PRIVACY POLICY

 

UPDATED ON DECEMBER 1, 2019.

 

PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE CONTINUING TO USE OUR WEBSITE OR SERVICES (AS SUCH TERM DEFINED IN THE TERMS OF SERVICES). BY CONTINUING TO USE THE VDBS WEBSITE AND SERVICES YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.

IF YOU ARE A CALIFORNIA OR NEVADA RESIDENT, YOU ARE ENTITLED TO CERTAIN ADDITIONAL RIGHTS IN ACCORDANCE WITH THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA) AND NEVADA SENATE BILL 220 AND CHAPTER 603A OF THE LAWS OF THE STATE OF NEVADA. PLEASE VISIT THE CCPA SUPPLEMENT AT THE END OF THIS POLICY.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
All personal data of data subject is processed with aim of compliance with a legal obligation under U.S. Law and Art. 6(1) lit. of GDPR under which data controller is obliged to receive consent of data subject for specific processing operations with personal data.

1. This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of collection, processing, distribution, use and storage of Website user’s Personal data including any dispute concerning privacy under current Laws of the United States and the EU General Data Protection Regulation (GDPR), and in accordance with the data protection regulations applicable to Media Direct, Inc., and the Virtual DBS Website (hereinafter the “VDBS”, “Company”, “Us”, “We”).

2. It is understood and presumed that by the fact of use of the Website and its services, the User gives Consent, that he/she/it has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and its services.

3. The following definitions and rules of interpretation apply in this Privacy policy:
a) Cookies: A cookie is a text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. For more information on managing cookies, please go to www.allaboutcookies.org.

b) Consent: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

c) Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

d) Personal data: Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is an individual that can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, address or other identification data.

e) Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

f) Processor: Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

g) Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

h) Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with U.S. and/or EU shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

i) Sensitive personal information: Any information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. VDBS does not collect or store such information.

j) Third party: Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Website: Virtualdbs.com

4. This Privacy Policy may be modified, changed, supplemented, updated at any time with prior written notice from VDBS. Your continued use of the Website and its services after any amendments or alterations of this Privacy Policy without notification of VDBS shall constitute your consent hereto and acceptance hereof of an updated version of this Privacy Policy. At any case, the date of the most recent amendments and alterations will be indicated at the top of this web page. If the User does not agree to such revised terms of the Privacy Policy or Terms of Use he/she/it must stop using this Website and the account and may withdraw from his/her/its obligations under this Privacy Policy.

5. The data controller of this Website is VDBS. Contact details can be received at: info@virtualdbs.com.

6. The Website of the VDBS collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

7. The following information may be collected for general purposes: (a) the browser type and its version; (b) the operating system used by the accessing system, (c) the website from which an accessing system reaches the website; (d) the sub-websites; (e) the date and time of access to the Internet site; (f) an Internet protocol address (IP address); (g) the Internet service provider of the accessing system; and (h) any other similar data and information that may be used in the event of attacks on our information technology systems.

8. When using this general data and information, the VDBS does not draw any conclusions about the data subject. Rather, this information is needed to (a) deliver the content of our website correctly, (b) optimize the content of our website as well as its advertisement, (c) ensure the long-term viability of our information technology systems and website technology, and (d) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the VDBS analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

9. The following information can be collected for services purposes: (a) Contact information, such as name, home address, and email address; (b) Account information, such as username and password; (c) Information related to you virtual wallets public addresses; and/or (d) Financial information, such as bank account numbers, bank statement, and trading information, credit card numbers and related information.

10. The internet pages of this Website use cookies for the following purposes:

Purpose Description Type & Expiration
Performance (i.e., User’s Browser) Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Session Deleted upon closing the browser

Security (e.g. Asp .NET) Cookies If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas. Session Deleted upon closing the browser
Site Preferences Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Session Deleted upon closing the browser

Analytical We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on Website for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. Persistent, but will delete automatically after two years if you no longer visit Website.


Site visitor feedback We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times. The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.
The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days. 1 Session Deleted upon closing the browser

2 Persistent Deleted automatically after 90 days or presenting survey invite.

Social sharing We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. Persistent, but will be deleted automatically after two years if you no longer visit Website.

11. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies.

12. Our websites may contain links to non-VDBS websites. We are not responsible for the practices of those third party websites. Where you access other websites from our sites using the links provided, the operators of these websites may use cookies in accordance with their own cookies policy, which may differ from ours. You should read their privacy and cookie policies carefully before you provide any personal information to them.

13. The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more Datablcokchain.io processors that also uses personal data for an internal purpose which is attributable to the controller.

15. By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

16. The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

17. On the website of VDBS, users are given the opportunity to subscribe to VDBS’s information service. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. The information service may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to receive VDBS’s information service.

18. The website contains information that enables a quick electronic contact to VDBS. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

19. The data controller process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage. If the storage purpose is not applicable, or if a storage period expires, the personal data is routinely blocked or erased.

20. Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting VDBS by sending an email to info@virtualdbs.com: (a) to request access to your information and information related to our use and processing of your information, including: (i) the purposes of the processing; (ii) the categories of personal data concerned; (iii) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; (iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (v) the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; (vi) the existence of the right to lodge a complaint with a supervisory authority; (vii) where the personal data are not collected from the data subject, any available information as to their source; (viii) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; (ix) to obtain information as to whether personal data are transferred outside the US and EU, to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. (b) To request and to obtain from the controller the confirmation as to whether or not personal data concerning him/her/it is being processed. (c) to request the correction or deletion of your information. Data subject can request to delete his personal information (the right to be forgotten) in case: (i) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) the data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing; (iii) the data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR; (iv) the personal data have been unlawfully processed; (v) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the VDBS, he or she may, at any time, contact any employee of the controller. An employee of VDBS shall promptly ensure that the erasure request is complied with immediately. (d) to request that company restrict the processing of your information in cases when: (i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead; (iii) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims (iv) the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the VDBS, he or she may at any time contact any employee of the controller. The employee of the VDBS will arrange the restriction of the processing. (e) to receive information which data subject have provided to us in a structured, commonly used and machine-readable format and the right to have that information transferred to another data controller (including a third party data controller); (f) to object to the processing of your information for certain purposes; and (g) to withdraw your data protection consent to our use of your information at any time where data controller rely on your consent to use or process that information.

21. In accordance with Article 77 of the General Data Protection Regulation, data subject have the right to lodge a complaint with a supervisory authority.

22. We may disclose any information we collect about you, whether you are a current or former customer, including nonpublic personal information and any other information we collect, to VDBS affiliated companies and to non-affiliated third parties, which include non-financial companies, such as email service providers and fraud verification services, and others, such as other VDBS users with which you engage in transactions. We may make such disclosures: (a) to service providers that perform marketing services on our behalf; and (b) for everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus; (c) if we are under a duty to disclose or share your information to comply with our legal obligations.

23. Other than in connection with a merger, sale of VDBS assets, financing or acquisition, we will not sell or rent any of your information to third parties for their own marketing purposes.

24. Please note that third parties that support our customer identification and anti-fraud controls may retain and use information about you to perform services on our behalf and to improve their services. By using our Services, you consent to the retention and use of such information by these providers to improve their services.

25. We may also share aggregated or de-identified information with our affiliated companies or non-affiliated third parties, which cannot reasonably be used to identify you.

26. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

27. CHILDREN UNDER 18: This website is not intended for sue by anyone under the age of 18. We encourage parents and guardians to supervise their child’s use of the Internet. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other personal information without a parent’s or guardian’s permission when using the Internet. We recognize a special obligation to protect personal information obtained from children. In compliance with COPPA (the Children’s Online Privacy Protection Act), we have adopted the following policies to keep kids safe (there are exceptions to these policies as noted below): (a) We will NOT knowingly collect, use, or distribute personal information from children under the age of 13 without prior verifiable consent from a parent or guardian. (b) Personal information we collect from children under the age of 13 will be used solely by us or our agents for internal purposes only and will NOT be sold or otherwise distributed to third parties. (c) We will NOT knowingly allow children under the age of 13 access to free form chat, message boards, email accounts, or other services within the VDBS Website that would allow them to publicly post or otherwise distribute personal information without prior verifiable consent from a parent or guardian. (d) We will NOT knowingly ask a child under the age of 13 to divulge more information than is needed to participate in any service. (e) We will NOT knowingly keep any personal information that is inadvertently included in a child’s email submission, help inquiry, or other one-time request, if we know that the child is under the age of 13. Any such information will be purged promptly after the issue has been resolved. (f) We will NOT knowingly post any personal information that is inadvertently included in a child’s submission to a general audience contribution area if we know that the child is under the age of 13. Upon notice to us, these submissions will be deleted and handled anonymously thereafter. (g) We will NOT knowingly provide any direct link to websites that are unsuitable for children or teens. (h) We will advise children under the age of 13 that they MUST obtain permission from their parent or guardian before sharing ANY personal information. (i) Upon request, VDBS will provide a parent or guardian with a description of the information that may have been provided about their child during a registration process for a program or service of this site.


In the following instances we will NOT get verifiable parental consent for the collection of a child’s personal information: (a) Collecting a child’s contact information solely to directly respond to the child’s request on a one-time basis (for example, to provide assistance with a particular customer service question). We will not use that information to re-contact the child for any other purpose (we will purge from our system the child’s personal information after responding); (b) Collecting a child’s contact information and the contact information of his/her parent or guardian solely to directly respond more than once to a specific request from the child. In this instance, the parent or guardian will be notified that the child made such a request and be informed of the information provided by the child. The parent or guardian will have an opportunity at any time to revoke the child’s request. We will not use the child’s personal information to re-contact the child for any other purpose. (c) Using persistent identifiers on our Website to support the internal operations of our Website which include: maintaining and analyzing the functioning of the Website; performing network communications; authenticating users; personalizing content on the Website; serving contextual advertising or capping the frequency of advertising; protecting the security or integrity of the user, Website or service; and to ensure legal and regulatory compliance. A “persistent identifier” is a series of numbers that we assign to a user but cannot be reasonably used to identify a specific user. (d) A child may provide the email address of their parent or guardian for the purpose of retrieving or resetting a child’s lost password for their user account. A parent or guardian’s email address collected in this instance will only be used for this purpose.

28. Data controller does not use automatic decision-making or profiling to process and use data subject’s personal data.

29. VDBS uses relevant electronic and procedural safeguards to protect the privacy of the information the User provide to VDBS from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that VDBS are not liable for the security of any data Users are transmitting over the Internet, or third party content.

30. VDBS takes and addresses its users’ privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your personal information or you have other related inquiries or concerns, you may write or contact VDBS at email: info@virtualdbs.com. In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that if you provide VDBS with inconsistent privacy preferences, VDBS cannot guarantee that your most recent privacy preference will be honored.


CCPA SUPPLEMENT

This Privacy Notice for California and Nevada Residents supplements and is expressly made part of the information contained in the Media Direct, Inc. Private Policy and applies solely to all visitors, users, and others who reside in the State of California or in the State of Nevada (“consumers” or “you”). We adopt this Notice to comply with both the California Consumer Privacy Act of 2018 (CCPA) and Nevada Senate Bill 220 and Chapter 603A of the laws of the State of Nevada. The above laws may not apply to each of you in each scenario and are supplied here for your reference.

Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect
Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Collected
A. Identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). YES
C. Protected classification characteristics under California or federal law. NO
D. Commercial information. YES
E. Biometric information. NO
F. Internet or other similar network activity. YES
G. Geolocation data. YES
H. Sensory data. NO
I. Professional or employment-related information. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). NO
K. Inferences drawn from other personal information. YES

Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Media Direct, Inc. obtains the categories of personal information listed above from the following categories of sources:
• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Websites.
• From third-party business partners such as social media sites, ad networks, and analytics providers.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Media Direct, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Media Direct, Inc. about our Website users is among the assets transferred.

Media Direct, Inc. will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
Media Direct, Inc. may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:
• Service providers.
• Data aggregators.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:
• Service providers.

Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that Media Direct, Inc. disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that Media Direct, Inc. delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How can I opt out of Forma Safe Home’s information sharing?
You can contact us by either:
• Calling us at +1 954-949-9500 or 800-305-5500; or
• Sending a letter to us at Media Direct, Inc., Attn: Privacy Administrator, 1000 E Hillsboro Blvd #105, Deerfield Beach, FL,
and request not to receive marketing mailings that result from Media Direct, Inc. data.

It’s important to understand that when you opt out with Media Direct, Inc., we don’t delete your information. We mark it on our databases as “Do Not Share.” We do this because if your information is deleted, in the future, we would have no way to know that you requested that your information not be shared. When you’re marked as “Do Not Share,” we’ll know that you didn’t want your information shared in case your information is later resubmitted. We want to be sure that consumers’ requests are honored until we’re told of a change.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Calling us at +1 954-949-9500 or 800-305-5500; or
• Sending a letter to us at Media Direct, Inc., Attn: Privacy Administrator, 1000 E Hillsboro Blvd #105, Deerfield Beach, FL.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

•We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing
penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@virtualDBS.com.

Changes to Our Privacy Notice
Media Direct, Inc. reserves the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

Contact Information
If you have any questions or comments about this Notice, the ways in which Media Direct, Inc. collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Calling us at +1 954-949-9500 or toll free at 833-797-3282

• Go to our “Do Not Sell My Personal Information” Page located at:
VIRTUAL DBS OPT OUT

• Sending a letter to us at Media Direct, Inc., Attn: Privacy Administrator, 1000 E Hillsboro Blvd #105, Deerfield Beach, FL,