Last Modified: December 31, 2019
Where noted in connection with a specific product or service on a DFA Website, there may be additional elements of our privacy practices that are applicable in connection with that product or service (which will be noted on the DFA Website offering that product or service).
WHAT INFORMATION DOES DFA COLLECT FROM YOU?
We collect information through our Websites in several ways. Some of the information we collect is personal to you, primarily information that you provide to us (such as when you become a member or register to receive a communication from us). “Personal Information” means any information that identifies or is capable of identifying you or your household. Other information is anonymous, aggregated or otherwise does not directly identify you. We collect the following categories of information:
- During registration, we ask for your contact information such as name, email address, mailing address, and phone number. If you are a DFA member, we ask for your DFA Member User ID and related password.
- When you report a problem with a DFA Website or service, we will collect contact information along with a description of your problem.
- When you contact us or communicate with us via our website or the company email address, we will collect your contact information and any information you provide to us.
- When you order a product from us we ask for transaction information including your shipping address, phone number, email address and payment information.
- When you ask us for a customized product quote, we collect contact information and information about your product interests.
- When you post a review about one of our products, we will collect your contact information and any information you include in your review.
- When you participate in a promotion or survey, we will collect your contact information and any information you provide to us in connection with the promotion or survey.
- To customize our service for you, we and our business partners may collect precise location data, including the real-time geographic location of your computer or device if you have enabled location services on your device.
- When you visit and navigate our Websites, use our applications or third-party sites, or open our emails, we may collect technical information about your use of our site including IP address, device identifier, and viewing information.
- If you visit our stores, we may collect your name, credit or debit card number, and other information related to payment for goods.
- If you make a consumer complaint, we may collect information provided by you in connection with the complaint.
- When you apply for a job through our Careers page, we may collect information that you submit on an application, including your name, address, phone number, email address, employment history, education level, and demographic information.
HOW DO WE COLLECT INFORMATION FROM YOU?
INDIRECT COLLECTION – COOKIES AND OTHER TECHNOLOGY
- Provide you with personalized content based on your use of our Websites;
- Enable you to more easily use our Websites by remembering and using contact information, purchasing information, and registration information;
- Evaluate, monitor and analyze the use of our Websites and its traffic patterns to help improve our Websites and services; and
- Assist us with ad reporting functions, such as to learn which ads are bringing users to our Websites and which links our users are following.
A “cookie” is a small text file that is placed on your hard drive in order to allow our server to identify your computer. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, a website is able to recognize repeat users, track usage patterns and better serve you when you return to that site. The cookie does not extract other personal information about you, such as your name or address. Most browsers provide a simple procedure that will enable you to control whether you want to receive cookies by notifying you when a website is about to deposit a cookie file.
INDIRECT COLLECTION – THIRD-PARTY ANALYTICS SERVICES
We may employ over time various analytics and marketing services to enable us to track your online behavior, including Google Display Advertising. In some instances, these services may use your IP address or other technology (where you have registered with us) to identify you as a user and match your activity with your member profile in DFA’s customer relationship management system. This tracking enables us to understand your activity across our Websites. We may use this utilization information to market DFA services and products to you but will not share this information with other parties for their marketing purposes.
HOW DO WE USE YOUR INFORMATION?
We use most of the information that is collected through your use of our Websites to improve our Websites and provide you with the best possible experience on our Websites. We use this information to determine which portions of our Websites are of the most interest to our users and how we can change our Websites to improve the experience of our users. In addition, by using the information we collect, we can provide you with an easy to use and readily available forum to purchase products from DFA and its related businesses.
We may also use your personal information to:
- Notify you of other products or services available from DFA;
- Enable you to participate in online transactions;
- Personalize online content so that is applies to you and your interests;
- Provide you with advertising based on your interests and online activities, or other interaction with DFA;
- Make our products, services, and Websites better;
- Compile, analyze and do research on our users’ demographics and behavior
- Detect, investigate and prevent activities that may violate our policies or be illegal;
- Deliver the information, programs, products and/or services you request;
- Evaluate and respond to your inquiries and submissions;
- Provide you with customer support and membership benefits;
- Communicate with you through various channels, including postal mail, email, telephone, applications, online chats, in person, and social media;
- Process your payments and account adjustments;
- Create and manage your membership and account registrations;
- Evaluate and improve our products, services, memberships, benefits, digital services, and other operations (e.g., developing and analyzing new or revised products and services; performing market research and data analytics; creating and applying data models; and assessing the effectiveness of our Websites, applications, communications, advertising, and marketing programs);
- Evaluate your employment applications and contact you regarding potential employment;
- Protect against and prevent fraud and unauthorized transactions, investigate complaints and claims, and provide other security protections;
- Comply with and enforce applicable legal obligations, our policies, and our terms and conditions; and
- Perform other business functions consistent with our mission and serve our membership.
We use and share location data only to provide and improve our service.
WITH WHOM DOES DFA SHARE MY INFORMATION?
We occasionally hire other companies to provide limited services on our behalf, including packaging, delivering, or mailing, website development and operation, sending postal mail or email, analyzing website use, processing payments, and processing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other reason.
DATA IN THE AGGREGATE
We may disclose “blinded” or aggregated data and user statistics to prospective partners and other third parties. Blinded data is data that does not identify an individual person.
We may also ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.
HOW DOES DFA PROTECT FINANCIAL-RELATED INFORMATION?
Keeping your personal financial information private is very important to us. We do not sell information provided by our users, whether financial or otherwise. Financial information may be shared by us in connection with products or services that you have requested. For example, when you make a purchase on our website, we will transfer your credit card number, bank account number or other personal information to the appropriate credit card company or bank in order to process any online payments. Any user statistics that we may provide to prospective partners regarding financial matters are provided in the aggregate only and do not include any personally identifiable information about any individual user. We do not otherwise share financial information about you.
WHAT SECURITY PRECAUTIONS ARE IN PLACE TO PROTECT AGAINST THE LOSS, MISUSE, OR ALTERATION OF MY INFORMATION?
We use administrative, technical, and physical security measures designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite our safeguards, however, no website, application, or information system can ever be completely secure so we cannot guarantee that the use of our systems, Websites, or applications will be completely safe or secure.
Your DFA account information and/or DFA profile is password-protected so that only you (or others that you authorize) have access to this personal information. We use SSL encryption technology for credit card numbers, bank account numbers and passwords. Remember to sign out of your DFA account and close your browser window when you have finished your work. This is to ensure that others cannot access your DFA account by using your computer when you are away from it.
In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
To ensure that you will not receive recurring marketing or other information from us unless you choose to, we will provide you with simple instructions on each marketing email from DFA for you to let us know that you have chosen to stop receiving such emails from us.
WHAT ELSE SHOULD I KNOW ABOUT MY PRIVACY?
Please keep in mind that whenever you voluntarily disclose information online, that information may be accessible to other customers and users. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.
When you or we end your customer relationship with us, we will treat the information we have about you in the same way that we treat the information of existing customers.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you may have certain rights.
ACCESS TO YOUR PERSONAL INFORMATION
You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
DELETION OF YOUR PERSONAL INFORMATION
You may request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Please contact us using the information below.
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here
DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. While the United States Federal Trade Commission has endorsed DNT, our Websites do not support DNT codes. Our Websites limit tracking to the internal uses described above, including in connection with aggregated data. Our Websites do not track your use across multiple websites. However, when we link to other websites not operated by DFA, these other websites may track your activity in different ways. Please review their privacy policies to understand how you may be tracked.
DFA does not directly and knowingly collect personal or non-personal information about or from children under the age of 13 through our Websites nor does DFA utilize any method of acquiring or verifying the age of our Websites visitors. Thus, DFA typically retains no known information about children. DFA does not sell personal information, including of children under 16. However, if a parent requests a review of information their child may have submitted, then DFA will make every reasonable effort to honor that request. In order to request a review or deletion of personal information your child may have submitted to dfamilk.com, please contact us using the information below. DFA is not responsible for the privacy practice of and use of children’s personal information by websites that DFA doesn’t operate and this policy does not apply to those linked sites.
Effective Date: January 1, 2020