Privacy Policy

DIGITALPATH'S PRIVACY POLICY

Last modified: May 17, 2024

INTRODUCTION

We at Digital Path, Inc. (“Digital Path”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit this website and our practices for collecting, using, maintaining, protecting, and sharing such information.

This Policy applies to information we collect on or through this website as well as in email, text and other electronic messages between you and this website. This Policy does not apply to information collected by (i) us offline or through any other means, or (ii) any third party, including any application or content that may link to or be accessible from or through our website.

We ask that you please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use this website. By accessing or using our website, you agree to this Policy.

This Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

WHAT INFORMATION WE COLLECT

Digital Path collects information to deliver and enhance our services. This collection happens in various ways and is used responsibly, adhering to privacy laws:

1. Information you provide directly:

1. Account setup: When you create an account or interact with our services, we collect details like your name, address, phone number, email and other information provided by you or your organization.
2. Customer Support and Feedback: When you sign up for DigitalPath service, we ask you to put a credit card on file for automatic payment. During this process we ask you to provide your name, contact information and credit card information.

2. Automatically Collected Information:

1. Website and Service Usage Data: When visiting our website or using our services, we collect data such as user demographics, referral URLs, visit duration, browser type, operating system, and mobile network information. This data helps us understand user behavior and improve website functionality.
2. Device Information and Access Details: We collect information about the devices accessing our services, including IP addresses, device settings, and GPS locations to optimize service delivery and ensure security.

3. Information from Third Parties

1. Referral Information: When existing customers refer new clients, we collect information provided about these new potential customers to facilitate contact and service offerings.
2. Partnerships and Integrations: Data received from partners or third-party services integrated with our platform can include additional user metrics, service usage data, and enhanced analytics.

4. Interaction and Behavioral Data

1. Customer Service Interactions: Detailed records of any interactions you may have with our support team are collected to resolve issues, provide assistance, and improve service quality.
2. User Navigation and Preferences: Analysis of how you navigate our platforms and your preferences to tailor user experiences and develop more effective services.

HOW WE USE YOUR INFORMATION

Digital Path uses the information collected through various methods for multiple purposes, all aimed at delivering and improving our services, maintaining security, and complying with legal obligations:

1. Service Provision and Customization

1. To set up and maintain your Digital Path account.
2. To ensure our services are tailored to meet your specific needs and preferences.
3. To manage and optimize our broadband network, ensuring accurate environmental monitoring and data collection.

2. Communication and Customer Service

1. To communicate with you about your account, service changes, updates, and other important notices.
2. To respond to your inquiries, support requests, and feedback.
3. To inform you about new features, products, services, and promotional offers that might interest you.

3. Service Improvement and Development

1. To analyze how our services are used and how they perform to identify areas for improvement and develop new features.
2. To conduct research and analytics in order to understand market trends and customer needs better.

4. Marketing and Customer Engagement

1. To conduct marketing efforts, including targeted advertising and promotional campaigns.
2. To understand customer demographics, interests, and behavior to tailor marketing strategies.

5. Security and Fraud Prevention

1. To monitor and analyze data to detect and prevent fraudulent or illegal activities.
2. To enhance the security and integrity of our services and protect against cybersecurity threats.

6. Compliance and Legal Obligations

1. To comply with applicable laws, regulations, and legal processes.
2. To respond to requests from public and governmental authorities, including those outside your country of residence.

7. Feedback and Surveys

1. To solicit feedback to improve our services and user experience.
2. To conduct surveys and research studies to better understand your needs and the effectiveness of our services.

8. Data Analysis and Business Insights

1. To perform data analysis, audits, and other internal functions to enhance our services.
2. To develop business insights and strategies based on aggregated data and market research.

HOW WE SHARE YOUR INFORMATION

At Digital Path, we understand the importance of your privacy. Here’s how we handle your information responsibly:

1. Internal Sharing for Business Operations

1. Team Collaboration: We limit internal access to your personal information to employees who require it to perform their job functions, such as customer service, software development, and system maintenance.
2. Policy and Procedure Compliance: Our internal data-sharing practices are guided by company policies and procedures designed to safeguard your information.

2. Collaboration with Trusted Service Providers

1. Specialized Partners: We partner with selected third-party companies that assist us in service provision, including infrastructure support, analysis, and payment processing.
2. Operational Support: External firms may assist with data storage, consolidation, and secure processing to improve our platform’s efficiency and security.

3. Compliance and Legal Obligations

1. Regulatory Compliance: We may disclose your information if required by regulatory authorities, court orders, or legal processes to comply with our legal obligations.
2. Safety and Rights Protection: When necessary, we share information to protect against harm to the rights, property, or safety of Digital Path, our users, or the public as permitted by law.
3. Term of Use Enforcement: We may disclose your information to enforce or apply our User Agreement

4. Strategic Business Movements

1. Strategic Transactions: In the event of a business deal such as a merger, acquisition, or asset sale, we may share your information as part of the business deal.

5. Consensual Sharing Based on User Choices

1. User-Directed Sharing: We share your information with third parties when you instruct us to do so or provide explicit consent. This can include sharing data for third-party services that enhance your experience with our platform.

6. Anonymized Data for Improvement and Analysis

1. Insight and Innovation: We may use and share data in an anonymized or aggregated form for operational analysis, market research, or service enhancement, ensuring individual users cannot be identified.

YOUR STATE PRIVACY RIGHTS

As of the date of this Privacy Policy, the States of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia have enacted certain laws that provide their State residents with certain rights, such as rights to (i) confirm whether we process their personal information, (ii) access and delete certain persona information, (iii) correct inaccuracies in their personal information, taking into account the information’s nature processing purposes (excluding Iowa and Utah), (iv) data portability, (v) opt-out of personal data processing for targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah), and (vi) either limit (opt-out of) or require consent to process sensitive personal data. The exact scope of these rights may vary by State.

In the State of California specifically, the California Consumer Privacy Act (“CCPA”) grants natural persons, who are California residents according to applicable state regulations (“California residents”), specific rights regarding their personal information.

If you are a California resident and the CCPA applies to you, then you have the following rights regarding your personal information:

1. Right to Know

1. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you, as well as the sources of such personal information, the business purposes for collecting or selling the information, and the categories of third parties with whom such personal information is shared.

2. Right to Access (Data Portability Right)

1. You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

3. Right to Delete

1. You have the right to request that we delete personal information that we collect from you, subject to certain exceptions provided by law, such as where the information is needed to complete a transaction or comply with legal obligations.

4. Right to Correct

1. You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

5. Right to Opt-Out of the Sale of Personal Information

1. You have the right to direct a business that sells personal information to stop selling your information. Digital Path does not currently sell your personal information. If we ever change our practices, you will be provided with the appropriate opt-out and opt-in rights as required by the CCPA.

6. Right to Freedom from Discrimination

1. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under the CCPA. This means we cannot deny goods or services, charge different prices, or provide a different level or quality of services just because you exercised your rights.

7. Right to Designate an Authorized Agent

1. You have the right to designate an authorized agent to make requests under the CCPA on your behalf. To do this, we may require verification of your identity and confirmation of the agent’s authority.

Our website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident, household or device (for purposes of this section, “personal information”). In particular, our website has collected the following categories of personal information from California residents within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address and account name.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name and telephone number. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or Federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

We may share the personal information of California residents by disclosing it to a third party for a business purpose. In the preceding twelve (12) months, we have disclosed personal information of California residents for a business purpose to the categories of third parties indicated in the chart below. Digital Path does not currently sell your personal information to third parties. If that changes in future, we will revise this Policy to update the chart below to provide the categories of third parties to whom personal information has been sold in the preceding twelve (12) months.

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	None	None
B: California Customer Records personal information categories.	None	None
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	None	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	None	None
G: Geolocation data.	None	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

EXERCISING YOUR STATE PRIVACY RIGHTS

To exercise any rights to which you may be entitled under state privacy laws (including any applicable rights under the CCPA), please submit a verifiable request to us by:

• Emailing customerprivacy@digitalpath.net; or
• Sending a written request to Customer Privacy Advocate, Digital Path, Inc., 1065 Marauder St., Chico, CA 95973.

Please note that we may need to verify your identity before processing your request, which may include confirming account information or providing other identifying details. You can make a verifiable consumer request up to two times within a 12-month period. We may charge a fee to process or respond to your verifiable consumer request to the extent the request is repetitive, excessive, or unfounded. If we determine that your verifiable consumer request warrants a fee, we use reasonable efforts to tell you why we made that decision and provide you with a cost estimate before completing your request.

DATA RETENTION POLICY

Purpose of Data Retention: Digital Path retains personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods are based on business needs and legal requirements.

Retention Periods: We retain personal information for different periods of time depending on the type of information, the nature of the relationship, and the requirements of applicable law. For example, we may retain certain account information for the duration of the account’s existence and for a period after closure to comply with legal obligations and resolve disputes.

Data Disposal: Upon expiration of the retention period, personal information is securely deleted or anonymized, unless further retention is required for legal or auditing reasons. We take appropriate measures to ensure that your information is treated securely and in accordance with this privacy policy.

PRIVACY OF CHILDREN UNDER THE AGE OF 16

Digital Path’s services are not directed to children under the age of 16. We do not knowingly collect or solicit personal information from children under 16 or knowingly allow such persons to register for our services. If we learn that we have collected personal information from a child under age 16 without parental consent, we will delete that information as quickly as possible.

If you believe we might have any information from or about a child under the age of 16 without parental consent, please contact us at customerprivacy@digitalpath.net. We encourage parents and guardians to observe, participate in, and monitor and guide their children’s online activity.

COOKIE POLICY

Digital Path uses cookies and similar tracking technologies, including pixel tags, web beacons, and JavaScript, to enhance your experience on our platform, understand usage patterns, and improve the overall quality of our services. The following cookie policy explains how and why we use these technologies and the choices you have.

What Are Cookies?

Cookies are small data files placed on your computer or mobile device when you visit a website. They are widely used to make websites work or work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.

Types of Cookies We Use

• Essential Cookies: Necessary for the operation of our services, enabling you to move around our website and use its features. Without these cookies, services like logging in to secure areas cannot be provided.
• Performance and Analytics Cookies: Collect information about how you use our website, such as which pages you visit most often. These cookies are used to improve how our website works and understand user interaction with our services.
• Functionality Cookies: Remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you’ve made to parts of our website you can customize.
• Advertising and Social Media Cookies: Used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

Third-Party Cookies

We partner with third-party service providers who may also set cookies on your device during your visit to our website. These cookies enable third-party features or functionalities to be provided on or through the website, such as advertising, interactive content, and analytics.

Your Choices and Control

You have the right to accept or reject cookies. Most web browsers are set to accept cookies by default, but you can usually modify your browser settings to reject cookies if you prefer. Be aware that if you choose to remove or reject cookies, this could affect the availability and functionality of our website and services.

Consent

By using our website, you consent to the use of cookies as described in this policy, unless you have adjusted your browser settings to reject them.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on this website’s home page. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Policy to check for any changes.

Contact Us

For privacy inquiries or requests about this Policy, the ways in which we collect and use your information described herein, or your choices and rights regarding such use, please contact us by emailing us at customerprivacy@digitalpath.net or by mailing us at Customer Privacy Advocate, Digital Path, Inc., 1065 Marauder St., Chico, CA 95973.