1. Introduction
This Privacy Policy describes how DLM Digital LLC (“we,” “us,” or “our”) collects, uses, and discloses your
personal information when you use our mobile application (the “Service”).
We are committed to protecting your personal information and your right to privacy. When you visit our
mobile application and use our products, you trust us with your personal information. We take your privacy
very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information
we collect, how we use it, and what rights you have in relation to it.
This Privacy Policy applies to all information collected through our mobile application, as well as any related
services, sales, marketing, or events.
Please read this Privacy Policy carefully as it will help you understand what we do with the information we
collect.
2. Definitions
- To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced,
- they are strictly defined as:
- Cookie: a small file placed on your device to enable certain features and functionality.
- Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to DLM Digital LLC.
- Country: where DLM Digital LLC or the owners/founders of DLM Digital LLC are based, in this case
- United States.
- Customer: refers to the company, organization, or person that signs up to use the DLM Digital LLC
- Service.
- Device: any internet-connected device such as a phone, tablet, computer, or any other device that can
- be used to visit DLM Digital LLC and use the services.
- Personal Data: any information that directly, indirectly, or in connection with other information allows
- for the identification of a natural person.
- Service: refers to the mobile application provided by DLM Digital LLC as described in the relative terms
- and on this platform.
- Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and
- others who provide our content or whose products or services we think may interest you.
- Website: DLM Digital LLC’s site, which can be accessed via https://dlmdigital.io/.
- You: a person or entity that is registered with DLM Digital LLC to use the Services.
3. Information we collect
We collect limited information necessary to provide and improve our Service to you.
Please note: We do not collect or store any biometric or facial recognition data. All biometric processing is
performed locally on your device and no such data is transmitted or retained by us.
4. How We Use Your Information
- DLM Digital LLC uses the collected data for various purposes:
- To enable on-device machine learning models to process biometric data locally
- To notify you about changes in the app
- To gather analysis or valuable information so that we can improve our Service
- To detect, prevent and address technical issues
- To fulfill any other purpose for which you provide it
- In any other way we may describe when you provide the information
- For any other purpose with your consent
5. Retention of Your Personal Data
We do not collect, store, or retain any personal, biometric, or facial recognition data. All biometric data
processing occurs locally and temporarily on your device during app use and is not transmitted, saved, or
shared with us or any third parties. As such, no biometric or facial data is retained by DLM Digital LLC at any
time.
6. Transfer of Your Personal Data
DLM Digital LLC does not transfer or share your Personal Data to any third parties or across jurisdictions. All
Personal Data you provide is processed and stored within the United States on your own system.
We take all reasonable steps to ensure that your data is handled securely and in accordance with this Privacy
Policy. No transfer of your Personal Data to organizations or countries outside the United States occurs.
7. Use of Artificial Intelligence and Local Processing
DLM Digital LLC utilizes on-device machine learning models to process photos and perform biometric
functions such as facial recognition. All AI processing occurs locally on your device, ensuring that your photos
and biometric data are not transmitted, stored, or shared externally.
This local processing approach enhances your privacy and security by keeping sensitive data confined to your
device and under your control at all times.
8. Third-Party Disclosure
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of our Service. This data is
shared with other Google services. Google may use the collected data to contextualize and personalize
the ads of its own advertising network. You can opt-out of having made your activity on the Service
available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on
prevents the Google Analytics JavaScript from sharing information with Google Analytics about visits
activity. For more information on the privacy practices of Google, please visit the Google Privacy &
Terms web page: https://policies.google.com/privacy
9. Security of Your Personal Data
The security of your Personal Data is important to us. However, please note that no transmission of personal,
biometric, or facial recognition data occurs from your device to our servers or any third parties. All such data
processing happens locally on your device.
While we strive to use commercially acceptable means to protect any Personal Data you provide, no method
of transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee
absolute security, but by ensuring that sensitive data never leaves your device, we significantly reduce
potential risks.
10. Children’s Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable
information from anyone under the age of 13. If you are a parent or guardian and you are aware that your
child has provided us with Personal Data, please contact us. If we become aware that we have collected
Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to
remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires
consent from a parent, we may require your parent’s consent before we collect and use that information.
11. Your Data Protection Rights
Depending on your location and applicable laws, you may have certain rights regarding your personal
information, including rights to access, correct, delete, or restrict use of your information. We honor these
rights regardless of your location and are committed to providing reasonable access to the information that
you have shared with us.
12.1 General Data Access & Deletion Rights
Regardless of your location, you can make the following requests regarding your personal data:
Access Your Data: You can request a copy of the personal information we have about you. We will
provide this information in a structured, commonly used, and machine-readable format.
Delete Your Data: You can request that we delete your personal information from our systems. We will
comply with this request unless there is a legal requirement for us to keep certain information.
To submit a data access or deletion request, please contact us using the contact information provided at the
end of this Privacy Policy. We will respond to your request within 30 days. We may need to verify your identity
before processing your request.
12.3 CCPA Privacy Rights (California Residents)
If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your
data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask
us:
What personal information we have about you. If you make this request, we will return to you:
The categories of personal information we have collected about you
The categories of sources from which we collect your personal information
The business or commercial purpose for collecting or selling your personal information
The categories of third parties with whom we share personal information
The specific pieces of personal information we have collected about you
A list of categories of personal information that we have sold, along with the category of any
other company we sold it to
A list of categories of personal information that we have disclosed for a business purpose, along
with the category of any other company we shared it with
To delete your personal information. If you make this request, we will delete the personal
information we hold about you as of the date of your request from our records and direct any service
providers to do the same. In some cases, deletion may be accomplished through de-identification of
the information. If you choose to delete your personal information, you may not be able to use certain
functions that require your personal information to operate.
To stop selling your personal information. We don’t sell or rent your personal information to any
third parties for any purpose. We do not sell your personal information for monetary consideration.
However, under some state laws, sharing your data through certain targeted advertisements may be
considered a “sale” of information. You are the only owner of your Personal Data and can request
disclosure or deletion at any time.
We will respond to verified requests within 45 days as required by the CCPA. If we need more time, we will
inform you of the reason and extension period in writing.
Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you
may not be able to participate in certain programs or membership services which require the usage of your
personal information to function. But in no circumstances, we will discriminate against you for exercising your
rights.
To exercise your California data protection rights described above, please send your request(s) by email:
support@dlmdigital.io.
Your data protection rights, described above, are covered by the CCPA, short for the California Consumer
Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect
on 01/01/2020.
12. service providers
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to
provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our
Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are
obligated not to disclose or use it for any other purpose.
13. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you
will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you
visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any
third party sites or services.
14. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new
Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming
effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are
effective when they are posted on this page.
15. Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: support@dlmdigital.io
By visiting this page on our website: https://dlmdigital.io/contact/
By mail: 4539 N 22ND ST PHOENIX, AZ, 85016, USA
