Effective Date: [Date the Privacy Policy is first posted]
Privacy Policy
This Privacy Policy (“Policy”) describes how DesignerBank, LLC (“Company,” "we," "us," or "our") collects, uses, stores, and discloses (collectively as "process" or “processing”) Personal Data when you use our services, such as when you visit our website at www.designerbank.com (“Site”), our learning platform through our third-party service provider Cypher Learning (our “Modules”), or any other related domains, subdomains, or mobile application (collectively as "Services") that links to this privacy policy or communicate with us by email or other digital means.
Please review this Policy carefully before using our Services. If you do not agree with our policies and practices set forth here, please end your visit to our Site and do not use our Services. By visiting and using our Services, including through submitting information through the Site, you acknowledge, agree and consent that DesignerBank may collect, process, use, and store your Personal Data during and after your visit to our Site and use of our Services as described in this Policy.
Questions or concerns? If you have any questions about how we handle your Personal Data that we collect that aren’t addressed in this Privacy Policy, you can always contact us at question@designerbank.com.
What Types of Information We Collect
We may collect information that identifies, relates to, is reasonably capable of being associated with a particular living person either by itself or in connection with other information (“Personal Data”). Different privacy laws around the world describe Personal Data using different terms, including personal data, personal information, and personally identifiable information. In this Policy, we use the term Personal Data to mean the same thing as these other terms.
The following are categories of Personal Data that we collect when you use our Services and the sources from which we collect them.
Your identifiers, such as your first and last name (or initials), Internet Protocol (IP) address, email address, telephone number, account or user name, or other similar identifiers. We collect this information when they are provided directly by you, indirectly through automated collection technologies, or from our service providers.
Your Account Information, such as your log in credentials when you create an account to access the Modules and your account information. We collect this information when they are provided directly by you or from our service providers.
Information about your transactions with us (your “Commercial Information”), which includes records of services you engaged with, purchase history or tendencies. We collect this information as you engage with us directly or from our service providers.
We do not intentionally collect, and ask you not to provide, Sensitive Personal Data, which includes racial or ethnic origin, religious beliefs, consumer health data, sex life or sexual orientation, transgender or nonbinary status, national origin, immigration or citizenship status, genetic or biometric data, precise geolocation, and personal data from those who we know or has reason to know is a child.
When you use our Modules, our service provider Cypher Learning may also collect your personal data which they may share with us. Please refer to Cypher Learning’s privacy policy at https://www.cypherlearning.com/privacy-policy to see how they handle your personal data.
Payment processing is performed by Stripe, a PCI-DSS compliant third-party processor. We do not store card holder data on our systems. For more information, see Stripe’s privacy policy at https://stripe.com/privacy.
If you choose not to provide personal data
Where we need to collect personal data by law or because you have ordered a service from us and you do not provide the requested data, we may not be able to perform the contract we are trying to enter into or have entered into with you. If that is the case, we will inform you at that time and we reserve the right to cancel a service you have contracted with us.
Usage Data
We may automatically collect certain information through the use of cookies, pixels, tags, or other similar tracking technologies when you access our Site and use our Services.
A cookie is a piece of data contained in a very small text file that is stored in your browser or elsewhere on your hard drive. Cookies allow us to identify your device as you navigate our Site or your account. This makes navigating and interacting with our Site or your account more efficient, easy, and meaningful for you.
Cookies do not, by themselves, identify you, but they recognize your web browser. If you have also otherwise identified yourself to us, such as signing in to your account, then we would have that information. We use both session and persistent cookies.
Session cookies are cookies that disappear from your computer or browser when you turn off your computer.
Persistent cookies stay on your computer even after you’ve turned it off. You have the option of using your browser settings to opt-out of most categories of cookies other than Strictly Necessary Cookies.
Log and Usage Data such as service-related usage, diagnostic, and performance information does not reveal your specific identity (like your name or contact information) but may include device, internet traffic and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you access the Site and use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Site and our Services, and for our internal analytics and reporting purposes.
Device Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Google Analytics. We use third party analytics tools to help us understand users of our Site and Services. These tools use cookies to collect non-personally identifiable information including usage information and navigational information. The analytics tools provide us with aggregated data about site traffic and interactions, enabling us to improve the user experience on our Site.
Do Not Track Signals. Some internet browsers include the ability to transmit “Do Not Track” signals. We do not currently process or respond to “Do Not Track” signals. To learn more about “Do Not Track,” please visit “All About Do Not Track” at www.allaboutdnt.com.
How We Use or Process Your Personal Information
We use or process your Personal Data for a variety of reasons, depending on how you interact with our Services. The table below shows the purposes for which we use your information:
|
Purpose/Activity |
Data Type Processed |
|
For creating user accounts, authenticating user accounts, and managing user accounts. We may process your Personal Data so you can create and log in to your account, as well as to keep your account in working order. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data |
|
For providing and performing our services, including processing of orders, and delivering our services. We may process your Personal Data to provide you with the requested service. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Usage Data |
|
Receiving payments from users in accordance with our agreements, if applicable |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Usage Data |
|
Responding to user inquiries or to provide support to users. We may process your Personal Data to respond to your inquiries and solve any potential issues you might have with the requested service. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data |
|
Communicating administrative information to you. We may process your Personal Data to send you details about our products and services, changes to our terms and policies, and other similar information. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data |
|
Purpose/Activity |
Data Type Processed |
|
Requesting user feedback. We may process your Personal Data when necessary to request feedback and to contact you about your use of our Services. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Usage Data (f) Inferences |
|
Sending users marketing and promotional communications. We may process the Personal Data you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see below on "YOUR PRIVACY RIGHTS." If you have given your consent, we may allow selected third parties to provide you with information about services we feel may interest you. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data |
|
Publishing testimonials on our Site, our Modules, Apps, or social networking pages. We may publish your user experience with our services with your consent. |
(a) Identifiers (b) Commercial Data (c) Internet or Similar network activity (d) Usage Data |
|
Delivering targeted advertising to you. We may process your Personal Data to develop and display personalized content and advertising tailored to your interests, location, and more. |
(a) Identifiers (b) Commercial Data (c) Internet or Similar network activity (d) Usage Data (e) Inferences |
|
Purpose/Activity |
Data Type Processed |
|
Administering our Services and improving our internal operations. We may process your Personal Data as part of running and maintaining our Site, including for troubleshooting, data analysis, testing, research, statistical and survey purposes. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data (f) Inferences |
|
Disclosing information as required by applicable law. We may process your Personal Data if we are required to disclose that information by law, or if we need to respond to legal process, or to enforce our legal rights or defenses. |
(a) Identifiers (b) Account Information (c) Commercial Data (d) Internet or Similar network activity (e) Usage Data (f) Inferences |
Limitation or Change of Purpose
We will use your Personal Data for the purposes for which we collected it or another purpose that is compatible with the original purpose after we disclose that to you. An incompatible purpose is one that is very different from the original purpose, that which would be unexpected by you, or one that would have an unjust impact on you. If you would like an explanation of the compatibility of the processing for the new purpose with the original purpose, please contact us.
If we need to use your Personal Data for incompatible purposes, we will notify you to either get your consent or to explain the legal basis that allows us to do so.
Please note that if we are required to or permitted by law, we may process your Personal Data without your knowledge or consent, in accordance with the above rules.
Disclosure of Your Personal Data
We may disclose your Personal Data to a third party for a business purpose. When we disclose Personal Data for a business purpose, such as when our service providers
need to process your Personal Data, we enter into a contract with the third party recipient that describes the purpose and requires them to both keep that Personal Data confidential and not use it for any purpose except performing the services under the contract.
We may disclose your Personal Data to the following categories of third parties:
Our service providers or contractors, including payment processors, hosting providers, auditors, advisors, consultants, customer service providers, support providers, and internet cookie data recipients (e.g. Google Analytics);
Our business partners;
Government entities, including judicial and regulatory authorities or law enforcement authorities, or other organizations pursuant to lawful requests;
Successors (or potential successors) to all or part of our business;
Any third party if you have consented or directed us to do so.
We do not sell or share your Personal Data to third parties, including for their direct marketing purposes, unless we have your explicit and informed consent.
We reserve the right to disclose any de-identified or aggregate information about users, which does not include personally identifiable information, with third parties.
Where We Store Your Personal Data
We are based in the United States. The information that we collect from you (including Personal Data) may be transferred to, and stored at, a destination outside of the country in which you initial provided or we collected it. It may also be processed by our service providers who may operate outside your country, for one of our suppliers or one of our business partners.
By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy and applicable law.
How Long Do We Retain Your Personal Data
We keep your Personal Data for as long as reasonably necessary to fulfil the purposes for which we collected it. For example, we may retain your Personal Data as long as your user account remains open.
For certain types of information, we may need to retain it for a longer period of time to meet applicable legal, regulatory, tax, accounting or reporting requirements. We may also retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation concerning our relationship.
In the event we reasonably believe that we may need your Personal Data to enforce or defend our legal rights, we may retain your Personal Data for a longer period of time.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means, as well as applicable legal, regulatory, tax, accounting or other obligations.
Keeping Your Information Safe
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security and integrity of any Personal Data we process. In addition, we limit access to your Personal Data to those who have a business need to know. They will only process your Personal Data on our instructions and are subject to confidentiality obligations.
However, despite our safeguards and efforts to secure your information, no information transmission over the Internet or electronic storage technology can be guaranteed to be completely secure, so we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly access, steal, or modify your information.
You also play an important role in keeping your information safe. Use a strong password. Do not share your log in credentials with someone else. Public Wi-Fi is notoriously insecure, so you should only access the Site and use the Services within a secure environment.
Although we will do our best to protect your personal information, transmission of information, including Personal Data, is at your own risk.
If we suspect that there has been a security incident involving your Personal Data, we will notify you and any applicable regulator of a breach where we are legally required to do so.
Your Privacy Rights
You always have the right to opt-out of receiving our marketing or promotional communications.
Depending on your geographic location, you may have certain additional privacy rights. For example, in certain states within the US, you may have rights under certain US state data protection laws such as the right of access and correct your Personal Data and the right to withdraw your consent to the processing of your Personal Data.
However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Rights and choices for Maryland residents.
The Maryland Online Data Privacy Act may provide certain consumer rights to you, subject to certain exemptions. These include:
|
Data Protection Right |
Explanation |
|
Right to access |
You have the right to access the personal data we have collected about you. |
|
Right to correct |
You may ask us to correct any inaccuracies in your personal data. |
|
Right to request deletion of personal data |
You may ask us to delete personal data that you provided to us or that we obtained about you from a third-party source. |
|
Right to data portability |
You may request a copy of your personal data that we collected about you in a readily usable format. |
|
Right to opt-out of the sale of your Personal Data, or use of it for targeted advertising or profiling |
You may restrict your Personal Data from being sold. You may also opt-out of having your Personal Data be used for targeted advertising or profiling in furtherance of solely automated decisions that have significant legal effects concerning you. |
|
Right to a list of third parties to whom your Personal Data has been disclosed |
You may ask us for a list of the third parties with whom we have shared your Personal Data. |
|
Right to revoke consent |
You may revoke your consent from our processing your Personal Data, including the processing of sensitive personal data. |
Exercising your rights
You may opt-out of the sale of your Personal Data or use of it for targeted advertising or profiling at any time, and may exercise your other privacy rights above at no charge once every twelve (12) months. We reserve the right to decline excessive, repetitive, or technically infeasible requests and/or to assess a reasonable administrative fee to respond to such request.
You may submit a verifiable request to us by either (1) calling 410-332-4444 or (2) emailing question@designerbank.com and use “Data Privacy Rights” in the subject line.
In order for us to act upon your request, we will need to verify your identity to a reasonable degree of certainty. We may therefore ask you to provide three points of Personal Data which you have previously provided to us that we can use to match against our records to verify your identity.
We may also require you to submit a signed declaration under penalty of perjury stating you are the individual whose Personal Data is subject to the request. We may not be able to respond to your request if you decline to provide the verifying details or if any of the details are incorrect.
In general and unless otherwise stated in the above sections describing your rights, we will respond to your request within forty-five (45) days. If necessary, we may extend the time to respond by a further forty-five (45) days.
If for any reason we decide to decline to respond to your request, we will notify you and provide our explanation and any appeal process that may be available to you.
Children’s Information
Our Site and Services are not directed to or targeted towards those who are under 18 years of age. We do not intentionally allow users under the age of 18 to access our Site or use our Services, and we do not have actual knowledge that we have collected the Personal Data of anyone under the age of 16.
If we learn that a user under 16 has submitted Personal Data to us, or if we learn that the Personal Data is from one who is under 16, we will attempt to delete that Personal Data as soon as possible.
If you believe that we may have any Personal Data from a child under 16, please contact us at question@designerbank.com.
Links To Other Sites
If we have provided a link to any other website or location, it is for your convenience only and does not mean that we endorse that business, the website or its contents. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or these Terms of Use.
We have no control over, do not review, and cannot be responsible for these third party websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites. We encourage you to read their privacy statements so that you are aware of their privacy practices.
Privacy Policy Updates
We reserve the right to amend this Privacy Policy at our discretion and at any time. If we change the way we collect, use, or disclosure your Personal Data that require us to make changes to this Privacy Policy, we will post a notice on this page and update the Privacy Policy’s effective date.
Your continued use of our Site following any posted updates to the Privacy Policy constitutes your acceptance of such changes. If you object to any of the changes to our Privacy Policy, you must stop using the Site.
Contact Us
If you have any questions, comments, complaints or requests regarding this Privacy Policy, including any requests to exercise your rights, please let us know at the following address:
DesignerBank, Inc.
Address: 1000 S Ellwood Avenue, Baltimore, MD 21224
Email Address: questions@designerbank.com
Telephone No.: 410-332-4444