Privacy PolicY

4. HOW WE USE YOUR INFORMATION

We use your personal data to develop and provide our products and services to you, to personalize, improve and promote our interactions with you, to manage our business and to ensure compliance with applicable laws.

Unless we specifically disclose otherwise, you understand that we may use any of your collected personal data for any of the purposes described in this Notice (as permitted by applicable law), including:

A. For Account Registration and Servicing.

• We may use your personal data to create, maintain, supplement, service, change or delete your account with us.
• If you have a customer account with us, we may collect certain personal data for security purposes in order to verify your authorized access to your accounts with us.
• We may use your personal data to resolve customer service questions you may have about our products and services and to follow up with you about your experience.

B. To Communicate with You.

• We may use your personal data to communicate with you about our products and services and to share offers for third party products and services that we think you may find useful.

C. To Improve and Develop New Products and Services.

• We may use your personal data to personalize your interactions and experiences with us.
• We may use your personal data to improve the quality of and to develop new products and services.
• We may use any information you give to us in surveys or other forms of feedback.
• We may combine your information with that from other customers in order to better understand our products and services and how we may improve them.

D. To Provide Our Products and Services and Operate Our Business.

• We may use your information to operate our business, including fulfilling your requests, providing you with technical or customer support, and complying with legal requirements.
• We may use your information to help us protect our products, services, workforce, and customers, including to combat fraud and protect your information.
• In some jurisdictions, we use demographic data such as ethnicity for diversity and inclusion programs.
• We may conduct research using your information alone or in combination with that of other customers.
• We use personal data to create aggregated or de-identified data, which we may use and disclose for any purpose.

5. HOW WE SHARE YOUR INFORMATION

We will only share your information as we have described in this Privacy Notice.

A. Third Party Service Providers. We may share your information, including personal data, with third party service providers who we contract with to help us provide our products and services and operate our business, including fulfilling your requests, providing you with technical or customer support, protecting our products and services, combatting fraud, protecting your information, verifying compliance with Dataram policies and applicable laws, preparing and delivering advertising and marketing content, providing content services, personalizing ads, studying the effectiveness of our ad campaigns, and understanding and measuring interactions with our online properties.

B. Information Sharing Between Dataram Entities. This Notice applies to all of your interactions with Dataram regardless of geography. Except where prohibited by law, regulation, or a contractual obligation, we share your information across Dataram (including among our affiliates and subsidiaries) for the purposes described in this Notice. When we share information between Dataram entities, we do so in the context of technical and organizational safeguards, including contractual measures in place between those entities, which for relevant transfers include the European Commission approved Standard Contractual Clauses. You can contact us for more details about those Clauses.

C. Following the Law and Protecting Dataram. We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to enforce our Terms of Use or other contracts, to protect the rights, property or safety of Dataram and our products, services, or workforce, or to protect or assist others.

D. Credit Reporting. We may share information about your creditworthiness with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

E. Sale of Our Business. If we sell, merge, or transfer any part of our business, information about you may be shared, sold or transferred as part of that transaction. We may also share your personal data with current or future corporate parents, subsidiaries or affiliates.

F. De-identified or Aggregated Data. We may de-identify or aggregate your information, alone or in combination with other individuals’ information, and share such de-identified or aggregated information freely.

G. With your Consent. Other than as set out above, we may also share your information for other purposes with your consent or at your direction.

6. INTERNATIONAL DATA TRANSFERS AND THE DATA PRIVACY FRAMEWORK

We may transfer, process or store your personal data in countries or regions other than those in which you are located.

Where permitted by applicable law, we may transfer, process or store your personal data in any country or region where we have facilities, business operations, or engage service providers, or where the other recipients of personal data described in this Notice are located. By using our site or otherwise interacting with us, you acknowledge the transfer of your personal data to, and the processing and storage of your personal data in, countries outside of your country of residence or the point of collection.

Some countries may have data protection laws that are different from the laws of your country. However, Dataram has taken appropriate safeguards to require that your personal data remains protected in accordance with law when it is being transferred, processed and stored.

Dataram complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Dataram has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Dataram has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, please visit https://www.dataprivacyframework.gov/.

Questions or Complaints In compliance with the DPF Principles, Dataram commits to resolve complaints about our collection or use of your personal data. Individuals with inquiries or complaints regarding our PrivacyNotice should first contact us by using our “Contact Us” information provided below. You may also use the self-help tools we make available to you on our websites to learn more about your rights with respect to data transfers and to request access to, limit the use of, or limit the disclosure of, your personal data. If you make a request that involves personal data, you will need to provide certain authentication and verification information in order for us to respond to your request. Dataram has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, the BBB National Programs Data Privacy Framework Service. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit:  https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

Binding Arbitration. Under certain conditions, and as a last resort, it may be possible for you to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. For additional information, see the U.S. Department of Commerce’s Arbitration Procedures (dataprivacyframework.gov). In the event and where necessary, if Dataram does transfer personal data to a country outside of the EEA, EU, UK or Switzerland which is not considered ‘adequate’ by the European Commission (‘Restricted Transfer’), Dataram will ensure that it will put into place adequate protection for the transfer of such personal data. This includes data transfer mechanisms such as the EU Standard Contractual Clauses and the UK Standard Contractual Clauses for Restricted Transfers.

7. CONNECTING WITH THIRD PARTIES

Dataram may work with third parties to enhance your experience.

In your interactions with us, it may be necessary for us to sync, link or connect your information with third parties, including providing personal data necessary to identify or authenticate your requested interactions. In some cases, your consent for these interactions will be required by us, by the third party or by both. We encourage you to review the privacy practices of any third party that you choose to share your personal data with, as we are not responsible for the privacy practices of third parties.

8. MANAGING YOUR PRIVACY

You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies. You can review and change your information or deactivate your account in your account settings, but we may retain certain information. While you have the right to select whether you receive promotional messages, you may still receive other non-promotional messages from us.

A. Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us. If you have received marketing communications from us that you no longer wish to receive, you may:

• Contact us or use the self-help tools we make available to you on our websites to manage your personal data and adjust your preferences regarding your personal data and your interactions with us.
• Click the “unsubscribe” link in the email or newsletter you received.
• Adjust your preferences in your Dataram account settings.
• For SMS messages, reply “STOP” or follow the instructions in the message or settings to discontinue the communications.
• If you are receiving push notifications from us to your mobile device and no longer wish to receive these types of communications, you may turn them off at the device level.
• Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.

B. Updating Your personal data. You may access, update, change, correct or request deletion of your personal data by using the self-help tools on our websites, by adjusting your Dataram account settings, or by contacting Dataram’s customer support.

C. Cookies and Similar Tracking Technologies. We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies (“Cookies”) to collect and manage information about you. You have control over some of the data we collect from Cookies and how we use that data. See our Cookie Policy and the “Manage Your Personal Data” button in the bottom corner of participating Dataram websites for details about some of these technologies and the information that they collect, use or share, including how you may be able to control or disable these applications. Please note that even if you elect not to enable Cookies for interest-based advertising, you may still receive advertisements, they just won’t be tailored to your interests based on those Cookies. Also, if you elect to receive Cookies and later delete your Cookies, or use a different browser or computer, you will likely need to renew your choices.

D. Do Not Track. Like most other companies, we are not currently configured to respond to browser “Do Not Track” signals because, at this time, no formal “Do Not Track” standard has been adopted. Please see our Cookie Policy for more information on “Do Not Track”.

E. Social Media Features. Dataram or our authorized third parties may use social media features to gather certain information about you. These features may collect your IP address and log which web pages you are visiting, and may also set a cookie to enable the feature to function properly. Your interactions with these social media features are governed by the privacy policies and practices of the providing company.

9. DATA RETENTION

Dataram retains and uses your information in accordance with and as permitted by applicable law and regulations:

• We will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business.
• When you close your account, we may continue to communicate with you about our products and services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have elected to not receive marketing communications from us.
• We may also continue to use some of your information for business purposes and to improve our offerings.
• We will retain and use your information as required by applicable regulations and Dataram’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and to detect and prevent fraud.
• Please refer to the table in Section 3 for retention by category of personal data.

10. SECURITY OF YOUR INFORMATION

We use security measures to help protect personal data.

Keeping your personal data safe is important to us. At Dataram we:

• Constantly work to update our security practices to help protect your personal data and review our security procedures carefully.
• Comply with applicable laws and security standards.
• Train applicable employees and contractors on data privacy and require them to safeguard your data.
• Comply with the Payment Card Industry’s Data Security Standards where applicable.

11. ADDITIONAL COUNTRY/REGIONAL CONSIDERATIONS

We operate in many different countries and regions. Our Privacy Notice sets out the privacy principles and procedures we adhere to globally, but specific laws may apply to you based on the country or region in which you are located.

Dataram has adopted a global approach on privacy with the intent of providing individuals with strong privacy protections regardless of where they reside. We recognize and implement high standards for privacy rights compliance on a global scale.

In addition to the terms of our Dataram Privacy Notice, additional privacy and data protection provisions apply to the processing by Dataram of personal data for Individuals in the European Union (EU), United Kingdom (UK), Switzerland (CH) and European Economic Area (EEA):

A. Controlling Law: During your interactions with us, the collection and processing of your personal data will occur as provided in and under the terms of our Dataram Privacy Notice, as modified or supplemented by these additional provisions. Dataram is considered to be a “controller” of your information under the EU General Data Protection Regulation 2016/679 (“GDPR”) and similar data privacy regulations.

The Dataram entity responsible for the processing of your personal data will depend on the unique circumstances of your interactions with us and applicable privacy rules, which may include the EU General Data Protection Regulation 2016/679 (“GDPR”). Dataram has adopted internal policies and implemented measures to ensure that the applicable legal requirements are met and that your personal data is processed with respect and care using the appropriate technology.

B. Legal Basis: Applicable law and policies require Dataram to have a “legal basis” for the processing of your personal data. The applicable legal basis often depends on the types of data and the specific context in which it is processed. Where the GDPR and similar laws apply, we typically rely on performance of a contract, our legitimate business interests, or your consent as our primary legal bases to process your personal data. The chart below provides more details regarding each of our processing activities and the corresponding legal basis that applies.