and processed in the United States where laws regarding processing of personal information may differ than the laws in your country.

COLLECTION OF PERSONAL INFORMATION
Information You Give Us. DFND may collect any information that you provide to DFND when you visit the Website, access the Service, or submit Personal Information, including the following:

  • Any information that you provide by filling in forms or registering. This includes information you provide at the time of registering to use the Website or using the Service, including but is not limited to first and last names, address, billing contact information, website URL, email address, phone number, fax number, title, organization name, accounting package name and CRM software information, industry, and contract details.
  • Credit card or other payment information.
  • Customer and vendor lists.
  • Accounting information including G/L entries and sales and purchasing transactions.
  • A record of correspondence with you if you contact us.

We use the information collected to deliver and improve services, process payments, update our records, communicate with you about products, updates and services, personalize and improve your experience, and generally maintain your accounts with us.

Responsibility for Content Provided. Once registered with the Service, you can send documents to the Service, which may include personal information about your customers (“Customer Information”). You are responsible for the content of the information you provide to us and you must ensure it is legal, honest, truthful, accurate and not misleading in any way; does not contain material that is obscene, blasphemous, or defamatory; does not infringe on any rights of any third party (including, without limitation, rights of confidentiality); or is not otherwise legally actionable by such third party. By uploading Customer Information, you represent that you are authorized to provide Customer Information to DFND, and that such information has been obtained by you in accordance with all applicable laws.

No Obligation. Your submission of Personal Information or Customer Information is entirely voluntary. If you choose not to submit Personal Information, this may limit your ability to use the Service. Submission of Personal Information or Customer Information does not establish any obligation not listed in this Policy.

Automatic Information Collection. Each time you visit the Website or use the Service, we may automatically collect certain types of information, which includes the following:

  • SESSION RECORDS. To maintain our quality of service and to assist in the analysis of product performance, we may gather data on connection information, including the timing and size of all packets sent over the Internet during a session. The gathered information is used to provide the highest quality experience possible when using the Website and Service.
  • SECURITY INFORMATION. We collect certain information about your device for security and identification purposes. This information may include: internet service provider (“ISP”) address; internet protocol (“IP”) addresses, domain names, access times, browser type and browser version, cookies, visitor traffic patterns and site usage, and unique identifying information of devices that access the Service. This information is used for the operation of the service, to identify and protect our customers and to control unauthorized use or abuse of our services. All information is encrypted during transmission.
  • COOKIES. We use “cookies” and other tracking technologies. A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer’s hard drive. The use of cookies helps us understand how the Website and Service are being used. We use cookies to help us improve security, content, navigation, and functionality. When you use the Website, we make use cookies to store unique, randomly assigned user IDs that we generate for administrative purposes. We may use “session cookies” to enable certain features of Service, track user traffic patterns, monitor aggreate usage and enhance the overall user experience. Session cookies usually expire and are deleted when you close your web browser. Credit card information is not stored in cookies. DFND also uses cookies on the websites on which DFND advertises and through email to track advertising performance and to collect aggregate data on sites and/or through email viewing. DFND may also use a third-party provider to track or collect this information. DFND does not use cookies that contain or capture unencrypted Personal Information. DFND may also use web beacons, match scripts, pixel tags, or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, links in the email utilized, or if the advertisements are effective. In some instances, these technologies may allow us to match activities with particular users. By visiting the Website or using the Service, you consent to the use of the cookies and other tracking technology described in this section of the Policy.
  • ANALYTICS. We continuously improve the Website and the Service, and we utilize different third party analytical tools to help us do so. We are interested in how visitors use our Website and Service, what they like and dislike, and where they have problems.
  • Our Website and Service use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific DFND usage tips and guidance. To increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties. Our mobile applications use analytical tools to help gather non-personally identifiable data about download and application usage. In our use of mobile applications we may utilize device identification data, but only if you specifically opt-in to collection of such data in connection with a particular service. We may use information such as IP addresses to determine the general geographic areas of our visitors, but this information is not correlated to personal information about individual users. These tools may gather data such as what browser a person uses, what operating systems are used, what is downloaded, and what content, products and services are reviewed when visiting or registering for services on our Website or Service. This information is used solely to assist DFND in maintaining a more effective and useful Site for our customers
  • DFND, or our third-party service providers acting on our behalf, collect and track information including aggregate traffic patterns, domain names, browser types, MIME types and web pages visited before coming to our Website and Service. To increase functionality and enhance your user experience, this information these third-parties may use cookies or other tracking technologies may sometimes be correlated with personal information about individual users.

Various browsers have different ways to let you delete cookies or limit the kinds of cookies that can be placed on your device. See http://www.usa.gov/optoutinstructions.shtml for more information on how to change cookies settings in popular desktop browsers. You may reject cookies, although if you do so, you may not be able to use some of the features of the Website or Service. You can still visit the Website if you choose to set your browser to refuse all cookies; however, session cookies must be enabled to establish an account and to access the Service.You may also avoid email tracking by not allowing “HTML” messages and choosing to view email messages only in a text format.

Interest-based Advertising. Neither the Website nor the Service serve third party advertisements. DFND partners with selected marketing companies and affiliates to help us track the effectiveness of the Website and the Service, generate visitor traffic and manage our advertising on other sites. When a third party refers a visitor to us from any other site, they set a web beacon and a cookie on our Website. An ad ID and a partner ID are stored in the cookie, but no personal information specific to the actual visitor is stored. DFND does not see the cookie. We only include the web beacon on our page, which results in a request to the partner’s servers from the customer’s browser. We have no control over their use of tracking technologies after they are placed on our Site. These third parties may use this information to deliver targeted advertising to you on other websites you visit. If you would like more information about these practices and to know your choices about not having this information used by these companies, please click http://www.aboutads.info/consumers/. To learn more and opt out of seeing interest-based ads on those websites, please click here: http://www.networkadvertising.org/managing/opt_out.asp: Please note this does not opt you out of being served all advertising. You may continue to receive generic ads.
Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (“W3C”) has not yet established universal standards for recognizable DNT signals and therefore, DFND, the Website, and the Service do not recognize DNT.
In-App Purchases. Neither the Website or the Service collects payment information for in-app purchases.

USE OF PERSONAL INFORMATION
DFND uses Personal Information in the following ways:

  • To create your account.
  • To provide the Service.
  • To enhance your customer relationship and improve our customer service.
  • To charge you for the Service.
  • To respond to your requests.
  • To conduct our normal business operations.
  • To improve functionality and security of the Service.
  • To communicate with you about things like order confirmations and customer service.
  • To send newsletters or other messages about our products or services or those of our partners. You can opt out of promotional emails at any time, but will still receive communications such as receipts, confirmation emails and customer service updates that are considered necessary to provide the Service to you.
  • To meet our legal or regulatory obligations, including enforcement of our Terms of Service.
  • For legal defense as necessary.
  • To ensure that content from the Website and Service is presented in the most effective manner for you.
  • To allow you to participate in interactive features of the Website or Service, when you choose to do so.
  • To notify you about changes to the Website or Service.

REVIEWING, CORRECTING, UPDATING AND/OR DELETING INFORMATION ABOUT YOU
If you would like to have your Personal Information deleted from our system, contact us at www.dfnd.net. Note that we may retain certain information if: (a) removal is technically not possible; (b) retention is required by law; or (c) the information is required for legitimate business purposes. If we remove your information, you will lose access to certain parts of the Website and Service.

If you wish to cancel your account or request that we no longer use your information to provide you services or communicate with you, contact us at www.dfnd.net

If you no longer wish to receive promotional/marketing communications, you may opt-out of receiving promotional/marketing emails by following the unsubscribe instructions in the email that you receive from DFND. Please note that even if you opt-out of promotional/marketing emails, we may still send you emails in accordance with applicable law.

DISCLOSURE AND/OR SHARING OF PERSONAL INFORMATION
Your privacy is important to us. We do not sell or otherwise disclose Personal Information we obtain through the Website to third parties, except as follows or as otherwise described in this Policy.

  • With employees and consultants of DFND and/or its subsidiaries or affiliates.
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including without limitation: authorization of credit card and/or payment transactions; website hosting or information technology consulting services; website management; data analysis; legal services; shipping companies; and other administrative and back-up and security services, who may, in turn, share Personal Information with their subcontractors. These vendors, consultants, and service providers are granted access to Personal Information and Customer Information as necessary and may use cookies (as defined above) or other automatic collection technology on our behalf. These vendors, consultants and service providers are not authorized by us to use or disclose Personal Information or Customer Information except as needed to perform their functions or comply with legal requirements, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Policy.
  • In response to a request for information if disclosure is required in accordance with any applicable law, regulation or legal process, or is otherwise required or permitted by any applicable law, rule or regulation.
  • To comply with any legal obligation.
  • To protect the rights, property or safety of DFND and others.
  • In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
  • With others with your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Links To Third-Party Sites. The Website or Service may contain links to third-party sites or services that are not owned by DFND. The information practices of the third party apply to those sites and to any information you submit while on those site. DFND is not responsible for the information policies or practices of those third parties, and we encourage you to read their privacy respective policies.

STORAGE OF INFORMATION
DFND is based in the United States. Regardless of where you access or use the Service, Personal Information and Customer Information is processed and stored in the United States. Personal Information and Customer Information will be handled and retained in accordance with United States privacy laws, regulations, and standards, and any contracts between you and DFND.

Customer Information is stored via Citrix ShareFile and Microsoft Azure. Citrix ShareFile’s Privacy Policy can be accessed here: https://www.sharefile.com/privacy. Citrix ShareFile’s Terms of Use can be accessed here: https://www.sharefile.com/terms.   Microsoft Azure’s Privacy Policy may be accessed here: https://azure.microsoft.com/en-us/support/legal/  Microsoft Azure’s Terms of Use can be accessed here: https://azure.microsoft.com/en-us/support/legal/website-terms-of-use/

Personal Information is also maintained on servers that are owned by DFND employees or managers. These servers are located in New Jersey and New York. DFND employees and managers are contractually restricted in the ways they may access or use Personal Information.

We will retain Personal Information and Customer Information for as long as your account is active, as needed to provide you services, to communicate with you about services and products, to comply with our legal obligations, resolve disputes, and/or enforce our agreements.

SECURITY OF INFORMATION
DFND uses reasonable physical, administrative and technical controls to protect Personal Information and Customer Information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. When you enter Personal Information or upload Customer Information, we encrypt the transmission of that information using secure socket layer technology (SSL). Passwords, device identification information, Personal Information and Customer Information are also encrypted during storage.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information and Customer Information, we cannot guarantee the security of your data transmitted to the Website or Service. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access, but DFND cannot be and is not responsible for unauthorized access to information by hackers or others who have obtained such access through illegal measures.

Where you have been given, or have chosen, a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You can help keep your information secure by using a strong username and password, and not sharing them with anyone. If you believe your account has been compromised or you would like to report a security concern, please contact us.

CHILDREN’S INFORMATION
Although our Service is for general audiences, the use of our Service is only for individuals age 18 and above. We do not use the Service to knowingly solicit data from or market to children under the age of 18. If you become aware that a child has provided us with information without their consent, you should contact us. DFND will take all reasonable measures to delete such information from its databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you are under the age of 18, you should use the Service only with the involvement of a parent or guardian and should not submit any personal information to us at all.

NO RIGHTS OF THIRD PARTIES
This Policy does not create rights enforceable by third parties or require disclosure of any information relating to visitors to the Website or users of the Service.

TERMS OF USE
If you choose to visit the Website or use the Service, your visit and any dispute over privacy is subject to this Policy and our Terms of Use Agreement, including limitations on damages and application of the law of the State of New York. If you have a concern about privacy at the Website or Service, contact us with a detailed description of your concern.

CHANGES TO OUR POLICY
DFND may change this Policy from time to time. All changes to this Policy are effective after they are initially posted on the site. Each version of the Policy is identified at the top of the page by its effective date. If we believe the changes are material, we will: (1) post a notice on our website 30 days before the change takes effect, and (2) make reasonable efforts to email registered users notice 30 day before the change takes effect.

Your continued use of the Website or Service, after changes have been posted, constitutes your acceptance of the Policy as amended. If you do not agree to the changes, please contact us to deactivate your account.

CONTACT
Please feel free to ask us questions about this Policy. Questions and requests related to your personal information may be directed to the following postal address: DFND Analytics, LLC, One Penn Plaza, Suite 6281, New York, NY 10119.

Last Updated: February 20, 2016