David Allen Capital Data Protection Policy

David Allen Capital is committed to safeguarding the information entrusted to us.

In order to fulfill our commitment to our agents, operate effectively, and adhere to our legal and ethical principles, David Allen Capital, Inc. ("DAC") collects and responsibly stores and uses certain personal data about current, past and prospective, agents, members, and suppliers. The individuals who entrust DAC with their information are referred to as “data subjects” throughout this policy.

DAC is dedicated to obtaining, handling, processing, transporting, and storing personal data, whether held on computer, or paper, lawfully and correctly, in accordance with the safeguards contained in the General Data Protection Regulation Act of 2016 (GDPR) and the California Consumer Privacy Act of 2018 (CCPA).

DAC adheres to the principles of data protection as detailed in both the GDPR and the CCPA. These principles require that personal data must:

  • be obtained for one or more specified, lawful purpose(s) and not processed in any manner incompatible with those purposes;
  • be adequate, relevant and not excessive for those purposes;
  • be fairly and lawfully processed;
  • be processed in accordance with the data subject’s rights under the DPA (GDPR only);
  • be accurate and kept up to date;
  • not be kept for longer than is necessary;
  • be kept secure from unauthorized or unlawful processing and protected against accidental loss, destruction or damage; and
  • not be transferred to countries outside the European Economic Area (EEA) unless the country or territory ensures adequate protection for the rights and freedoms of the data subjects (GDPR only).

This David Allen Capital Data Protection Policy applies only to the collection, storage, and usage of information of data subjects located within the State of Michigan. David Allen Capital, Inc. hereby reserves all its rights under the law.

Personal Data

DAC collects personal data that data subjects, like you, provide to DAC. Personal data is any information which can be used to identify someone as an individual or location of an individual. This personal data may include your:

  • Name;
  • Address;
  • Telephone number;
  • Email;
  • Birth Date;
  • Credit card information;
  • Product purchase history;
  • Commission Earnings History;
  • Sales Data;
  • Tax Id (if one is supplied to us by you, the data subject).

How David Allen Capital Collects and Uses Personal Data

By sharing personal data, you, as a data subject, agree that DAC may, in accordance with applicable laws, use your personal data to:

  • Provide you with tips, helpful information, newsletters, upcoming events, and updates;
  • Improve the content of our communications with you;
  • Respond to your requests;
  • Improve DAC services;
  • Notify you of new products and services;
  • Seek your opinions on new products and services;
  • Assist with DAC’s own administrative and quality assurance purposes; or
  • For other purposes detailed elsewhere on the DAC website or a mobile application.

DAC only collects personal data to serve a specific business, commercial, or legal purpose and only gathers the minimum amount needed to fulfill those purposes. DAC will uses fair and lawful means to obtain the personal data.

DAC obtains a data subject’s informed consent to process and store his or her personal data in cases where it is necessary and appropriate to do so in compliance with applicable laws.

DAC does not use personal data collected for one purpose for a different purpose without the data subject’s consent, unless applicable laws require or allow it.

DAC will amend or delete any personal data if it is notified that such personal data is inaccurate.

Only authorized employees, trustees and volunteers of DAC, and third-party suppliers are permitted access to process personal data, which must be done in strict accordance with the individual roles and responsibilities with which they are tasked.

How David Allen Capital Protects Personal Data

DAC takes all appropriate measures to protect personal data, in accordance with applicable privacy and data security laws in the State of Michigan.

At the time personal data is collected, DAC uses strict procedures and security features to prevent unauthorized access. However, no data transmission over the internet is completely secure. As a result, DAC cannot guarantee the security of any information you transmit to us and you do so at your own risk.

When DAC teams up with a third-party service provider, that provider is carefully selected and purports to operate in such a manner as required under the GDPR and CCPA.

How David Allen Capital Limits the Sharing of Personal Data.

To operate effectively, DAC uses carefully selected third parties to provide support services, such as accounting, order processing and fulfillment, shipping, newsletter distribution and other legitimate business communication purposes. These parties are granted limited access to your personal data to enable them to provide those services to DAC. DAC makes every reasonable attempt to verify that all third parties providing such support services to meet the same standards of data protection as DAC’s own.

In certain limited instances permitted by applicable law, DAC may disclose your personal data when:

  • DAC has reason to believe that disclosure of this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with DAC’s rights, property or operations, other users of this website or any mobile application or anyone else who could be harmed by such activities;
  • DAC believes that applicable law requires it, or in response to any demand by law enforcement authorities in relation to a criminal investigation, or civil or administrative authorities in connection to a pending civil case or administrative investigation;

Personal data collected by DAC may be transferred to, stored, and processed in your country of residence, or any other country in which DAC subcontractors, agents, or third parties maintain facilities, including the United States and countries outside the European Economic Area (EEA).

DAC will ensure that if your personal data is transferred outside your country of residence, it will be treated in accordance with this DAC policy, and within the strict guidelines of the GDPR and CCPA.

Unless otherwise specified elsewhere, DAC will not sell or license your personal data.

Personal Data from Outside Sources

Where permitted by applicable law, DAC may also collect legally obtained information from third parties to add to its existing user databases. Some of this information may be personal data of data subjects. DAC may do this to better target information offerings and promotional campaigns in which DAC believes a data subject might be interested. Such personal data will only be collected and used by DAC in accordance with the basis on which it was originally provided by the data subject, or as otherwise permitted by applicable law.

Website and Mobile Application Usage Information – Google Analytics

DAC may also collect information about your computer browser type and operating system, websites you visited before and after visiting our websites, standard server log information, Internet Protocol (IP) addresses, GPS location data, mobile phone service provider, and mobile phone operating system. DAC has the ability to aggregate this information to understand how visitors to DAC websites use the websites so that DAC can improve these and the services that DAC offers.

GPS location data does not typically identify individual users. This information includes:

  • the total number of visits to DAC websites and mobile applications; and
  • the number of visitors to each page of DAC websites and mobile applications.

DAC uses Google Analytics as the main form of website statistics tracking. Any visitors to DAC websites who do not want their data used by Google Analytics can install the Google Analytics optout browser addon.

This addon instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) running on websites to prohibit their information from being used by Google Analytics. To optout of Google Analytics for the web, go to:

https://support.google.com/analytics/answer/181881?hl=en

Cookies.

The DAC website and mobile applications may use technology called “cookies.” A cookie is a small text file that is placed on your hard disk by a server. Cookies allow DAC websites and mobile applications to respond to you, the data subject, as an individual. The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

For instance, DAC server may set a cookie that keeps you from having to enter a password more than once during a visit to a website.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can typically adjust your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer. Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences.

If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit.

Links to Other Websites

DAC’s website may from time to time provide links to embed third party websites. This DAC policy does not apply to those third-party websites. If you choose to enter such a linked site, you agree and understand that DAC does not review or endorse, nor shall DAC be liable, directly or indirectly, for:

  • how these third-party websites treat your personal data; or
  • the content of such third-party websites.

For your own protection, always check the data protection policy posted on a third-party website or mobile application you access before entering any personal data.

Use of IP Addresses

An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your internet service provider o through your organization’s local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online.

DAC, or third-party companies acting on its behalf, may collect IP addresses for the purposes of systems administration and to audit the use of DAC’s website. DAC also may use IP addresses to identify users of DAC’s websites when DAC feels it is necessary to enforce compliance with the websites’ terms of use or to protect the service, website or other users.

Access to information – Subject Access Request

DAC will retain your information only for the period necessary to fulfill the purposes outlined in this DAC policy unless a longer retention period is required or permitted by applicable law. Data subjects may request the updating, correcting or removal of personal data that has been provided to us, or to third parties by DAC, at any time using the contact information below. California-based data subjects are limited to two personal information requests per year and DAC will respond to requests for information within the 45-day window, per CCPA requirements. Applicable laws may also give you the right to access information that you have provided to DAC.  If, as the result of a subject access request, any personal data is found to be incorrect it will be amended or deleted. DAC will deal promptly with subject access requests and respond to the request within a reasonable amount of time. If there is a reason for delay, the person making the request will be informed accordingly.

To request this information, please contact us at support@davidallencapital.com

Future Amendments to this Policy

DAC will update this policy to account for changes to working practice or applicable law. If the changes that DAC makes are material, DAC also may post a notice regarding the changes on its websites or mobile applications. DAC encourages you to periodically review this policy to remain informed about how DAC is helping to protect the personal data that DAC collects. Your action in continuing to use DAC websites and mobile applications constitutes your agreement to this DAC Policy and any updates.