Privacy Statement

Revised January 2021

Welcome to Dispoteca!

Dispoteca, an Arizona limited liability, and its affiliates (collectively, “Dispoteca”, “we”, or “us”) is committed to safeguarding the privacy of information entrusted to us. This privacy statement (the “Privacy Statement”) sets forth how we collect, use, store, process, disclose, and delete personal data (as defined in this Privacy Statement) you provide directly to us or that we receive from your authorized third parties including, without limitation, that you provide to us via our website, located at the dispoteca.com domain (“Website”), accessed through any medium, including via computer, mobile device, or other device (collectively, “Device”). This Privacy Statement also explains your rights in respect to your personal data. By using the Website, you unambiguously consent to any collection, processing, transfer or use of any personal data. If you do not consent to any collection, processing, transfer or use of such information, please discontinue use of the Website.

This policy does not apply to third-party websites, products, or services, even if they link to our services or Website, and you should consider the privacy practices of those third parties carefully.

1. Overview

Dispoteca provides businesses and institutions with end-of-life management services for computer equipment, using third-party providers, including the packaging, transporting, processing, testing, recycling, remarketing, purchasing, selling and/or destroying equipment, and offers features, applications, services, technologies, and software to assist in managing all aspects of electronic equipment end-of-life management services (the “Services”). Dispoteca obtains Personal Data about you from various sources to provide our Services and to manage our Website. “You” may be a visitor to our Website, or a user of one or more of our Services (“User” or “Client”).

For purposes of this Privacy Statement, “Personal Data” includes the following: first name, last name, username or similar identifier, title, company name, government issued identification number, billing address, shipping address, email address and telephone numbers, bank account, payment card details and credit history, details about payments to and from you and other details of products and services you have purchased from us, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website, your username and password to access the Website, account number, purchases or orders made by you, your interests, preferences, feedback and survey responses, information about how you use our Website, products and services, your preferences in receiving marketing from us and our third parties, and your communication preferences.

2. Processing of Personal Data

Personal Data will be collected, stored, processed, and transmitted in accordance with Dispoteca’s established policies and applicable federal, state, local and international laws, rules, and regulations. Dispoteca will do the following with respect to the processing of Personal Data: (1) Process all Personal Data in a fair and lawful manner, (2) Collect Personal Data for specified, explicit, and legitimate purposes and not process it for incompatible purposes, (3) Collect Personal Data in a manner that is adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) Collect Personal Data that is accurate and keep it up to date to the best of our ability, (5) Protect Personal Data from unauthorized access and processing using appropriate technical and organizational security measures and controls; and (6) Retain Personal Data as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

Although we use appropriate technical and organizational controls to secure and protect your Personal Data, we cannot warrant or guarantee that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.

Dispoteca will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) stored by or for us, in accordance with applicable laws.

If Dispoteca engages in the processing of Personal Data for purposes other than those specified in this Privacy Statement, Dispoteca will provide notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.

3. Collection of Personal Data

Dispoteca may collect Personal Data about you from a variety of sources, including, directly from you, from other users, from resellers and distributors, from our vendors, from our service providers, from third-party information providers, from our affiliates, and through the operation of the Website. We may also obtain Personal Data from publicly available sources such as open government databases or other data in the public domain.

If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

Information about how you access, use, and interact with the Website may be automatically monitored and collected by the Website through “cookies,” “flash cookies”, “web beacons,” and other automated tracking technology. A “cookie” is a small piece of information that is stored on your Device. Cookies are used for record-keeping purposes and allow us to collect information such as browser type, time spent on the Website, and pages visited. For example, Dispoteca can retrieve stored information from its website server when you return to the Website to automate access and data-entry functions of the Website and to personalize your experience. The use of cookies is common in the industry, and they are used at most major websites. You may wish to adjust your Web browser to inform you whenever a cookie is to be used, or to reject all cookies automatically. However, if you elect not to accept cookies, some parts of the Website may not function properly or permit access. For more information on cookies, see http://www.cookiecentral.com/faq.htm.

Please note that the use of cookies or other tracking technologies by Dispoteca’s third-party service providers is not covered by this Privacy Statement. Dispoteca does not have access or control over third-party cookies. Dispoteca’s service providers may use persistent cookies for advertising and retargeting purposes. We may tie the information gathered from third-party cookies to Dispoteca’s users’ Personal Data, and we will use the combined information in accordance with this Privacy Statement.

4. Usage of Personal Data

  1. The Personal Data we collect is used to operate our business and provide you with Services, as well as to improve our Services and personalize your experiences. We may use Personal Data for a variety of purposes (the “Purposes”), including the following:
    • To register you as a new customer or user.
    • To provide, maintain, and improve the Website and our Services, including to operate certain features and functionality of the Website.
    • To understand user preferences to enhance users’ experience with Dispoteca and its contractors and business partners.
    • To research and analyze the effectiveness of the Website and the marketing, advertising, and sales efforts of Dispoteca, its contractors and business partners.
    • To collect account receivables owed by Clients of Dispoteca.
    • To process orders and deliveries and payments made through the Website.
    • To develop additional Services.
    • To process job applications.
    • To comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements).
    • To manage our everyday business needs.
    • To enforce compliance with our Terms and Conditions Agreement and applicable law.
    • To prosecute and/or defend a court, arbitration, or similar legal proceedings.
    • To communicate directly with you by sending you newsletters, surveys, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications by clicking “Unsubscribe” at the bottom of the email or by contacting us using the details below.
    • To communicate directly with you by phone to respond to customer service inquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support.
    • To deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third-party sites, and to tailor ads based on your interests and browsing histories.
    • To monitor and record your call, emails and text messages, social media messages and other communications in relation to your dealings with us.
    • To comply with our contractual or legal obligations to share data with credit reference agencies, fraud prevention agencies and law enforcement agencies.
    • To compile aggregated statistics about the operation and use of our Website and to better understand the preferences of Users and Clients.
    • To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
  2. We may combine and enhance the Personal Data we collect about you with other information we receive from third parties.
  3. We may also use the Personal Data we collect about you through the Website to generate aggregated data that is anonymized so that it is no longer personally identifiable and may not later be used to identify you. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
  4. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  5. The Personal Data that we have collected from you when setting up an account may be shared from time to time with credit reference and fraud prevention agencies who use it to prevent fraud and money laundering and to verify your identity. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide services to you or to allow you to access the Website. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing to you. Fraud prevention agencies can hold your information for different periods of time.

5. Sharing of Personal Data

We share your Personal Data with your consent or as necessary to complete any transaction or provide any Service you have requested or authorized. We also share Personal Data with third-party vendors, resellers and distributors, third-party service providers, Affiliates, and business units, when required by law or to respond to legal process, to protect our customers, to maintain the security of our Services, to protect the rights or property of Dispoteca, or in connection with merger and acquisition discussions.

We may also share aggregated, anonymized data with third parties for other purposes. If we are required under applicable law to treat such information as Personal Data, then we will only disclose it as described above.

Without your consent, Dispoteca will never sell, trade, or disclose your Personal Data to third parties that want to market products to you.

6. International Data Transfers

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

7. Privacy Choices for EEA Residents

If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Data information described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (such as to fulfill your purchase of a Service), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third-party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services and Services to you, and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we collect and use your Personal Data based upon your consent, the consequences of denying or withdrawing consent will be made known at the time your consent is provided.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.

Where required we have implemented the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our Affiliates outside the EEA and United States, which require us to protect Personal Data they process from the EEA in accordance with European Union data protection law. Where required we have implemented similar appropriate safeguards with our third-party service providers and partners and can provide further details upon request.

If you are a resident of the European Union, all the Personal Data related to you and received and stored by Dispoteca are erased after 5 years, save for any Personal Data in documents and files we must keep for a longer period under applicable laws. For example, we cannot erase personal data appearing on VAT invoices before we can delete the invoices from our systems.

If you are a resident of the European Union, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data by contacting us using the contact details provided below. The controller for any Personal Data processed by us is the Dispoteca Affiliate in the European Economic Area country or Switzerland collecting the Personal Data. If you have any questions about the Personal Data you have submitted to the respective affiliate, please contact the relevant affiliate.

8. Privacy Choices for California Residents

California law provides that California residents have a right to request that businesses tell them how their personal information has been shared with third parties for their direct marketing purposes. Under California law, “personal information” includes your name, signature, Social Security number, physical description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s personal information to third parties for direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Data to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your personal information to third parties for direct marketing purposes and thus fall within this exception. To opt-out of the sharing of your personal information to third parties for direct marketing purposes, please contact us using the contact details provided below.

9. Other Important Privacy Information

  • If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided below.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
  • The Website is intended solely for use by individuals 18 years of age and older and thus is not directed to children under 18 years of age. Dispoteca does not knowingly solicit or collect Personal Data from children under 18 years of age.
  • Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your express consent.
  • The Website may include links to other websites and web services. This Privacy Statement does not apply to those websites and services and the privacy practices of those websites and services may differ from those described in this Privacy Statement. If you submit Personal Data to any of those other websites or services, your Personal Data is governed by the privacy policies applicable to those websites and services. Dispoteca encourages you to carefully read the privacy policy of any website or web service you visit.
  • Dispoteca will periodically verify that the Privacy Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.
  • If you believe that your Personal Data has been processed or disclosed in violation of this Privacy Statement, Dispoteca encourages you to raise any concerns using the contact information provided below. Dispoteca will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data.
  • Dispoteca may from time to time revise this Privacy Statement in its sole and absolute discretion to reflect changes in our business practices. If we revise this Privacy Statement, we will notify you by posting the updated Privacy Statement on this Website or by sending you a notification by email. Changes to the Privacy Statement will become effective and will apply to the information collected starting on the date Dispoteca posts the revised Privacy Statement on the Website. If we are required by applicable data protection laws to seek your consent to any changes in use of your Personal Data described in our updated Privacy Statement, then we will do that.

10. Questions and Contact Information

If you have any questions or concerns about this Privacy Statement, the privacy practices of Dispoteca, our collection or use of your Personal Data, or you wish to access your Personal Data, please contact us at [email protected].