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 * Privacy Policy - DTEN

--------------------------------------------------------------------------------


PRIVACY POLICY

--------------------------------------------------------------------------------


DTEN PRIVACY POLICY

This Privacy Policy ("Policy") describes the policies and practices of DTEN Inc.
("we" or "us") as to the collection, use, and disclosure of information that we
collect from users (“you”) when you purchase our product(s), access your account
through our portal, and/or visit, access, use, or download from our website and
all other media forms, media channels, mobile websites, or mobile applications
related or connected thereto. Together, this Policy refers to these products,
related services, our portal, and our website as the "Services". Please read
this Policy carefully. By visiting, accessing, using, downloading, or purchasing
the Services, you agree to be bound by our Terms of Use and any other policies
referenced herein, and you acknowledge that you have read and understood this
Policy. If you do not agree with the terms of this Policy, please do not access
or engage with DTEN Services.  This Policy is not a contract and does not create
any legal rights or obligations.  For purposes of European data protection laws,
DTEN Inc. acts as the controller in connection with the certain personal
information described in this Policy.

If you are a California resident, see Section 8 for additional information
pursuant to the California Consumer Privacy Act, including information on how to
submit requests that we not “sell” your personal information by emailing
support@dten.com.

Section 1: We Collect Information From and About You

We (and the vendors we hire to perform business functions on our behalf) may
collect and receive various categories of personal information about you
depending on the nature of your interactions with us:

●Contact Information. We might ask you to provide your name, shipping address,
email address, telephone, and other contact information.

●Purchase and Preference Information: We collect information about your
preferences or purchases when using the Services.  For example, we collect
information about your order history and your preferences about our Services and
platforms, as well as which pages and content you interact with. 

●Internet and Network Activity Information. When you use the Service, we and our
service providers (as enumerated below) automatically collect information about
those interactions, including but not limited to the Internet Protocol ("IP")
address of your computer; web pages that you access within the Service; web
pages that you access directly before and/or after accessing the Services;
geographic information; a unique user ID; your access times; the type of
browser, device, or operating system you use; search information; and usage and
browsing information (such as what areas of our sites you visit and for how
long, what search terms you enter, and what products or content you view and
click on). If you access the Services through a mobile device, we will also
collect certain device information, such as your mobile device ID, model, and
manufacturer.

Section 2: How We Use Your Information

We use the above-referenced categories of personal information for the following
purposes:

●Create and manage your account.

●Process and manage purchases, orders, payments, and other such transactions
related to our Services.

●Email regarding your account or order.

●Enable user-to-user communications which may include third party services like
Zoom Video communications.

●Generate a personal profile to make subsequent use of our Services more
personalized.

●Increase the efficiency and operation of our Services.

●Analyze and improve our products and the Services.

●Send notifications of updates to the Services.

●Prevent fraudulent transactions, monitor against theft, and protect against
criminal activity.

●Resolve disputes and troubleshoot problems.

●Respond to product and customer service requests.

●For marketing purposes, such as delivering information on new products and
services, recommendations, advertising, coupons, newsletters, and other
information regarding promotions.

●Compile anonymous statistical data and analysis for use internally or with
third parties.

●Request feedback regarding the use of our Services.

●Connect your DTEN account with opted-in third-party applications (e.g. video
conferencing).

●Communicate with you as described elsewhere in this Policy.

●Verify your identity if you make requests pursuant to this Policy.

Section 3: We Collect Information From Various Sources

We collect information about you from various sources, directly and indirectly,
including from the following sources:

●Directly from you. For example, we may ask you to provide certain information
if you create an account, make a purchase, or otherwise engage or use our
Services.  We may also ask for information if you participate in a promotion,
contact us, or sign up to receive communications from us.  We will collect any
personal information you provide when you post a comment, make a request, or
complete a survey.

●Automatically from your devices. We use tracking tools like browser cookies and
web beacons to automatically collect information about you when you interact
with our websites, our ads, or our emails that we or our vendors send to you. To
learn about your choices for these tracking tools, read Section 6 of this
Policy.

●Vendors we hire to work on our behalf. For example, vendors that host or
maintain our websites or send promotional emails for us may give us information.
Our employment and recruiting vendors also give us information. Our marketing
agencies, advertising technology vendors, and analytics providers may also
provide us with information.

●Other sources. These other parties might include business and marketing
partners, and social media platforms that give us the information they have
collected either directly or indirectly from you.

Section 4: We Disclose and Share Information With Others

We may share or disclose each of the above categories of your information in the
following circumstances:

●Business partners, affiliates, and marketing companies. We might share
information with business partners or affiliates who co-sponsor a promotion or
promote our services. We may also share the above categories of personal
information with companies that help us with our marketing efforts, including
social media platforms, advertising networks, and ad tech companies. For
example, we may share email addresses or other contact information with social
media platforms so they can serve our advertising to you on their platform.
Personal information received by our partners and other parties may also be
subject to their privacy policies.

●Service providers. We use various service providers to help us operate the
Services, such as analytics, payment processing, customer support, data
analysis, customer service engagement, email delivery, cloud hosting services,
and marketing assistance. Examples include Google Analytics and Amazon Web
Services (AWS).

●For safety, security, or legal compliance purposes.  For example, we may share
your information in response to a court order or where required by law, or to
prevent, detect, or investigate suspected fraud, violations of our Terms of Use,
harassment, or illegal conduct.

●Mergers or Reorganizations.  We might share your information with another
company in the course of a business acquisition, merger, or sale of assets. If
we reorganize or sell all or a portion of our assets, undergo a merger, or are
acquired by another entity, we may transfer your information to the successor
entity. If we go out of business or enter bankruptcy, your information would be
an asset transferred or acquired by a third party.

We may also share information for other reasons we may describe to you from time
to time as permitted by law.

Section 5: Cookies and Other Tracking Technologies

We (including some of our service providers) use tools to collect information
about how you use our Services. These tools include cookies, web beacons,
tracking pixels, or other storage technologies that store users’ IDs or
passwords to personalize web pages and provide website analytics. These tools
help customize the Services and improve your experience, as well as analyze our
performance and marketing activities. Please note that most browsers allow you
to control cookies, including whether or not to accept them and how to remove
them. You may set most browsers to notify you if you receive a cookie, or you
may choose to block cookies completely.  Please see Section 6 below to learn
more about your choices about these tracking tools.  If you choose to block
cookies, our Services might not operate the way it was intended and any
preferences you save may be lost.

Some content or links, including advertisements, on the Services are served by
third parties, including advertisers, ad networks and servers, content
providers, and application providers. These third parties may use cookies, alone
or in conjunction with web beacons or other tracking technologies, to collect
information about you when you use our Services. The information they collect
may be associated with your personal information or they may collect
information, including personal information, about your online activities over
time and across different websites and other online services. They may use this
information to provide you with interest-based (behavioral) advertising or other
targeted content. We do not control these third-party tracking technologies or
how they may be used. If you have any questions about an advertisement or other
targeted content, you should contact the responsible provider directly. Please
see Section 6 below to learn more about your choices about these tracking tools.

Section 6:  You Have Certain Choices About How We Use Your Information. 

●You can opt-out of receiving our marketing emails. To stop receiving our
promotional emails, you can follow the instructions in any promotional message
you get from us. Even if you opt-out of getting marketing messages, we will
still send you transactional messages. These include responses to your
questions. 

●You may be able to block or remove cookies through your browser settings. You
can delete cookies by going to the preferences, tools, or options menus of your
Internet browser. If you choose to do so, some features of the website may not
function properly.  Selections you make are device-specific and
browser-specific, meaning that you may need to make your selections on each
browser and on each device you use to access the Services.  To control flash
cookies, which we may use on certain sites from time to time, you can go here.
Why? Because flash cookies cannot be controlled through your browser settings.

●You can opt-out of having your online behavior recorded and used for online
behavioral advertising purposes.  To opt-out from receiving interest-based
advertising from participating companies, visit the opt-out mechanisms of the
Digital Advertising Alliance (United States), the Network Advertising Initiative
(United States), and the European Interactive Digital Advertising Alliance
(European Union). Choices you make are both browsers- and device-specific,
meaning that you should exercise your preference on each browser and each device
you use. If you clear cookies from your browser, you may need to exercise these
choices again.

●Our Do-Not-Track Policy.  Most web browsers and some mobile operating systems
include a Do-Not-Track (“DNT”) feature or setting that you can activate. This
signals your privacy preference not to have data about your online browsing
activities monitored and collected. No uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will do so
accordingly.

Section 7: Your EU Privacy Rights

Since your privacy is important to us, we want you to be fully aware of the
potential data protection rights under applicable law, including the EU General
Data Protection Regulation (“GDPR”) if applicable to you. Information we collect
may be sent to and stored on servers located in the United States of America,
People’s Republic of China (China), or elsewhere outside the European Economic
Area (“EEA”), and may be processed by personnel operating outside the EEA. As a
result, this information may be subject to access by and disclosure to
government and law enforcement agencies in those countries according to their
laws. The standard of data protection in the United States, China, and in
certain other countries where we may process your information is considered by
the European Commission to be not adequate when compared to the data protection
standards of the EU and EEA. By using our Services, or providing us with any
information, you consent to the collection, processing, maintenance, and
transfer of such information in and to the United States, China, and other
applicable territories in which the privacy laws may not be as comprehensive as
or equivalent to, those in the country where you reside and/or are a citizen.

Lawful basis for processing your EEA personal data.

We process personal data on the following legal bases:

 1. Contract: It is necessary for our performance of the contract you have
    agreed to enter with us. If you do not provide your personal data to us, we
    will not be able to carry out our obligations under the terms of the
    contract.
 2. Legitimate Interests: We are permitted to process your personal data if it
    is based on our legitimate interests. In relation to the general inquiries
    and complaints you send us, our legitimate interest is to provide you with
    the information you have requested and to provide customer support. You can
    object to the processing that we carry out on the grounds of legitimate
    interests. See the section “Rights of data subjects” below to find out how.
 3. Consent: Where you have given us consent to do so, we provide you, or permit
    third parties to provide you, with information about goods or services which
    we feel may interest you. You have the right to withdraw your consent.
    Please see the section “Rights of data subjects” below to find out how.
 4. Legal Claims: We need to process your personal data to defend or establish a
    legal claim (for example, claims relating to the sale of our goods and
    services under contract law).

Rights of EEA Data Subjects

Users accessing Services from the EEA are entitled to the following rights:

 1. The right to be informed – You have the right to be provided with clear,
    transparent, and easily understandable information about how we use your
    information and your rights. This is why we are providing you with the
    information in this Policy.
 2. The Right to Access – You have the right to request access to your personal
    data that is within our possession. This is so you are aware and can check
    that we are using your information in accordance with data protection law.
 3. The Right to Rectification – You have the right to request that we correct
    any personal data you believe is inaccurate. You also have the right to
    request that we complete the personal data if you believe it is incomplete.
 4. The Right to Erasure – This is also known as the “right to be forgotten.” 
    You have the right to request that we erase your personal data, if there is
    no compelling reason for us to keep using it or if it is no longer necessary
    in relation to the purposes for which it was originally collected or
    otherwise processed.  This is not a general right to erasure; there are
    exceptions.
 5. The Right to Restrict Processing – You have the right to request that we
    restrict the processing of your personal data. If you choose to restrict
    DTEN from processing such data, DTEN may not provide you with Services.  We
    may keep lists of people who have asked to restrict processing in order to
    make sure the restriction is respected in the future.
 6. The Right to Object to Processing – You have the right to object to certain
    types of processing of your personal data, in particular, processing based
    on our legitimate interests.  You also can object at any time to your
    personal data being used for direct marketing purposes (including profiling
    related to such direct marketing). Where you object to processing for direct
    marketing purposes, the personal data shall no longer be processed for such
    purposes.
 7. The Right to Data Portability – You have the right to request that we
    transfer the personal data we have about you to another organization, or
    directly to you, in a format that is easily readable and transferrable.
 8. The right to refuse or withdraw consent: You have the right to refuse to
    provide and withdraw your consent to the processing of your personal
    information at any time with effect for future processing.

If you are not satisfied with our response to your complaint or believe our
processing of your information does not comply with data protection law, you can
make a complaint to your data protection authority.

Please note your rights in relation to your personal data are not absolute. We
may, for example, deny you access to your personal data when required or
authorized by law, or if granting access would have an unreasonable impact on
another individual’s privacy. We will retain and use your personal data as
described in this Policy, including as necessary to comply with our legal and
business obligations, resolve disputes, and enforce our agreements.

Section 8: Your California Privacy Rights, California Supplemental Privacy
Notice

This California Supplemental Privacy Notice supplements the information in our
Privacy Policy above, and except as provided herein, applies solely to
California residents. It applies to the personal information we collect on or
through the Services and through other means (such as information collected
offline, in person, and over the telephone).

If you are a California resident, you may ask for a list of third parties that
have received your information for direct marketing purposes during the previous
calendar year. If we have shared your information, this list will contain the
types of information shared, and we will provide this list at no cost. To make
such a request, contact us by emailing support@dten.com or sending us a letter
to the address below.  Indicate in your letter that you are a California
resident making a “Shine the Light” inquiry. 

If you reside in California, you can make the following more specific requests
with respect to your personal information:

●Access – You can request that we disclose to you the categories of personal
information we collected about you, the categories of sources from which we
collected the personal information, the categories of personal information we
sold or disclosed, our business or commercial purpose for collecting and selling
the personal information, the categories of third parties with whom we shared
the personal information, and the specific pieces of personal information we
collected about you over the past 12 months.

●Deletion – You can request that we delete your personal information that we
maintain about you, subject to certain exceptions.

●Do Not Sell My Personal Information – You can request that we not sell your
personal information by emailing support@dten.com. For purposes of this Policy,
“sell” means the sale of your personal information to an outside party for
monetary or other valuable consideration, subject to certain exceptions. Please
note that if you make a request to opt-out of sale, if you would like to opt-out
of cookie-based tracking for advertising purposes, you will need to separately
visit www.aboutads.info/choices and https://optout.privacyrights.info to opt-out
of certain uses of cookies for advertising purposes. Your selections are
specific to the device, website, and browser you are using. Your selections are
also deleted whenever you clear your browser’s cache.

DTEN will not discriminate against you because you made any of these requests.

If you would like to exercise any of these rights, please submit a request by 
or emailing support@dten.com. We may deny certain requests, or fulfill a request
only in part, based on our legal rights and obligations. For example, we may
retain personal information as permitted by law, such as for tax or other
record-keeping purposes, to maintain an active account, and to process
transactions and facilitate customer requests. Except as otherwise provided by
applicable California law, note that for purposes of these requests under this
Section, personal information does not include information about job applicants,
employees, and other of our personnel; or information about employees and other
representatives of third-party entities we may interact with.

We will take reasonable steps to verify your identity prior to responding to
your requests. The verification steps may vary depending on the sensitivity of
the personal information and whether you have an account with us.

California residents may designate an authorized agent to make a request on
their behalf. When submitting the request, please ensure the authorized agent is
identified as an authorized agent.

For purposes of California residents making these requests, please also note the
following regarding how we collect, use, and share your personal information as
described in this Privacy Policy, including in the previous 12 months:

●We or our service providers may collect the following categories of personal
information for our business or commercial purposes (as those terms are defined
in applicable law): Identifiers; payment and customer records information;
commercial information; professional or employment information; and internet or
other electronic network activity information. See Section 1 of this Policy for
additional detail.

●We collect and use the above categories of personal information for the
business and commercial purposes described in Section 2 of this Policy.

●We collect the above categories of personal information from the sources
described in Section 3 of this Policy.

●We may disclose each of the above categories of personal information for the
business and commercial purposes described in this Policy to the extent
permitted by applicable law to the categories of third parties as described in
Section 4 of this Policy.

●We may “sell” categories of personal information, including: Identifiers;
commercial information; internet or other electronic network activity; and
geolocation data. We may “sell” these categories of personal information to the
categories of third parties described in Section 4 of this Policy.

Section 9: Security

DTEN is committed to being transparent about our security practices and uses
industry standard security measures designed to protect your data at rest and in
transit. We will continue to review and, where necessary, improve our security
posture to support our commitment to protecting your data. Having said that, the
Internet is not 100% secure, and we cannot promise that your use of our Services
will be completely safe. Any transmission of your data to our websites is at
your own risk. We encourage you to use caution when using the Internet. We keep
personal information as long as it is necessary or relevant for the practices
described in this Policy, or as otherwise required by law. Personal information
may be accessed by persons within our organization, or our third-party vendors,
and those other parties described in this Privacy Policy, including those who
require such access to carry out the purposes described in this Privacy Policy,
and such other purposes as permitted or required by applicable law.

Section 10: The Services Are Not Intended For Children Under the Age of 13

To access or use our Services, you must be at least 18 years old and have the
requisite power and authority to understand and consent to the practices
described in this Policy.  We do not knowingly market, direct our Services, or
collect information from anyone under the age of 13 years old. If and when we
discover the contrary, we will promptly delete the information from all of our
databases.

Section 11: Third Party Links

Our Services may contain links to third-party websites and other applications of
interest, including advertisements and external services that are not affiliated
with us. Once you use these links to leave our Services, this Policy does not
cover any information you provide to these third parties. We cannot guarantee
the safety and privacy of your information. Before visiting and providing any
information to any third-party websites, you should inform yourself of the
privacy policies and practices (if any) of the third party responsible for that
website, and should take those steps necessary to, in your discretion, protect
the privacy of your information. We are not responsible for the content or
privacy and security practices and policies of any third parties, including
other sites, services, or applications that may be linked to or from our
Services.

Section 12: How to Contact Us

If you have any questions about this Policy, the information we hold on you, or
you would like to exercise one of your data protection rights, please do not
hesitate to contact us:

Email: support@dten.com

Call: 1-866-936-3836

Write: 97 E. Brokaw Road, Suite 180 San Jose, CA 95112

Please note that once you contact us to exercise any of your rights, we may
require additional information and documents, including personal data, in order
to authenticate and validate your identity and to process your request. We will
then retain such additional data for legal purposes (e.g. as proof of the
identity of the person submitting the request).

Section 13: Changes

From time to time, we may change this Policy. Any material changes,
modifications, additions, or deletions will be effective immediately as soon as
we give you notice of them, which we may do by means including but not limited
to issuing an email to the email address listed by registered users and/or
posting the revised Policy on this page. It is your responsibility to review
this Policy periodically and to be aware of any modifications. Unless otherwise
given an opt-in screen notification, your continued use of the Service after any
modification means that you acknowledge the change and understand the practices
that we disclose in this Policy.


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