Privacy policy

1. Who we are and what this policy covers

Down To Connect Inc., a Delaware corporation (“DTConnect,” “we,” “us,” or “our”), is the controller of the personal information described in this Privacy Policy.

This Policy explains how we collect, use, disclose, and protect personal information in connection with:

• the website at www.dtconnect.co and any DTConnect webpage that links to this Policy (the “Site”); and
• our related sales, marketing, application, and business communications.

What this Policy does not cover. Personal information processed in connection with participation on the DTConnect platform, including at app.dtconnect.co, is governed by the separate written agreements executed between DTConnect and the applicable vendor or brand executive, together with any platform-specific privacy notice or data processing terms referenced in them (each, a “Platform Agreement”). Where a Platform Agreement addresses a matter covered here, the Platform Agreement controls as to that matter.

This Policy also does not cover the practices of third parties we do not control.

2. Personal information we collect

2.1 Information you give us

• Identifiers and business contact information: name, business email address, telephone number, company name, job title, LinkedIn or other professional profile, and country or region.
• Application information: whether you are applying as a brand executive or as a commerce enablement vendor, your company’s category, size, technology stack, and other information you choose to include.
• Communications: the content of emails, forms, support requests, and other messages you send us, and our correspondence with you.
• Commercial information: if you make a purchase through the Site, information about the transaction. Payment card details are collected and processed directly by our payment processor and are not stored by us.
• Any other information you choose to provide.

Please do not submit sensitive personal information, confidential information belonging to you or a third party, or material nonpublic information through the Site.

2.2 Information we collect automatically

When you visit the Site, we and our service providers may collect:

• Device and connection data: IP address, browser type and version, operating system, device identifiers, language, and time zone.
• Usage data: pages viewed, referring and exit pages, links clicked, dates and times of access, and approximate location derived from IP address.
• Cookie and similar-technology data: as described in Section 5.

2.3 Information from third parties

We may receive information about you and your company from:

• Business data and enrichment providers, which supply professional and firmographic information such as job title, company details, and business contact details;
• Publicly available sources, including company websites and professional networking sites;
• Referrals, where a colleague, vendor, brand, or partner provides your business contact details so that we may contact you; and
• Our service providers, including analytics, marketing, and payment providers.

We combine this information with information we already hold about you.

2.4 Meetings and communications

If you participate on the DTConnect platform, meetings and other communications facilitated by DTConnect may be recorded, transcribed, and summarized, and information derived from them may be retained and used by DTConnect. Those practices, including notice, consent, use, and retention, are governed by the applicable Platform Agreement and any platform-specific notice, and not by this Policy. You will be told before a meeting is recorded, and applicable consent requirements will be followed.

3. How we use personal information

We use personal information to:

(a) respond to your Application, evaluate eligibility, and communicate with you about the platform;

(b) operate, maintain, secure, and improve the Site;

(c) send you marketing and business communications about DTConnect, subject to your rights in Section 8 and Section 9;

(d) personalize and measure the effectiveness of our communications and marketing;

(e) process and fulfil any purchase you make through the Site;

(f) analyze usage and trends, and conduct internal research, analytics, and product development;

(g) prevent, detect, and investigate fraud, abuse, security incidents, and violations of our Terms of Use;

(h) comply with legal, regulatory, tax, and accounting obligations, and to establish, exercise, or defend legal claims; and

(i) evaluate, negotiate, or complete a corporate transaction, including a financing, merger, acquisition, or sale of assets.

4. Legal bases for processing (EEA, UK, and Switzerland)

Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases:

Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights. You may request further information about that assessment using the contact details in Section 14.

5. Cookies and similar technologies

We and our service providers use cookies, pixels, tags, local storage, and similar technologies to operate the Site, remember your preferences, understand how the Site is used, and measure our marketing.

We use the following categories:

• Strictly necessary, required for the Site to function and to keep it secure. These cannot be switched off.
• Analytics and performance, which help us understand how visitors use the Site.
• Functional, which remember choices you make.
• Marketing and advertising, which help us measure and deliver our marketing.

Your choices. You can control cookies through your browser settings and, where we provide one, through our cookie banner or preference center. In the EEA and UK, non-essential cookies are set only with your consent. Blocking some cookies may affect how the Site works.

Global Privacy Control. Where required by law, we treat an opt-out preference signal such as Global Privacy Control transmitted by your browser as a valid request to opt out of the sale or sharing of personal information for that browser.

Do Not Track. The Site does not currently respond to browser “Do Not Track” signals.

6. How we disclose personal information

We disclose personal information to:

• Service providers and processors that perform services for us, including hosting, analytics, email and marketing, customer support, scheduling, payment processing, transcription and meeting-intelligence tools, security, and professional advisers. They are bound by contract to process personal information only on our instructions and for no other purpose.
• Affiliates, including group companies, for the purposes described in this Policy.
• Vendors and brands, where you have applied to, or participate in, the platform and it is necessary to evaluate or arrange an introduction or meeting. We disclose your business contact and professional information for that purpose.
• Professional advisers, including lawyers, auditors, and accountants.
• Acquirers and investors, in connection with a financing, merger, acquisition, reorganization, bankruptcy, or sale of all or part of our business, subject to confidentiality protections.
• Government authorities and others, where we believe disclosure is required by law or legal process, or is necessary to protect the rights, property, or safety of DTConnect, our users, or the public, or to enforce our Terms of Use or a Platform Agreement.

We do not sell your personal information for money.

We do not disclose personal information to third parties for their own independent marketing purposes.

7. Retention

We retain personal information for as long as necessary for the purposes described in this Policy, and then for the additional period necessary to comply with legal, tax, accounting, and regulatory obligations, to resolve disputes, to enforce our agreements, and to establish, exercise, or defend legal claims.

In determining retention periods, we consider the amount and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether those purposes can be achieved by other means, and applicable legal requirements. Where information is no longer needed, we delete it or de-identify it.

Retention of platform meeting recordings, transcripts, and derived information is governed by the applicable Platform Agreement.

8. Your U.S. state privacy rights

Depending on where you live, U.S. state privacy laws, including in California, Colorado, Connecticut, Virginia, Texas, Utah, Oregon, Montana, and other states with comprehensive privacy laws, may give you the right to:

• Know and access the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties to whom we disclose it;
• Correct inaccurate personal information;
• Delete personal information we have collected from you, subject to exceptions;
• Obtain a portable copy of personal information you provided to us;
• Opt out of the sale or sharing of personal information, and of targeted advertising; and
• Not be discriminated against for exercising these rights. We will not deny you goods or services, charge different prices, or provide a different level of quality because you exercised a privacy right.

We do not use personal information to make decisions that produce legal or similarly significant effects about you without human involvement, and we do not process sensitive personal information for the purpose of inferring characteristics about you.

How to exercise your rights. Email help@dtconnect.co with the subject line “Privacy Request,” identify the right you wish to exercise, and provide enough information for us to locate your records. We will verify your identity by matching the information you provide against our records, and may request additional information where necessary. We will respond within the timeframe required by applicable law, generally within 45 days, and may extend that period where permitted.

Authorized agents. You may use an authorized agent to submit a request. We may require written proof of the agent’s authority and may require you to verify your identity directly with us.

Appeals. If we decline your request, you may appeal by replying to our response or emailing help@dtconnect.co with the subject line “Privacy Appeal.” We will respond to appeals within the timeframe required by applicable law. If your appeal is denied, you may contact your state attorney general.

California categories

In the preceding twelve months we have collected the following categories of personal information under the California Consumer Privacy Act, as amended: identifiers; personal information listed in the California customer records statute; commercial information; internet or other electronic network activity information; approximate geolocation data derived from IP address; professional or employment-related information; audio or visual information, in the context of platform meetings governed by a Platform Agreement; and inferences drawn from the foregoing. The sources, purposes, and disclosure recipients for each category are described in Sections 2, 3, and 6.

9. Your rights in the EEA, UK, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the right to:

• request access to your personal information;
• request rectification of inaccurate or incomplete information;
• request erasure of your information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing based on our legitimate interests, and to object to direct marketing at any time;
• request portability of information you provided to us, in a structured, commonly used, machine-readable format; and
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise these rights, email help@dtconnect.co. You also have the right to lodge a complaint with your local supervisory authority, or with the UK Information Commissioner’s Office. We would appreciate the chance to address your concerns before you do so.

10. International transfers

DTConnect is based in the United States and our service providers operate in the United States and other countries. When we transfer personal information out of the EEA, the UK, or Switzerland, we rely on an appropriate transfer mechanism, which is generally the European Commission’s Standard Contractual Clauses together with the UK International Data Transfer Addendum, and we apply supplementary measures where necessary. You may request a copy of the relevant safeguards using the contact details in Section 14.

11. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, and loss. These include access controls, encryption in transit, and contractual security obligations on our service providers.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive information to us by unencrypted email.

12. Children

The Site is intended for business users and is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us at help@dtconnect.co and we will delete it.

13. Changes to this policy

We may update this Policy from time to time. We will post the revised version on the Site and update the “Last updated” date. If we make material changes, we will provide additional notice where required by law. Your continued use of the Site after the revised Policy takes effect constitutes acceptance of it.

14. Contact us

Down To Connect Inc.
800 North King Street, Suite 304-3620
Wilmington, Delaware 19801
United States
Email: help@dtconnect.co