DIRECT SOURCE WEALTH

PRIVACY POLICY

Last updated: June 22, 2018

Thank you for using directsourcewealth.com.  Direct Source Wealth, Inc. (“DSW”) collects information you provide when you create an account or use the Services.  This Privacy Policy explains how DSW collects, uses, and shares your personal information, and the choices that are available to you.  Our Privacy Policy applies to all who use our Website, the Services, and any online services, applications, and tools that we own or control (regardless of how you access or use them).  This Privacy Policy is incorporated in our Terms of Use [link], which also apply when you use our Services.  Capitalized terms used in this Privacy Policy that are not defined herein shall bear the meanings set forth in the Terms of Use.

Your use of the Services is subject to this Privacy Policy.  Please read this Privacy Policy carefully.  We may change this Privacy Policy at any time.  Please look at the “Last updated” legend at the top of this page to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website.

  1. How We Collect Your Information.

When you visit the Website and use the Services, we may collect certain information about you, including personal information.  “Personal Information” means information that specifically identifies you or, when combined with other information we have, can be used to identify you, such as your name, email address, physical address, phone numbers, age, gender, financial information, and payment information.  DSW does not collect any Personal Information from you through the Services unless you voluntarily choose to provide us with such information.  In some cases, if you choose not to provide us with the requested Personal Information, you may not be able to use some or all of our Services.

[We may automatically collect certain information about you and store it in our log files when you use and interact with our Services, such as data collected from cookies and other automated technology.  This information may include details about the emails we send that you open, forward, or click through to our Services, Internet Protocol (IP) address, Internet Service Provider (ISP), date and time stamps, sites visited before and after interacting with our Services, page views, page navigation, links that are clicked, ad blocker status, and certain device data (such as operating system type, device type or model, location, browser type and version, user language, and other system settings).  Cookies help us track and understand how people use and interact with our Website and the Services.  Your access to our Services should not be affected if you do not accept cookies served by third parties.]

DSW collects Personal Information about you through the Services when you (i) register or log in to your DSW account, (ii) submit information through the Services, (iii) open or respond to our email offers, (iv) contact customer service or otherwise made use of the customer support tools, or (v) when you otherwise voluntarily provide us with your Personal Information.

When you purchase any services, including Conferences, we may ask you to provide certain financial information that is needed in order to complete your order.  All payments are processed through a third party payment processor, such as PayPal.  We neither have access to nor store any payment information; all payment information is stored by our trusted third party payment processors.

  1. How We Use Your Information.

We use the Personal Information we collect for various purposes, including to: (i) operate, maintain, and improve the Services and overall customer experience; (ii) establish an online DSW account for you at your request through which you may access information about DSW’s current and past opportunities; (iii) determine whether you may qualify as an accredited investor for investment purposes; (iv) provide customer service and respond to communication requests (for example, answering your questions, responding to a request, or providing feedback about Submitted Information); (v) communicate and provide additional information that may be of interest to you about DSW and our affiliates; (vi) identify your preferences so we or our affiliates can notify you of new or additional services, promotions, and opportunities that might be of interest to you; (vii) validate your ability to access certain content or use certain services; (viii) send you reminders, updates, support, administrative messages, service-related announcements, marketing messages, and requested information; (ix) perform analytics and conduct customer research; (x) enhance other information we have about you to help us better understand you and determine your interests; or (xi) manage our everyday business needs, such as administration of the Services, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with applicable law.

We may anonymize some information for purposes of analyzing and gauging interest in current or potential markets, projects, or industries.

We may also use information collected as described in this Privacy Policy with your consent or as otherwise required or permitted by law.

  1. How We Share Your Information.

We may share your Personal Information as required or permitted by law as follows: (i) with any of our affiliates, who may only use your Personal Information for the purposes described in this Privacy Policy, (ii) with our vendors who provide services for use on our behalf, such as processing payments, data storage, assistance with direct marketing and distribution of emails and other communications, fraud prevention services, analysis and underwriting inquiries, and to accomplish the other purposes for collection as described in this Privacy Policy, (iii) in the event we or any of our affiliates file for bankruptcy, or where there is a transfer of ownership or assets in connection with proposed or consummated corporate reorganizations of DSW or any of our affiliates, such as merger, acquisition, or sales of business units, (iv) to comply with legal orders and lawful government requests, (v) to combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and business partners, or as part of legal proceedings affecting DSW, (vi) in response to a subpoena, court order, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries were we operate, or (vii) with your consent.

We may disclose Personal Information on an anonymized basis with our affiliates and vendors for their own research and analysis.

  1. Third Party Websites.

This Privacy Policy only addresses the collection, use, and disclosure of information by DSW through your interactions with the Services.  Our Services may contain links to, or have features that are hosted by, other third party websites or services that are neither owned nor controlled by DSW.  This Privacy Policy does not address the policies or practices of any third parties or any third party websites or features that are linked or available from our Services.

We have no control over or responsibility for the privacy practices and content of our vendors, linked services or features, or any other third party services.  If you provide information to any third parties, such as a third party payment processor, different rules regarding collection and use of your Personal Information by such third parties may apply.  We strongly recommend that you review the privacy policies of any third party before providing information to them.  You should contact those third parties directly if you have any questions or concerns about their privacy practices or policies.

  1. Your Choices.

Commercial and Marketing Emails.  You may choose to opt-out of receiving commercial emails from us by following the instructions contained in any commercial or marketing emails.  Please note that even if you unsubscribe from commercial or marketing emails we may still email you non-commercial emails related to your account and Services.  [Please allow us 10 business days from when the request was received to complete the removal.]

EU users.  If you are a user based in the European Union, Switzerland, or European Economic Area (together the “EU”), we only send you commercial emails when we have obtained your explicit prior opt-in consent.

[Cookies and Tracking.  You can disable cookies at any time by adjusting your browser settings.  Browsers are different, so refer to instructions related to your browser to learn about cookies-related and other privacy and security settings that may be available.]

[Do Not Track.  Currently we do not alter our data collection and use practices in response to Do Not Track signals.]

Accessing Your Personal Information; Right to Be Forgotten.  Subject to applicable law, you have the right to obtain, request access to, and receive copies of the Personal Information we keep about you; correct inaccuracies in your Personal Information; object to the processing of your Personal Information; and have your Personal Information blocked, anonymized, or deleted, as appropriate.  The rights to access or delete your Personal Information may be limited by local law requirements.  To receive copies of your Personal Information, correct inaccuracies, or request that your Personal Information be deleted, please contact us as [email].

  1. How We Protect Your Personal Information.

The security of your Personal Information is very important to us.  We maintain commercially reasonable security safeguards that are designed to protect the Personal Information we collect against unauthorized use, disclosure, alteration, or destruction.  Notwithstanding the steps we have taken to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  While we strive to protect your information, DSW cannot guarantee or warrant that your Personal Information is under absolute security with the existing security technology.  If you have any questions or concerns about the security of our Services, please contact us at [email].

We store Personal Information only for as long as it is necessary for the fulfillment of the purposes for which the Personal Information was collected, unless otherwise authorized by law.  We take measures to destroy information if required by law or if the Personal Information is no longer required for the purpose for which it was collected.  Notwithstanding the preceding sentence, we may retain Personal Information if requested by law enforcement, government request, or if necessary to resolve a Dispute, or otherwise as required or allowed by applicable law.

  1. Children’s Privacy.

DSW does not intend that any portion of its Services be used by persons under the age of 18 and such use is prohibited.  By using the Services and/or creating an account you represent that you are at least 18 years old.  If DSW obtains actual knowledge that an account is associated with a registered user who is not at least 18 years old or that information has been transmitted to DSW by a person who is not at least 18 years of age, we will promptly delete information associated with that account and any information collected from use of the Services by such person.  If you are a parent or guardian of a minor under the age of 18 and believe that he or she disclosed Personal Information to us, please contact us at [email].  A parent or guardian of a minor under the age of 18 may review and request deletion of such minor’s Personal Information and prohibit the use of such information.

  1. International Users.

If you live outside of the United States (including in the EU) and you use the Services or provide Personal Information to us directly via the Services, your information will be handled in accordance with this Privacy Policy.  Your Personal Information will be collected and stored in the United States and will be subject to the laws of the United States.  By using the Services or giving us your Personal Information, you are directly transferring your Personal Information to us in the United States.  Please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country.  The laws of the United States will govern the processing of your Personal Information, including any obligations of security and third party information sharing.

  1. California Privacy Rights.

Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year.  That notice will identify the categories of information shared with third parties, the name and addresses of those third parties, and examples of the types of services or products marketed by those third parties.  If you are a California resident and would like to request a copy of this notice, please submit a written request to [email].

  1. Contact Us.

If you have any questions or comments about our privacy practices or this Privacy Policy, please contact us at [email].

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