DTEN PRIVACY POLICY

This Privacy Policy ("Policy") describes the policies and practices of DTEN Inc. ("we" or "us") as to the collection, use, and disclosure of information that we collect from users (“you”) when you purchase our product(s) and/or visit, access, use, or download from our website www.DTEN.com including all other media forms, media channels, mobile websites, or mobile applications related or connected thereto. Together, this Policy refers to these products, related services, and our website as the "Services". Please read this Policy carefully. By visiting, accessing, using, downloading, or purchasing the Services, you agree to be bound by our Terms of Use and this Policy and any other policies referenced herein. We will not use or share your Collected Information (as defined below) with anyone except as described herein. If you do not agree with the terms of this Policy, please do not access or engage with DTEN Services.

We take your privacy seriously. We provide this Policy so that you understand how we treat the information that you provide us ("Collected Information") as you use our Services.

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

Section1: How We Collect Information

We refer to all the information described in this section as “Collected Information.” We collect personally identifiable information in the following ways:

User-Provided Information. We ask you to provide us with their name, shipping address, email address, telephone, payment information, and other contact information when they engage our Services.

Automatically Collected Information. When you use the Service, our third-party service providers (as enumerated below) automatically collect information including but not limited to the Internet Protocol ("IP") address of your computer; web pages that you access within the Service; web pages that you access directly before and/or after accessing the Services; geographic information; a unique user ID; your access times; the type of browser, device, or operating system you use; search information; and usage and browsing information. If you access the Services through a mobile device, device information, such as your mobile device ID, model, manufacturer, and location will also be collected.

Section 2: How We Use Collected Information

Having accurate information about you allows us to provide a smooth, efficient, and customized user experience. We use Collected Information to deliver and better our Services, and for communicating with you about our Services. We do not use your personally identifiable information except as expressly describe in this Policy. If we use your email address to market to you, we will provide you with the option to unsubscribe or opt out of future marketing emails. Transactional emails regarding your use of the Service will not include an opt-out feature.

Specifically, we use Collected Information to:
Create and manage your account.
Process and manage purchases, orders, payments, and other such transactions related to our Services.
Email regarding your account or order.
Enable user-to-user communications which may include third party services like Zoom Video communications.
Generate a personal profile to make subsequent use of our Services more personalized.
Increase the efficiency and operation of our Services by monitoring and analyzing usage and trends of our users.
Send notifications of updates to the Services.
Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
Resolve disputes and troubleshoot problems.
Respond to product and customer service requests.
Deliver information on new products and services, recommendations, advertising, coupons, newsletters, and other information regarding promotions.
Compile anonymous statistical data and analysis for use internally or with third parties.
Request feedback regarding the use of our Services.
Connect your DTEN account with opted-in third-party applications (e.g. video conferencing).
Communicate with you as described elsewhere in this Policy.

Section 3: How We Disclose Collected Information to Others
We will not otherwise sell, license, or disclose Collected Information to anyone, without your express consent, except in the following limited circumstances:
Our business partners and affiliates (as defined in our Terms of Use;
Where necessary for us to work with other third-party service providers used for our Service ("Third-Party Services," detailed below);
In response to a court order or where required by law;
To investigate suspected fraud, violations of our Terms of Use, harassment, or illegal conduct; or
To another company in the course of a business acquisition, merger, or sale of assets. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.

Third-Party Services
We use various third-party service providers ("Third-Party Services") to operate the Services. Third-Party Services are used for analytics, payment processing, customer support, data analysis, customer service engagement, email delivery, cloud hosting services, and marketing assistance. Examples include Google Analytics and Amazon Web Services (AWS). To request an up to date list of the Third-Party Services we use as processors and/or our Data Processing Agreement, please create a support ticket or send your request to support@dten.com.

Section 4: Activity Logging and Tracking
The DTEN service performs server-side logging of client interactions with our Services. This includes web server access logging, as well as activity logging for actions taken through our API. We also collect event data from our Services. We collect information about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android, Windows) to ensure the Services work as expected for you. By providing us with information about how you interact with our Services, these tools help us learn how to make the DTEN experience even better and customize our communications with you. In order to use our Services we may need to use activity logging, tracking, or other Collected Information. If you choose to restrict us from processing such data, we may not be provide you with Services.

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

We do not process your payment information, a third-party payments system (e.g. Stripe)
processes your financial information, data relating to your payment method (e.g. valid credit card number, card brand, expiration date), when you purchase, order, return, exchange, or request information about our Services.

Section 5: Tracking Technologies
Cookies and Other Tracking Technologies
We (including some of our Third-Party Services) will use tools to collect information about how you use our Services. These tools include cookies, web beacons, tracking pixels, or other storage technologies that store users’ IDs or passwords to personalize web pages and provide website analytics. These tools help customize the Services and improve your experience, as well as analyze our performance and marketing activities. Please note that most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies completely.

If you choose to block cookies, our Services might not operate the way it was intended and any preferences you save may be lost.

Third-Party Use of Cookies and Other Tracking Technologies
Some content or links, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third-party tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting that you can activate. This signals your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will do so accordingly. If you set the DNT signal on your browser, we will respond to such DNT browser signals. To learn more about advertising networks and how to opt out of sharing information with them, please click here, here, and here.

Website Analytics
We also partner with select Third-Party Services, like Google Analytics, that allow tracking technologies and remarketing services that analyze and track users’ use of the Services, determine the popularity of certain content, and better understand online activity.

Section 5: Security
DTEN is committed to being transparent about our security practices and uses industry standard encryption to protect your data in transit such as the transport layer security (“TLS”) or secure socket layer (“SSL”) technology. We will continue to improve our transport security posture to support our commitment to protecting your data. We monitor the cryptographic industry trend and work promptly to update the service to respond to new cryptographic weaknesses and implement evolving standard best practices.

Section 6: Children Under the Age of 13
To access or use our Services, you must be at least 18 years old and have the requisite power and authority to understand and consent to the practices described in this Policy.

We do not knowingly market, direct our Services, or Collect Information from anyone under the age of 13 years old. If and when we discover the contrary, we will immediately delete the Collected Information from all of our databases.

Section 7: Your Rights With Respect to Collected Information
Since your privacy is important to us, we want you to be fully aware of all of your data protection rights under any applicable law, including EU General Data Protection Regulation (GDPR). Information that users in the European Economic Area (EEA) submit via the Services, and data we need to access or analyze in order to provide the Services available through the Services to you, may be sent to and stored on secure servers located in the United States of America and may be transferred by us to our other offices and/or to the third parties, who may be situated in the United States of America, People’s Republic of China (China) or elsewhere outside the EEA and may be processed by staff operating outside the EEA. The US, China, and other non-EEA countries do not have similar data protection laws to the EEA, and you should be aware that the law and practice in the United States or China in respect of law enforcement authority access to data is significantly different from Europe. By using our Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.
Every user accessing Services in the EEA is entitled to the following:
The Right to Access – You have the right to request from us copies of your personal data that is within our Collected Information.
The Right to Rectification – You have the right to request that we correct any Collected Information you believe is inaccurate. You also have the right to request that we complete the Collected Information if you believe it is incomplete.
The Right to Erasure – You have the right to request that we erase your personal data, if the Collected Information is no longer necessary in relation to the purposes for which it was originally collected or otherwise processed.
The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data. Per Section 4, if you choose to restrict DTEN from process such data, DTEN may not be provide you with Services.
The Right to Object to Processing – You have the right to object to us processing your Collected Information.
The Right to Data Portability – You have the right to request that we transfer our Collected Information about you to another organization, or directly to you, in a format that is easily readable and transferrable.
Section 8: Your California Privacy Rights, California Supplemental Privacy Notice
This California Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents (as defined by the California Consumer Privacy Act). It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone).
Summary of Information We Collect
California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as each of those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.
We or our Third-Party Services may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):
Our Services and operational purposes;
Detecting, protecting against, and prosecuting security incidents, fraudulent or illegal activity and activity that violates any terms or policies;
Bug detection, error reporting, and activities to maintain the quality or safety of our services;
Short-term, transient use, such as customizing content that display on Products and Services;
Providing Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communication about our services);
Auditing interactions on our site (e.g., measuring ad impressions);
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features, or to train our employees on issues that our users need to be resolved);
Other uses about which we notify you.
Examples of these types of uses are identified are in Sections 1-3 of this policy. We may also use your personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
Rights
If you are a California resident (as defined by the California Consumer Privacy Act), you may have certain rights. California law may permit you to request that we:
Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete particular information we have about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights referenced herein. Certain information may be exempt from such requests under applicable law. In addition, we need certain types of information so that we can provide our services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
If would like to exercise any of these rights, please submit a request by creating a ticket, calling 03-5532-7234, or emailing support@dten.com. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
The California Consumer Privacy Act (CCPA) sets forth certain obligations for businesses that “sell” personal information. It is important to note that DTEN does not sell any such personal information at this time.
Metrics
California law may require us to compile the following metrics for the previous calendar year: the number of rights requests received, complied with, and denied, as well as the median number of days within which we responded to those requests. To the extent this obligation applies to DTEN, we may update this section after the CCPA has been in effect for a year.
California Shine the Light
If you are a California resident, you may ask for a list of third parties that have received your information for direct marketing purposes during the previous calendar year. If we have shared your information, this list will contain the types of information shared, and we will provide this list at no cost. To make such a request, contact us by creating a support ticket or emailing support@dten.com.
California Do-Not-Track Disclosure
DTEN is committed to providing you with meaningful choices about the information collected on our Platform for third party purposes. That is why we have provided links (see Section 5) to the NAI "Consumer Opt-Out" link, the DAA opt-out link, and a Google opt-out link. However, DTEN may not fully recognize or respond to browser-initiated Do-Not-Track signals if you are trying to utilize the Services.
Section 9: How to Contact Us
If you have any questions about this Policy, the Collected Information we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us:

Email: support@dten.com

コール: 03-5532-7234

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

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