Data Collected

2.1. Experts and Registration for a Directly Account. We collect Personal Data in different ways depending on the circumstances of your use of our Services and the choices you make about the Data you submit to us. You can visit directly.com and certain subdomains without registering, but to become an authorized Expert eligible to submit Expert Content, you will need to create an account with Directly (“Directly Account”) and submit the following types of Personal Data: legal name, email address and/or mobile phone number, a personal headshot photo, physical mailing address, birthdate, verification phone number and government identification (“Expert Registration Information”). As an Expert, you must also select your username, sometimes referred to on our platform as your “alter ego”. The default setting for the username is your first name and last initial, unless that username is already taken. You also have the option to change your username. Please read our current guidelines on the Expert User Hub as there are rules and privacy consequences for your username selection. Generally, we recommend that Experts do not use their full legal name, which could be used to identify them, or use a fanciful, misleading or inappropriate username. Experts also have the option to create user profiles describing why they should be considered Experts, as well as their top skills and language abilities. We use elements of the Expert Registration Information to verify your identity, combat fraud and keep our Services, Experts, Customers and partners secure. By registering for a Directly account, you authorize us and/or our Third-Party Providers (as described below) to verify Expert Registration Information, including your identity.

As described in our Terms, Directly or Customers may impose additional terms and duties for your eligibility (“Supplemental Terms”). You will be given an opportunity to review and consent to such Supplemental Terms. For example, where a Customer or applicable data protection law requires special expert certification measures, and subject to your consent, Experts may be asked to provide additional Personal Data relating to professional background, location of access or residence.

2.2. Log and Usage Information. We also collect other types of Data, which may be construed as Personal Data in certain jurisdictions, including the following: website usage information such as how you have used our Services, IP address and other technical data such as browser type, unique device identifiers and information, language preference, referring site and the date and time of access, operating system and mobile network information; approximate location data (from IP address); information regarding interactions with directly.com, such as votes on Expert Content, feedback, comments, poll responses and other information you may provide such as contact form submissions or other information you provide us.

2.3. Cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes such as site visitation. We use first party and third-party cookies for several different purposes. Some cookies are required for technical reasons to operate our Services. Other cookies enable us to track and target the interests of our users to enhance the experience of our Services. For example, Directly uses first-party cookies to keep track of the specific directly.com webpages or Services you visit to determine which are the most popular or most used. Third parties serve third-party cookies through our website for advertising, analytics and other purposes. These third parties may use information about your visits to directly.com and other websites to provide relevant advertisements about goods and services that may be of interest to you. They may also employ technology that is used to measure the effectiveness of advertisements. Information about cookies is available at https://www.aboutcookies.org. Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences. Please note that if you choose to block cookies, doing so may impair the Services or prevent certain elements of them from functioning. On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt Out of Interest-Based Ads” (on Android), which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

2.4. Data Collected by Third Parties. We also may process Data and Personal Data that certain third-party providers (each a “Third-Party Provider”) collect from you to update or supplement the Data and Personal Data you provide, or we collect automatically. Third party services provide us with information needed for core aspects of the Services. If you access our Services from a Third-Party Provider in connection with services such as the Apple App Store, Google Play, Salesforce App Store or another third-party app platform, you are subject to the privacy policies of the respective provider. Our Services and associated technology also enable one or more Third-Party Providers of analytic services (e.g., Google Analytics) to collect this type of information (such as device identifiers) so we can analyze how our Services are used. (We may also link with certain Third-Party Providers, such as Jumio, who link from our Service and collect personal data subject to its separate terms and privacy policy.) All Data and Personal Data collected by Third-Party Providers are governed by the respective provider’s terms of service and privacy policy.

3. Use and Retention

3.1. Personal Data Use. We and our Third-Party Providers use Personal Data to: (i) provide our Services; (ii) promote, analyze and improve our Services; (iii) comply with applicable law and (iv) detect and prevent fraud, harmful or abusive conduct, or other harm to Experts, Customers, Directly and third parties. Some examples of how we may use Personal Data include:

Creating your Directly Account,

Identifying you on our system, and verifying your actual identity and Registration Information, to ensure the security of our Services and enable you to send or respond to certain routed Tasks;

Responding to your inquiries to administer and improve our website and Services:

Informing the applicable Customer of your relevant activity on the Services:

Providing technical support and respond to inquiries by Experts and Customers:

Soliciting input and feedback to improve and customize your Expert experience:

Informing you about new features, services and programs on the Services“

Customizing your use of the Services and/or content, or other material that we may send to you from time to time:

Conducting aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions and improve and report on the performance of our Services and business:

For audits, regulatory purposes or compliance with industry standards:

Preventing or taking action against activities that are, or may be, in breach of our Terms, Privacy Policy or applicable law, including combating fraud: and

For any other purpose, provided we disclose this to you at the relevant time, and provided that you agree to the proposed use of your Personal Data.

3.2. Retention. Where Directly is processing and using your Personal Data, as permitted by law or under your consent, we will store your Personal Data (i) only for as long as is required to fulfil the purposes set out below; (ii) until you object to Directly’s use of your Personal Data (where Directly has a legitimate interest in using your Personal Data): or (iii) until you withdraw your consent (where you consented to Directly using your Personal Data). However, where Directly is required by law to retain your Personal Data longer, or where your Personal Data is required for Directly to assert its legal rights or defend against legal claims, we will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled. Please note that we have a variety of obligations to retain Personal Data and Other Data you provide to us, including to ensure that rewards and associated payments can be appropriately processed consistent with applicable law and our legal obligations. Accordingly, even if you close your Directly Account, we may retain certain data to meet our obligations.

4.1. General. Directly does not sell or rent your Personal Data. We share Personal Data collected by Directly with Third-Party Providers only in limited circumstances, including: (i) with your consent; (ii) to an authorized Third-Party Provider who meets our data protection standards; or (iii) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process, or to enforce our Terms.

4.2. Third-Party Providers. We share data with certain Third-Party Providers who help us provide the Services. For example, certain Third-Party Providers help us with such activities as web hosting and data analysis. Currently, we use Amazon for hardware, software, networking and storage services which are necessary to operate our website and Services. We also reserve the right to share Personal Data with Third-Party Providers, such as merchants (e.g., PayPal), application providers (e.g., Lessonly), and identity verification providers (e.g. Jumio) as necessary to process payments, qualify Experts and provide Services. Except as otherwise stated in this Privacy Policy, such Third-Party Providers are prohibited from using Personal Data other than to provide the services specified under written contract by Directly and for no other purposes. Subject to the foregoing, you expressly consent to the sharing of your Personal Data and Other Data with these Third-Party Providers for these limited purposes.

4.3. Third Party Acquirer. If we merge with another company such that your Personal Data and Other Data will become subject to a materially different privacy policy, we will notify you before the transfer. You can opt out of any new policy by deleting your account during the notice period.

4.4. Experts. We disclose certain limited content of each request for Answers (e.g., non-personally identifiable usernames or first names of Experts). We also share Other Data with Experts about their responses to Answers and the generation of Expert Content.

4.5. Customers and Customer End Users. We disclose the content of the responses to Answers (including the first name of the Expert who responded) to the Customer who generated the request for Answers (and to any subsequent Customer End Users that pose similar requests). When an Expert responds to requests for Answers by Customer End User posted via the Services, certain limited and filtered Data contained in the Answer, such as your username, the text of the response to the Answer and other Personal Data (such as an Expert’s headshot or picture) will be accessible to Customers and Customer End Users. You understand and agree to the sharing of Data.

4.6. Usage Data. Directly will not use or disclose (except as expressly provided herein) the personal data of Experts, except to provide the Services as specified herein, but, except where prohibited by applicable law or legal duty, may use and disclose data about usage of the Services that does not identify or reasonably could be anticipated to be used to identify any individual user of the Services or otherwise constitute Personal Data (“Usage Data”). We share Usage Data about our Website and Services with our business partners. We reserve the right to use and disclose Usage Data for any purpose and to any third parties subject to the terms herein.

4.7. Future Affiliates. Although we currently do not have a parent company, any subsidiaries, joint ventures or other companies under a common control (collectively, “Affiliates”), we may in the future. We may share some or all of your Personal Data with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company or our assets, including pursuant to a bankruptcy or similar proceeding, that company will possess the Personal Data collected and stored by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

4.8. Legal Disclosures. We reserve the right to disclose your Other Data and Personal Data as required by law, in connection with any legal investigation, when we believe that disclosure is necessary to protect our rights (or those of other Users or third parties) and/or to comply with a judicial proceeding, court order, warrant, subpoena or legal process served on us.

4.9. Communications. Services/Services-related Announcements. We will send you services-related announcements when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email or other communications. App Notifications. We may send you notifications on your mobile device. You may disable these notifications in the settings of your device. Customer Service. Based upon the Personal Data you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your Directly Account. We will communicate with you by email or telephone, in accordance with your indicated preferences.

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Data Collected

3. Use and Retention