Last Updated – 10 September 2024
At Digitalux LLC (“Digitalux”, “we”, “us”, "Dream Life Rewards Club"), we process personal data about our customers, visitors on our websites and when you communicate with us or use our services (“you”). We make efforts to handle your personal data with care, keep it secure and comply with data protection laws.
How this policy works
The purpose of this Policy is to explain when, why and how we process information which may relate to you (“personal data”). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.
Contents
Who is responsible for looking after your personal data?
What personal data do we process?
What do we use your personal data for and when do we process your personal data?
Who do we share your personal data with?
Direct marketing
How long do we keep your personal data?
What are your rights?
1. Who is responsible for looking after your personal data?
Digitalux LLC having its registered address 33 McCarter Avenue, Fair Haven, New Jersey 07704, is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.
You should be aware that although we are principally responsible for looking after your personal data, information may be held in databases which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.
2. What personal data do we process?
We may process the following personal data about you:
Name
Email address
Postal address
Mobile Number
IP address
Location data
Website usage
Gender
Age
Occupation and place of work
Information that you choose to provide us with, for example personal information about yourself, preferences and interests
Account information, such as your username and password and other information you provide when you register for an Account
Membership and Subscription information, including information you provide when you sign up for a Membership and Subscription
Purchase history information, such as when you make a purchase from us or our partners
Inferred information, such as information derived from the information listed above
3. What do we use your personal data for and when do we process your personal data?
Digitalux LLC will collect information directly from you when you communicate with us, use our services or visit our websites.
We use your personal data to:
Send you material relating to Dream Life Rewards Club.
Communicate with you, for example by phone or email.
Analyze information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.
If we make available, register you for a chat forum or community in which you can provide comments.
Meet or exercise any of our legal obligations or rights.
We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:
you have provided your consent to us using the data in that way, or
our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to be able to carry out our business, improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy, or
perform obligations and exercise rights under a contract that we have with you or the organization you work for or represent.
Certain data protection laws require us to have a “legal basis” and defined purpose before processing any personal information about you. Our legal bases for which we may process your personal information may include:
to establish or perform the contract we are about to enter (or have entered) into with you;
for our legitimate interests (or those of a third party) which will not override your interests and fundamental rights; this includes many of purposes of processing listed above;
with your consent; this includes, for example, to personalize, deliver and measure certain direct marketing and advertising communications concerning our products and services; our communications may be sent by both non-automated and automated means (e.g., email, social media messages, SMS, MMS, automated dialing systems, or calls by human operators); and/or
where we need to comply with a legal or regulatory obligation and/or respond to requests from public and government authorities. This may include disclosing your information to law enforcement agencies or as required to comply with laws or regulations (including antifraud laws, money laundering, or tax laws) as well as transferring your personal information in connection with any potential or actual merger or sale of assets as part of a corporate transaction. When we process personal information on this basis, consistent with this Policy, we carefully review each request to ensure it is valid and that the requestor is entitled to the personal information they seek (and may challenge such requests as appropriate).
4. Who do we share your personal data with?
We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:
Our mailing application provider Klaviyo, based in the USA, who is certified under the Data Privacy Framework as you may see here and processes personal data on our behalf;
Our analytics service providers (such as Google & Meta), who process personal data for their own purposes as Data Controllers. Please refer to our Cookie Policy in order to identify how you may prevent access to your personal data by analytics providers.
Service providers or data processors that handle your personal data on our instructions, for example cloud services, advisers and consultants.
If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
In the event we sell, buy or re-organise any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.
We do not sell your personal information.
5. Direct Marketing
We will use your personal data to send you direct marketing communications regarding Digitalux LLC. This may be in the form of email, mobiler number or targeted online advertisements.
In some cases our processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by law it will be based on your consent.
You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting us (see Section 7).
We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.
6. How long do we keep your personal data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.
In some circumstances we keep your personal data during a certain period to meet for example legal, tax or accounting requirements.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.
7. What are your rights?
You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.
To exercise your rights you may contact us by sending an email to hello@dreamliferewardsclub.com or in writing to Digitalux LLC at the address set out in Section 1 above.
Please note the following if you wish to exercise your rights.
You can ask us to:
Confirm whether we are processing your personal data;
Give you a copy of that data;
Provide you with other information about your personal data, for example what data we have, what we use it for, who we disclose it to, whether we transfer it and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.
Rectification
Erasure
Restriction
Portability
Objection
You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Supervisory Authority
You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
8. Additional Rights
For information about your privacy rights and protection of your information, please see the California Privacy Rights Act Statement and Nevada Privacy Rights Statement below.
8.1 California Privacy Rights Act Statement
This California Consumer Privacy Statement (“Statement”) supplements our Privacy Policy. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, along with any implementing regulations (the “CCPA”).
8.1.1. Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal (including sensitive) information about you:
Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), internet protocol address, email address, and account name.
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, education, and financial or health information.
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, medical condition, disability, citizenship status, and military and veteran status.
Commercial Information: commercial information, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site.
Geolocation Data
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Policy and for the following business or commercial purposes specified in the CCPA:
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality.
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
8.1.2. Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
Directly from you, such as when you contact us with a question
From your devices, such as when you visit our Site or mobile applications
Our affiliates and subsidiaries
Vendors who provide services on our behalf
Our joint marketing partners
Online advertising services and advertising networks
Government entities
Social networks
Data brokers
Data analytics providers
8.1.3. Selling or Sharing of Personal Information
We do not sell your personal information in exchange for monetary consideration without your consent.
We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration. We share the categories of personal information listed below for the business and commercial purposes of online advertising and to provide third-party social network features and functionality on our Site. Those third parties may include Google, Coveo, Twitter, Facebook, EqualWeb, and Neustar. You can contact us at hello@dreamliferewardsclub.com to see an up to date list of the third parties collecting information on our sites. Those third parties may use your personal information to optimize our properties, display cross-contextual advertising and manage their own platforms. Please see the Cookies and Similar Tracking Technology above to learn more about those third parties’ collect of information. You have the right to opt out of this disclosure of your information, which may be considered a “sale” or “sharing” under California law, as set forth below in Section 5 (California Consumer Rights) of this Statement. During the 12-month period prior to the effective date of this Statement, we may have sold or shared the following categories of personal information:
Category of Personal Information
Category of Third Party
Identifiers - Advertising networks, data analytics providers, social networks, data broker
Commercial Information - Advertising networks, data analytics providers, social networks, data broker
Online Activity - Advertising networks, data analytics providers, social networks, data broker
Inferences - Advertising networks, data analytics providers, social networks, data broker
We do not knowingly collect, sell or share the personal information of minors under 16 years of age.
8.1.4. Disclosing Personal Information to Third Parties
During the 12-month period prior to the effective date of this Statement, we may have disclosed your personal information with certain categories of third parties and service providers, as described below.
We may have disclosed the following categories of personal information about you listed below for the commercial and business purposes set forth in Section 1 (Notice of Collection and Use of Personal Information) of this Statement to the following categories of third parties:
Category of Personal Information
Category of Third Party
Identifiers - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Additional Data Subject to Cal. Civ. Code § 1798.80 Law
Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Protected Classifications - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Commercial Information - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Online Activity - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Geolocation data - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Sensory Information - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
Inferences - Advertising Networks, Data Analytics Providers, Social Networks, Data Brokers
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have disclosed personal information about you with the following additional categories of third parties:
Government entities
8.1.5. California Consumer Privacy Rights
Privacy Rights. You have certain choices regarding your personal information, as described below. If you exercise any of these choices and rights, we will not disadvantage you. You will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services.
Know: You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions.
Correct: You have the right to correct inaccurate personal information that we maintain about you.
Opt-Out of Sale or Share:You have the right to opt out of the sale or sharing of your personal information, by contacting us. Once we receive and verify your request, we will not sell or share your personal information unless you later allow us to do so. You may also opt-out of our sharing and selling through certain browser enabled opt-out preference signals, such as the Global Privacy Control. You can learn more about that option at https://globalprivacycontrol.org/.
Limit Use and Disclosure of Sensitive Personal Information: In some instances, we may use or disclose your sensitive personal information You have the right to direct us to limit our use and disclosure of such sensitive information by contacting us. If you do, we may still use the information for certain limited purposes, such as the following: (i) performing our services or providing goods; (ii) detecting security incidents; (iii) resisting malicious, deceptive, fraudulent, or illegal actions; (iv) ensuring physical safety; (v) for short-term transient use, including certain non-personalized advertising; (vi) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services; and (vii) to verify and maintain the quality or safety of a service or product or to improve, upgrade or enhance a service or product.
Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit a request to know, delete, or correct, or limit the use of sensitive personal information, contact us at hello@dreamliferewardsclub.com
Authorized Agents. You may designate an authorized agent to submit requests on your behalf. To submit a request as an authorized agent on behalf of a consumer, please contact us at hello@dreamliferewardsclub.com
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign into your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: first name, last name, month & year of birth, email address, mobile number, mailing address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.
Data Retention. We keep records and personal information for specified periods of time, depending on business needs, privacy interests and the law. As a general matter, we only retain personal information for as long as it is needed or useful for accomplishing a business, legal or tax purpose. After such period, the data is deleted or fully anonymized:
data not processed based on your consent, but collected to fulfill our contractual obligations to you is retained while we have a relationship with you plus a period of no more than 10 years after that relationship ends, except when the retention of the data is necessary to enforce or defend our rights or comply with law; and
data collected for marketing purposes according to your consent is retained for a maximum period of 5 years after your relationship with us ends or until you withdraw your consent (although in many circumstances we retain that information for a shorter period, as required by law).
Nevada Privacy Rights
As a Nevada resident, you have the right to ask certain companies not to sell your personal information in exchange for money under the Nevada’s privacy law, SB260. Consistent with this Policy, we do not engage in such sales for monetary consideration, without your consent.
LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION
