Privacy Policy

Purpose and Scope

This Digital Transformation Cloud Services (“DTCS”) Privacy Policy explains how Digital Transformation Cloud Services Inc., a California corporation, collect, use, store, process, disclose, and delete Personal Data (as defined in this Privacy Policy) you provide directly to us or that we receive from your authorized third parties including, without limitation, that you provide to us via our website, located at the dtcs.io domain, accessed through any medium, including via computer, mobile device, or other device (collectively, “Device”). This Privacy Policy also outlines your rights in respect to your Personal Data. We require this Privacy Policy to be posted on all DTCS Websites or be provided to you prior to any collection or processing of Personal Data.

Digital Transformation Cloud Services (DTCS) is a reseller of IT products and services that is headquartered in the United States. DTCS provides services to support cloud aggregation and cost optimization. DTCS provides you the ability to purchase or access a variety of product and service offerings made by DTCS and various third-party providers (“Offerings”) both directly from DTCS and through resellers and distributors. Each offering may be subject to offering specific privacy policies, which may supersede or complement the terms of this privacy statement. DTCS encourages you to carefully read the privacy policy of any offering before accessing or using that offering.

Although we encourage you to read this entire Privacy Statement, this is a summary of some of the more important aspects of the Privacy Statement:

Each Offering may include its own specific privacy policy. You should carefully read the privacy policy of any Offering before accessing or using that Offering.
We may collect both Personal Data and other information from you through a variety of sources, including Personal Data we have collected from you, whether on- or offline. We may also combine it with information we receive about you from publicly available information sources (including information from your publicly available social media profiles), and other third parties.
We will not use or share your Personal Data except as described in this Privacy Statement.
The failure to provide us with your Personal Data may interfere with our ability to conduct business with you, such as purchasing Offerings or process your transactions.
Where applicable, we honor opt out instructions from you for certain uses of your Personal Data under this Privacy Statement, such as, for example, when you opt out of receiving marketing email communications from us or request us to delete your Personal Data. However, by opting out of receiving marketing email communications you will not receive information about incentives and sales promotions.
We use appropriate technical and organizational controls to secure and protect your Personal Data, but we cannot ensure or warrant that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.

General Principles for the Processing of Personal Data

Personal Data will be collected, stored, processed and transmitted in accordance with DTCS’s established policies and applicable federal, state, local and international laws, rules and regulations.

The principles of DTCS with respect to the processing of Personal Data are as follows: (1) Personal Data will be processed fairly and lawfully, (2) Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) Personal Data collected by DTCS will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) Personal Data collected by DTCS will be accurate and, where necessary, kept up to date to the best of our ability, (5) Personal Data will be protected against unauthorized access and processing using appropriate technical and organizational security measures and controls; and (6) Personal Data collected by DTCS will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

If DTCS engages in the processing of Personal Data for purposes other than those specified in this Privacy Policy, DTCS will provide a notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.

Collection of Information

DTCS may collect Personal Data about you from a variety of sources, including, directly from you, from other users, from resellers and distributors, from our vendors, from our service providers, from third-party information providers, from our customers, and through the operation of the Website.

“Personal Data” collected by DTCS includes:

“Identity Data” such as first name, last name, username or similar identifier, title, company name, and government issued identification number.
“Contact Data” such as billing address, shipping address, email address and telephone numbers.
“Financial Data” such as bank account, payment card details and credit history.
“Transaction Data” such as details about payments to and from you and other details of products and services you have purchased from us..
“Technical Data” such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
“Profile Data” such as your username and password to access the Website, account number, purchases or orders made by you, your interests, preferences, feedback and survey responses.
“Usage Data” such as information about how you use our Website, products and services.
“Preference Data” such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
“Applicant Data” such as your employment history, education history, and professional certificates that you submit to us during a job application.

DTCS does not collect any Special Categories of Personal Data about you unless required by law (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, and sexual orientation).

DTCS collects your Personal Data as follows:

Information You Provide Voluntarily. We may collect Personal Data directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through the Website by way of email, online chat, web form, or online account registration to obtain access to Offerings, register for an event or training, sign up for marketing, promotional, or informational emails or communications, purchase an Offering, ask questions, attempt to resolve any issues related to the Website or Offerings, submit a job application, or submit feedback and comments.
Information that We Collect Automatically. When you visit our Website, we may collect certain information automatically from your Device. In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, your Media Access Control (MAC) Address, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
From Other Users. We may receive Personal Data about you from other users of the Website when they provide information to us. For example, we may receive information when they communicate with you or with us through the Website.
From Resellers and Distributors. We may obtain Personal Data about you from the resellers and distributors that purchase Offerings available from us and provide such Offerings to you.
From Our Vendors. We may obtain Personal Data about you from the third-party vendors that make Offerings available through us.
From Third-Party Providers. DTCS may also obtain Personal Data from third parties that have obtained or collected information about you and that have the right to provide that Personal Data to us. DTCS will only obtain this Personal Data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us. For example, if you register for the Website using a third-party service or through a third-party website or service, the information you provide to that third-party will be provided to us to establish your account on the Website. We may also contract with third parties that are in the business of providing information to businesses such as ours to verify certain information about you or obtain information. We may use the Personal Data about you we receive from a third-party outside of the Website in accordance with the terms we establish with that third-party and within the limits of the law. We may also obtain Personal Data at trade shows or events where you have attended and provided your consent to collect your Personal Data. We may also obtain Personal Data from publicly-available sources such as open government databases or other data in the public domain.

Cookies and Other Website Usage Information

The Website may also monitor and collect information about how you access, use, and interact with the Website automatically through “cookies,” “web beacons,” and other automated tracking technology.

Use of Information

DTCS uses Personal Data we collect to operate our business and provide you with Offerings, which includes using this data to improve our Offerings and personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account and product information.

DTCS may use your Personal Data for a variety of purposes (the “Purposes”), including to:

Register you as a new customer;
Provide, maintain, and improve the Website and our Offerings, including to operate certain features and functionality of the Website;
Understand user preferences to enhance users’ experience with DTCS, contractors, and business partners;
Research and analyze the effectiveness of the Website and the marketing, advertising and sales efforts of DTCS, contractors, and business partners;
Collect account receivables owed by customers of DTCS;
Process orders, deliveries and payments made through the Website;
Develop additional Offerings;
Process job applications;
Comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements);
Manage our everyday business needs;
Prosecute and/or defend a court, arbitration or similar legal proceedings;
Communicate directly with you by sending you newsletters, surveys, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications at any time by clicking “Unsubscribe” at the bottom of the email or by contacting us at [email protected].
Communicate directly with you by phone to respond to customer service inquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support.
Monitor and record your call, emails and text messages, social media messages and other communications (as permitted by local law) in relation to your dealings with us;
Comply with our contractual or legal obligations to share data with credit reference agencies, fraud prevention agencies and law enforcement agencies;
Compile aggregated statistics about the operation and use of our Website and to better understand the preferences of the visitors of our Website; and
Other Purposes: To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

We may combine and enhance the Personal Data we collect about you with other information we receive from third parties. We may also use the Personal Data we collect about you through the Website to generate anonymized, aggregated data. When we do so, we ensure that the anonymized, aggregated data is no longer personally identifiable and may not later be used to identify you. This will include, by way of example, storing the anonymized, aggregated data separately from any Personal Data.

Change of Purpose. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Credit Reference Checks, Fraud Prevention, and Denied Parties. The Personal Data that we have collected from you when setting up an account may be shared with credit reference, fraud prevention, and denied party agencies who use it to prevent fraud and money laundering and to verify your identity.

We may access and use information from credit reference and denied party agencies when you open your account and periodically to:

manage and take decisions about your account, including assessing your creditworthiness;
prevent criminal activity, fraud and money laundering;
check your identity and verify the accuracy of the information you provide to us; and
trace debtors and recover debts.

Application decisions may be taken based solely on automated checks of information from credit reference agencies and internal records.

We will continue to share information with credit reference agencies about how you manage your account including any default in making payments, while you have a relationship with us. This information will be made available to other organizations so that they can take decisions about you.

If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies, law enforcement agencies and other organizations may access and use this information.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing to you. Fraud prevention agencies can hold your information for different periods of time.

When credit reference, fraud prevention, and denied party agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect their business and to comply with laws that apply to them.

Information Sharing

We share your Personal Data with your consent or as necessary to complete any transaction or provide any Offering you have requested or authorized. We also share Personal Data with third-party vendors, resellers and distributors, third-party service providers, Subsidiaries and business units, when required by law or to respond to legal process, to protect our customers, to protect lives, to maintain the security of our Offerings, and to protect the rights or property of DTCS.

We may disclose your Personal Data as follows:

Vendors. DTCS may share Personal Data about you with the third-party vendors that make Offerings available through us. For example, we may share your Personal Data with a third-party vendor if you purchase or access an Offering through us, or an DTCS reseller or distributor, and that vendor requires verification of an Offering purchase in order to register that Offering. We may also share your Personal Data with a third-party vendor if that vendor co-sponsors a marketing activity with us to verify your participation in the marketing activity.

Resellers and Distributors. DTCS may share your Personal Data with the resellers and distributors that purchase Offerings available through the Website. For example, we may share your Personal Data if you purchase or access an Offering through a reseller or distributor, and that reseller or distributor leveraged our reseller tools and services.

Third-party Service Providers. DTCS may provide your Personal Data to third-parties that provide services to assist us with the Website and with achieving the Purposes. For example, these third parties may include providers of customer service, payment processing, email and messaging support, hosting, management, maintenance, information analysis, offering fulfilment or delivery, or other services we may receive on an outsourced basis. We will require that these third parties use your Personal Data only as necessary for such reasons and protect your Personal Data consistent with this Privacy Statement and applicable law. A list of third-party service providers is available upon request.

Other Users. DTCS may share your Personal Data with other users when you elect to interact with those users (or request that we communicate with them on your behalf) through the Website.

Law Enforcement and Safety. DTCS may share your Personal Data with any competent law enforcement, regulatory, government agency, court, other governmental officials, or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Sale or Acquisition of Assets. If DTCS transfers ownership or control of any portion of DTCS or the Website to an actual or potential buyer, whether in the context of an acquisition, merger, reorganization, 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 transfer your Personal Data to that actual or potential buyer, provided that the use of your Personal Data by that third-party remains subject to applicable law.

Others. We may share your Personal Data with any other person with your consent to the disclosure.

We may also share aggregated, anonymized data with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information we collected through your use of our Website. If we are required under applicable law to treat such information as Personal Data, then we will only disclose it as described above.

DTCS does not sell your Personal Data to third parties.

Other Important Privacy Information

Security of Personal Data. DTCS uses appropriate technical and organization controls and measures to secure and protect your Personal Data from unauthorized loss, misuse, and disclosure, such as strong user access controls, segmented network architecture, and comprehensive employee policies and training. Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while DTCS attempts to protect all Personal Data, DTCS cannot ensure or warrant that Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. DTCS will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) stored by or for us, in accordance with applicable laws.

Legal Basis for Processing Personal Data (EEA and UK Visitors Only). If you are a visitor from the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Data information described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (such as to fulfill your purchase of an Offering), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third-party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services and Offerings to you, and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we collect and use your Personal Data based upon your consent, the consequences of denying or withdrawing consent will be made known at the time your consent is provided.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using [email protected] email address.

Accuracy. It is your responsibility to provide DTCS with accurate Personal Data. Except as otherwise set forth in this Privacy Statement, DTCS shall only use Personal Data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, DTCS shall take reasonable steps to ensure that Personal Data is accurate, complete, current and relevant to its intended use.

International Data Transfers. Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our primary Website servers are in the United States, and our Subsidiaries and third-party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries. However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Policy. For Personal Data collected in the countries of the European Economic Area and/or the UK and transferred or accessed by DTCS in the United States, Digital Transformation Cloud Services, Inc. has executed the European Commission’s Standard Contractual Clauses in addition to appropriate technical and organization controls.

For additional transfers of Personal Data between our Subsidiaries outside the EEA and/or the UK and the United States we have implemented the European Commission’s Standard Contractual Clauses in addition to appropriate technical and organization controls, which require us to protect Personal Data they process from the EEA or the UK in accordance with European Union and UK data protection law as applicable. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Retention Period. We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with an Offering you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

If you are a resident of the European Union or the UK, all the Personal Data related to you and received and stored by DTCS are erased after 5 years, save for any Personal Data in documents and files we must keep for a longer period under applicable laws. For example, we cannot erase personal data appearing on VAT invoices before we can delete the invoices from our systems.

Your Data Protection Rights. You have the following data protection rights:

If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using [email protected].
In addition, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the contact [email protected].
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using [email protected].
Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area and the UK are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Children. The Website is intended solely for use by individuals 18 years of age and older and thus is not directed to children under 18 years of age. DTCS does not knowingly solicit or collect Personal Data from children under 18 years of age.

Do Not Track. Certain web browsers and other devices you may use to access the Website may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Website does not respond to “Do Not Track” signals. We do not modify your experience on the Website or modify the Personal Data we collect from you through the Website, based on whether such a preference is indicated.

Your California Privacy Rights. The California Consumer Privacy Act grants California residents certain rights in regards to our collection of their personal information. These rights include:

The right to be informed of (1) what personal information is collected, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about the consumer;
The right to request deletion of their personal information that has been collected; and
The right to opt out of the sale of their personal information.

California law also provides that California residents have a right to request that businesses tell them how their personal information has been shared with third parties for their direct marketing purposes. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s personal information to third parties for direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Data to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your personal information to third parties for direct marketing purposes and thus fall within this exception.

To opt-out of the sharing of your personal information to third parties for direct marketing purposes or otherwise exercise your rights under this section, please contact us using [email protected].

Sensitive Information. Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your express consent.

Third-party Websites. In addition to providing access to Offerings, the Website may include links to other websites and web services. This Privacy Statement does not apply to those websites and services and the privacy practices of those websites and services may differ from those described in this Privacy Statement. If you submit Personal Data to any of those other websites or services, your Personal Data is governed by the privacy policies applicable to those websites and services. DTCS encourages you to carefully read the privacy policy of any website or web service you visit.

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

If you believe that your Personal Data has been processed or disclosed in violation of this Privacy Statement, DTCS encourages you to raise any concerns using the contact information provided in this Privacy Policy using the email address [email protected]. DTCS will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data.

Revisions. DTCS may from time to time revise this Privacy Statement in its sole and absolute discretion to reflect changes in our business practices. If we revise this Privacy Policy, we will notify you by posting the updated Privacy Statement on this Website or by sending you a notification by email. Changes to the Privacy Statement will become effective and will apply to the information collected starting on the date DTCS posts the revised Privacy Statement on the Website. If we are required by applicable data protection laws to seek your consent to any changes in use of your Personal Data described in our updated Privacy Statement, then we will do that.

Questions and Contact Information

If you have any questions or concerns about this Privacy Policy, the privacy practices of DTCS, our collection or use of your Personal Data, or you wish to access or delete your Personal Data, please contact us at: [email protected]