Privacy Policy

Scope
This statement applies to Direct Effect® customers and directeffectinnovation.com visitors, unless a separate privacy notice is prominently displayed.

Uses
Direct Effect® values your privacy and has worked to build a brand that our participants and visitors trust. Thank you for reviewing our privacy policy.
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Our privacy policy tells you about our information practices when you provide personal information to us, whether collected online or offline, or when you visit us online to obtain information or materials. Personal information may include your name, email, mailing and/or business address, phone numbers, or other information that identifies you personally. We do not require you to register or provide personal information to visit our website, though registration may be required to access certain products or services.

Key aspects of our privacy policy include:

• We do not sell or rent your personal information to outside parties.
• We do not market other products or services to you without your consent.
• We do not use web analysis tools (e.g., cookies) to identify you personally without your express consent.

Notice of our privacy practices, including Privacy Act rights

The following describes the ways we collect information from you, and the protections that apply to your information.
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Direct Effect collects personal information from you and from your visits and interactions with us. We use information we collect to provide you certain products and services, and if needed to respond to your inquiries or requests for information.

Privacy Act Rights
Direct Effect follows the privacy requirements of the Privacy Act, which protects your personal information that we maintain in what is called a system of records. A system of records is a file, database, or program from which personal information is retrieved by name or other personal identifier. In other words, the Privacy Act applies when we use your personal information to know who you are and to interact with you – such as when you provide information to request a product or service, register on directeffectinnovation.com, or submit an inquiry or complaint. The Privacy Act provides comprehensive protections for your personal information. This includes how information is collected, used, disclosed, stored, and discarded.

When we collect and maintain personal information from you offline, a Privacy Act notice will be provided. The following is your Privacy Act notice for personal information collected online: Privacy Act notice: Your information will be used to provide you requested products, services, or information. Collection is authorized by 39 USC 401, 403, & 404. Providing the information is voluntary, but if not provided, we may not process your transaction. We do not disclose your information to third parties without your consent, except to facilitate the transaction, to act on your behalf or request, or as legally required. This includes the following limited circumstances: to a congressional office on your behalf; to financial entities regarding financial transaction issues; to an auditor; to entities, including law enforcement, as required by law or in legal proceedings; to domestic and international customs relating to outgoing international mail pursuant to federal law and agreements; and to contractors and other entities aiding us to fulfill the service (service providers).  

Information Collected from Emails and Online Forms
Many of our programs and websites allow you to send us an email. We will use the information you provide to respond to your inquiry, provide information, or to fill your order for products and services in which you have expressed an interest. Remember that email may not necessarily be secure against interception. If your email communication is very sensitive, or includes information such as your bank account, charge card, or social security number, you should send it by mail unless the Web site indicates the particular site is secured.  

Your choices and preferences

‍Direct Effect believes in permission-based marketing. We do not sell, rent, or otherwise provide your personal information to outside marketers. You will only receive marketing about products and services of Direct Effect or its partners, other than products and services you already receive or are registered for, under the following conditions.

• If you are a consumer, we use an opt-in standard. If you have provided personal information to register for or purchase a product or service, we will not use that information to contact you in the future about another product or service unless you have provided express consent.
• If you are a business, we use an opt-out standard. We assume you are interested in other products and services that could aid you in your business, and so we will provide information to you unless you tell us you do not want to receive it.

Consumers may opt-in, and businesses may opt-out, by contacting Direct Effect at any time. Please contact us at team@directeffectinnovation.com with any questions about your preferences.
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Security features and service provider controls

In those instances where we secure your personal information in transit to us and upon receipt, Direct Effect uses the encryption software. The URL in your browser will change to "HTTPS" instead of "HTTP" when this security feature is invoked. Your browser may also display a lock symbol on its task bar line to indicate this secure transmission is in place.

For site security purposes and to ensure that this service remains available to all users, Direct Effect employs software programs to monitor network traffic in order to identify unauthorized attempts to upload or change information, or otherwise cause damage. Except for authorized law enforcement investigations, no other attempts are made to identify individual users or their usage habits other than those uses identified in this policy. Unauthorized modification or misuse of information stored in this system will be investigated and may result in criminal prosecution.

Service Providers
Direct Effect enters into relationships with service providers in order to provide the highest quality product or service. Service providers may include an entity that provides assistance for the program, such as a call center; a provider of advertising services; or a partner for the program. Direct Effect holds service providers to the same rigorous standards of privacy that apply to Direct Effect, including being made subject to the Privacy Act policies. Service providers that have access to personal information are also subject to security review.

How you can access your personal information

If you have provided personal information to us, you may request to review the information that we have maintained. Please contact the Direct Effect via email at team@directeffectinnovation.com. We will correct or delete any inaccurate information upon your request.

Where to submit inquiries

We would like to hear from you if you have any questions or complaints regarding our privacy policy or use of your information. Please contact us at team@directeffectinnovation.com, or mail us at:

DIRECT EFFECT
THROUGHLINE, INC
1838 COLUMBIA RD, NW
WASHINGTON DC 20009

We will investigate and respond to your inquiry. Your inquiry will be treated confidentially and will be protected under the Privacy Act.

Web technology (such as cookies) to make the site operate effectively

Information Collected and Stored Automatically
We automatically collect certain information about your visit to directeffectinnovation.com. We limit the data collected to meet specific business needs and to fully protect your privacy. We thus may know what path(s) you took on directeffectinnovation.com, but we don't know who you are. Except for authorized law enforcement investigations, we do not use this information to identify you personally without your express consent.

We automatically collect and store the following information about your visit:

• General log information—Internet domain (for example, "xcompany.com" or "yourschool.edu"); Internet Protocol (IP) address; operating system; the browser used to access our Web site; the date and time you access our site; and the pages that you visited. Additionally, we collect information that identifies the software acting on your behalf (i.e., your user agent) and the device that you are using if you access the site through a mobile or wireless network. We use the information to help us make directeffectinnovation.com more useful to visitors. We use it to learn about how locations on our site are being used, what information is of most and least interest, and to ensure directeffectinnovation.com can interface with the types of technology our visitors use. We also use the information to tell us of any possible site performance problems and to identify, prevent, or mitigate the effects of fraudulent transactions.
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• Referral and statistical information where we have links or ad banners to or from directeffectinnovation.com. Such data may include aggregate data such as the number of click-throughs that occurred. It may also include specific data, such as whether you are a repeat visitor; whether you visited a page with a banner on it or clicked on an ad banner and then used our site (for instance, to register or access particular information); the value, date and time of any sale; and the identity of the site which you linked to or from directeffectinnovation.com. We collect this information to know which links and banners are effective. For example, this allows us to determine which ads may be of most interest and to help us control how many times a specific ad is displayed.

How Data Is Collected - Cookies and Other Web Analysis Tools
We understand that you may have questions about Web technology and information that is collected as you surf or conduct business online. Direct Effect has very strict policies about Web analysis tools. Such tools include what are known as cookies and Web beacons. Direct Effect uses a third-party analytics provider (currently Google Analytics) to analyze data from cookies. The third-party analytics provider does not receive personally identifiable information through these cookies and is prohibited from combining, matching or cross-referencing directeffectinnovation.com information with any other information. We have also limited the provider's ability to see your full IP address (a process known as "IP masking"). Please refer to Google Analytics security and privacy principles for more information. Direct Effect limits the types of analysis tools allowed, the data collected, and how long the tools last, in order to best serve your business needs and also safeguard your privacy.  

Cookies
Cookies may be categorized as session or persistent, which describes the length of time that they stay on your system. Both session and persistent cookies are used on this site. The following are detailed descriptions of how we use these cookies.

Session Cookies
A session cookie is a small piece of textual information that a server places temporarily on your browser during the time your browser is open. The cookies are erased once you close all browsers. We use session cookies in the following manner:

• Log-on and log-off administration—If you decide to register with our site, so as, for example, to use one of our online services, session cookies help with the log-on and log-off process. The cookies enable us to recognize your log-on ID when you log on so that we do not establish a duplicate registration record for you.
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• Transactions and site usability — We use session cookies to improve how you navigate through www.directeffectinnovation.com and conduct transactions. As examples, session cookies are used to maintain your online session as you browse over several pages; to store and prepopulate information so that you do not have to reenter the same information twice; to enable the postage rate calculator; and to retain your shopping cart information. Session cookies may also be used to collect referral statistics when you click on a link or ad banner to or from www.directeffectinnovation.com.

Persistent Cookies
A persistent cookie is a small piece of text stored on your computer's hard drive for a defined period of time, after which the cookie is erased. We do not collect or link to personal information through persistent cookies without your express consent. We use persistent cookies as follows:

• Site usage measurement—Our site measurement tool uses a persistent cookie to assist us in measuring how and when our Web site and its various components are used. It functions as a "visit cookie," so that we can determine if you are a repeat visitor to our site. This allows us to know if we are attracting new visitors and what aspects of the site seem most useful. The cookie will expire 30 days after your last visit.
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• Log-off safety function—Direct Effect uses a persistent cookie to automatically log you off of directeffectinnovation.com if there has been no activity for a certain number of minutes. This is done for your safety to ensure that, if you have finished using our site, but have forgotten to log off, no one else can use your computer via your log-on and password. The cookie is permanently removed from your computer when you log off, or, if you have closed the browser without logging off, it is removed within 15 minutes from your last activity.
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• Opt-in cookies—Persistent cookies allow us, at your request, to recognize you when you return to www.directeffectinnovation.com, or to remember certain information that you have provided us. The recognition feature allows you to log on to www.directeffectinnovation.com automatically, without having to enter your name and password each visit. The cookie assigns a random number to you, which we link to personal information you have provided and your purchase history. This allows us to personalize the site for you and tailor the content to your needs, for instance to show you other products you may be interested in. Other cookies allow us to remember certain information related to prior transactions, such as package tracking numbers, or mailing or address lists, so that we may prepopulate those fields for you on return visits. These features and cookies are strictly at your option and for your convenience. We will also present you with a convenient way to remove the cookies, via where you manage your account, if you decide later that you want to terminate one or more of these functions. The cookies will expire one year from your last visit.
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• Ad banner cookies—On behalf of the Direct Effect, persistent cookies and beacons (described below) may be set and managed by third party advertising suppliers to support ad banners. Ad banner cookies are set when you view or click on an ad banner on directeffectinnovation.com, or an ad banner on another site for a Direct Effect product, and persist for no more than five years.

Web Beacons
A Web beacon, also referred to as a clear gif or page tag, consists of code on the directeffectinnnovation.com site that delivers a small graphic image from another Web site or third party server. They may not be visible as the beacon is generally a 1x1 pixel that is often designed to blend into the background of a Web page.

We use beacons, often in conjunction with cookies, to monitor the effectiveness of ad banners; and to gather general log, statistical, and referral information. We do not use beacons to store or link to personal information. We thus use beacons to understand certain actions that you took (such as a purchase), but not to know who you are.

Third Party Web Analysis Tools
Direct Effect does not allow Web analysis tools to be used by third parties, except for service providers who help us in performing site analysis or providing a particular product, service, or advertisement. Service providers may use session cookies, just like Direct Effect does, solely to improve the use of the site.

Data Derived from Web Analysis Tools
‍We are careful to safeguard any data derived from cookies and beacons. No data derived from session cookies, or from the log-off persistent cookie, are retained. Data derived from other persistent cookies and beacons are retained behind the firewall or a secure firewall of our service provider.

Opting Out of Web Analysis Tools
‍If you still have concerns about cookies, you may choose to opt out of their use. Ad banner cookies – You can opt out of ad banner cookies, without erasing or altering other cookies. If you opt out of these cookies, we will no longer track any information from ad banners related to a specific user's visit. By clicking below, you will be taken to a third party site that explains how to opt out. Click here to learn how to opt out of ad banner cookie.

Opting out of all cookies – You may choose to opt out of the use of all cookies. You will still be able to access most features of directeffectinnovation.com. However, certain features may not work as well or may be unavailable to you. You will not be able to register on directeffectinnovation.com because we need cookies to keep track of your registration and associated transactions.

Online protections for children

Information from Children
As a collegiate-focused marketing program, Direct Effect does not typically request information from children under 13 years of age. Should Direct Effect do so in the future, we will do so only with parental notice and consent. We will take all necessary steps to protect the privacy and safety of any child participating, in accordance with the Children's Online Privacy Protection Act (COPPA).  

Postal Service Collection of Information from Children
‍We will post a notice that we are requesting information from children including the type of information, how we will use it, whether it will be forwarded to a third party, and a contact at our Web site for questions. We will utilize the information only for the given Direct Effect program, activity, or promotion. We will not condition a child's participation in an event on the provision of more information than is absolutely necessary for the purpose at hand. An example of such a promotion could be an educational opportunity that might be of interest to children.

Obtaining Verifiable Parental Consent
We will use reasonable effort to obtain verifiable parental consent prior to the collection and use of personally identifiable information from children under 13. The method of parental consent verification may vary according to the event in which the child wishes to participate. Means of obtaining such consent may include, but are not limited to, offline consent such as printing and submitting a permission form by mail or fax, or online consent that contains a verifiable unique identifier such as a credit card.

Parental Review
‍Direct Effect will allow parents to review any personal information collected from their children, based on verifying the identity of the consenting parent. Parents may revoke their consent and delete information collected from their children at their discretion. Direct Effect will then stop collecting, using, or disclosing information from that child, and will end that child's participation in that event if such information is necessary to continue. We will also alert parents if the event or activity changes either the type of information collected or the way in which the site uses the information.

When Parental Consent is Not Required
‍We do not require parental consent in order to collect and use online contact information to:

• respond directly to a child's request on a one-time basis to a specific request where the information is not used to recontact the child for other purposes;
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• request the name or online contact information of a parent for the sole purpose of obtaining verifiable parental consent or providing parental notification;
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• respond more than once directly to a specific request from a child and not used to recontact the child beyond the scope of that request.
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Notification to Children
Direct Effect will provide a prominent notice to children describing in age appropriate terms what personally identifiable information will be collected, and explain the need for those children to obtain parental consent before sharing their information.