Privacy Policy

Last Updated: January 2019

This Privacy Policy

This privacy policy (“Privacy Policy”) explains how DAL Capital, Inc. and its subsidiaries and affiliates (collectively referred to as “DAL,” “us,” “our,” or “we”) collect, use, and share your Personal Information (as defined herein). This Privacy Policy applies to all websites and applications (“Website”) that link to this Privacy Policy.

We may revise and update this Privacy Policy from time to time and will post the updated Privacy Policy to the Website.

Privacy Statement

Information posted on this website may be accessible to third parties, by means of the internet or otherwise. You acknowledge that communications transmitted to or through this website are public and not private communications, and you confirm that you have no expectation of privacy with respect to any such communications. By visiting the Website, you are accepting the practices described in this statement. If you do not agree to this Policy, please refrain from using the website.

We may collect information about visitors to this website through technologies such as cookies, pixel tags, and web beacons. Such information may include usage details, IP addresses, features used, pages visited on this website, the domain name of the site from which visitors connect to our site, and other website visitor data, and may be collected automatically as you navigate through this website.

We may collect information that you voluntarily provide on or through this website. If you choose to take advantage of some of the website’s features, you may be asked to provide certain personal information. Such information may personally identify you. For example, you may provide us with your name, email address, telephone number, and company when you submit a form from our "Contact" page. Your personal information may be stored and processed in any country where DAL has facilities or in which DAL engages service providers. You hereby consent to the transfer of that information to countries outside the country of your residence. You can change, update, correct, or delete your personal information by sending us an email at info@dalcapital.com.

We may use the information collected on this website in several ways such as: (1) to estimate audience size and usage patterns; (2) to store information about your preferences, allowing us to customize our website; (3) to manage, develop, analyze, or improve this website; (4) to conduct research and analysis; and (5) for other business purposes.

We may disclose aggregate information about users without restriction. We may disclose personal information that we collect or you provide to: (1) our subsidiaries and affiliates; (2) contractors, service providers, and other business partners; (3) to a buyer or other successor in interest; (4) other third parties with your consent; and (5) third parties as permitted or required by law.

DAL will not collect or maintain Personal Data that is not relevant to or required for the conduct of DAL business and will take reasonable steps to assure that Personal Data remains accurate.

Personal Data will be treated as confidential and internal procedures and controls will be employed to prevent unauthorized access, disclosure, use, copying, modification, or destruction. Personal Data maintained by DAL will not be used for purposes that are incompatible with the purposes for which it was collected. Personal Data will not be transferred to third parties, except as required for the conduct of DAL business, and only to third parties who have agreed in writing to protect such Personal Data.

Consent

By accessing and using the Website, you consent to us using your Personal Information (as defined herein) in a manner consistent with this Privacy Policy. This Privacy Policy does not cover Personal Information collected or held by us about our employees. If you do not wish for us to collect or process your Personal Information in the manner described in this Privacy Policy, then you should not access or use the Website and the services therein. Per our Terms of Use, all account owners are required to be at least 18 years of age. By using the Website, you authorize us to use your information, including Personal Information, in the United States and any other country where we operate. Please be aware that privacy laws and standards may differ from country to country, and may differ from those that apply in your home country. We will transfer Personal Information only to countries to which we are permitted to by relevant law, and will endeavor to ensure that your Personal Information enjoys appropriate protections.

Personally Identifiable Information

We may collect and transmit personally identifiable information that you provide to us through the Website. Personally identifiable information (“Personal Information”) is information that can be used to identify or contact a single person, such as: (1) Name; (2) User name; (3) Address; (4) Telephone Number; (5) Email Address; (6) Payment Information (i.e. credit or debit card); (7) Country of Residence; (8) Demographic Data (i.e. age and profession).

We only collect Personal Information to the extent that it is reasonably necessary for one or more of our functions or activities. We do not consider Personal Information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

Information Collected Automatically

We may automatically collect certain information when you use the Website, including information about your computer or device, hardware, software, connection information, Internet Service Provider (“ISP”), browser type and language, operating system, Internet Protocol (“IP”) address (which is a numeric address assigned to your computer by your ISP), browsing history on the Website, click stream data, HTTP protocol elements, information about your interactions with email messages (such as the links clicked on and whether the messages were opened or forwarded), and standard server log information. The Website may use cookies, which are small text files that a website places on your hard drive, and similar tools, such as log files and web beacons, to automatically collect this information. These tools record data about your visit so that when you return to the Website, the Website recognizes your computer and can personalize your visit.

You may adjust your web browser software if you do not wish to receive cookies or web beacons, but this may prevent you from taking advantage of some of the Website’s features. Please refer to your browser or email software instructions or help screen to learn more about these functions.

Use and Disclosure of Information

We will only use and disclose Personal Information for the purposes for which the information was collected or, in some circumstances, for a reasonably related secondary purpose. These purposes include, but are not limited to: (1)Carrying out our commercial functions and activities; (2) Investigating, resolving and reporting any incidents; (3) Responding to inquiries or questions that you may submit; (4) Improving the services that we offer; (5) Maintaining the Website (including disclosure to outsourced and cloud service providers); (6) Preventing fraud; (7) Offering site content to you that includes items and services that you may like; (8)Providing access to your purchase history and other features; (9) Providing other services requested by you as described when we collect the information; (10) Providing you with location based services (such as advertising, search results, and other personalized content); (11) Personalizing our advertising and marketing communications; (12) Personalizing, measuring, and improving our advertising based on your advertising customization preferences; (13) Enforcing our policies; or (14) For any purpose with your consent (or if we are permitted or required to do so by law).

We may disclose your Personal Information to others, including to: (1) Third party service providers and vendors we use in connection with our business, including our property managers; (2) Third parties without your consent under certain circumstances, such as third parties to whom we are required to disclose personal information under law; in order to exercise our legal rights or defend against legal claims; to comply with a subpoena, court order, legal process or other legal requirement; or when we believe in good faith that such disclosure is necessary to prevent imminent physical harm or financial loss; (3) Any third party who claims that any content posted or uploaded by you to the Website constitutes a violation of their intellectual property rights or their right to privacy; or (4) Any third party with your consent.

We may, at a future time, use Personal Information for new, unanticipated uses not previously disclosed in our Privacy Policy.

We may combine and enhance the Personal Information with information we receive from third parties as long as we use the combined information as described in this Privacy Policy.

We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide services to you. Unless we tell you differently, they do not have any right to use Personal Information beyond what is necessary to assist us.

We may use and share non-personal, de-identified information (i.e. information that cannot be used to identify you) for any lawful business purpose without any obligation or accounting to you. For example, we may use non-personal information for developing products, services, and providing those offerings to other users and third parties. We may use your personal information to generate non-personal information (e.g., by statistically aggregating your personal information with the information of others). When we do so, we will take reasonable measures to ensure that the non-personal information is no longer personally identifiable and cannot later be used to identify you. We may also disclose non-personal, aggregate, anonymous data in a de-identified format to investors and potential partners based on information collected from users.

We do not share Personal Information with third parties for those third parties’ own direct marketing purposes.

Information Modification and Retention

You may access, correct, update, and/or delete certain information that you affirmatively submitted to the Website. You may also unsubscribe from mailing lists or any registrations on the Website. To do so, please contact us at the address provided at the bottom of this Privacy Policy.

Please note that in certain circumstances, we may not be able to completely remove a user’s information from our systems. For example, we may retain a Personal Information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law or as retained in our data backup systems or cached or archived pages. All retained Personal Information will continue to be subject to the terms of the Privacy Policy to which the user has previously agreed.

We will retain your Personal Information as long as it is necessary and relevant for the operation of our Website. In addition, we may retain Personal Information from closed accounts if needed. After we believe that is no longer necessary for us to retain your Personal Information, we will dispose of it in a secure manner according to our policies.

Third-Party Websites

The Website may include or provide links to third-party websites and services as a service to our users. We do not control these websites or services. If you use these links, you will leave this Website. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by DAL of the third party, the third party website or service, or the information contained therein, and we are not responsible or liable for your use of these third-party websites or services, which is subject to the terms of use, privacy policies, and data collection policy and procedures applicable to those sites.

Security

We have implemented reasonable security procedures to help protect information collected through the Website from loss, misuse, alteration, or destruction. However, despite these precautions, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

We are not responsible for the circumvention of any privacy settings or security measures relating to the Website by any users or third parties. While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Website, we cannot guarantee that these efforts will always be successful. Your information may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to or from us. We cannot and do not guarantee the total privacy or security of any information you transmit through the Website.

Disclosure of Your Information Through Business Transfers

We may buy, merge, or partner with other companies or businesses and in so doing, acquire or transfer information. Personal Information collected through the Website may be among the transferred business assets. In the event that a portion or substantially all of our assets are sold or transferred to a third party, Personal Information would likely be a transferred business asset, and you hereby agree to such a transfer.

International Users and Storage

DAL may process information on our servers in the United States, and may work with third parties who may have servers in countries around the world. As a result, your Personal Information may be processed or stored on a server located outside the country where you live, and your information may be accessed by foreign governmental authorities and otherwise in accordance with applicable laws. By using the Website you consent to such storage, processing, and transferring. This Privacy Policy is intended to meet the laws and requirements of the United States, which may not be the same as the laws and regulations of your home country.

Children’s Privacy

DAL understands the importance of protecting children’s privacy, especially in an online environment. The Website is not designed for or directed at children, including without limitation those children 13 years of age or younger. Any information we receive from users we believe to be under the age of 13 will be purged from our database.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Last Updated” date above. We recommend that you review the Privacy Policy each time you use the Website to help you stay informed of our privacy practices. If these changes are material (i.e., changes we believe you will find important), we will provide notice to you by email or by posting notice of the changes on our affected Websites. Where required by applicable law, we will obtain your consent. Unless otherwise indicated, any changes to this privacy policy will apply immediately upon posting to the website.

Privacy Policy Questions

If you have any questions about our Privacy Policy or if you require any assistance in navigating or reading the materials on this Website, please contact us using the “Contact” function on the Website.