privacy policy
Last Updated: August 1 , 2024
Introduction
This Privacy Policy explains how Dream Aspect LLC ("we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with our website, dreamaspect.co (the "Site"), and the marketing and advertising services we provide to our business clients (collectively, the "Services").
This Policy is designed to help you understand your privacy rights, particularly if you are a resident of California, and to provide you with the information required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").
The Personal Information We Collect and How We Use It
*** Using a table is the clearest and most effective way to present this information. You MUST customize the examples, sources, purposes, and retention periods in this table to accurately reflect your agency's specific operations. The information here should be a direct output of your internal data mapping exercise.]*
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). The table below outlines the categories of personal information we have collected over the past 12 months.
Table 2: Categories of Personal Information We Collect and Process
Category of Personal Information
Examples (What we collect)
Sources (Where we get it)
Business or Commercial Purpose(s)
Data Retention Period
Identifiers
Name, email address, postal address, telephone number, online identifiers (e.g., cookie IDs, mobile ad IDs, pixel tags), Internet Protocol (IP) address.
Directly from you (e.g., when you fill out a form); From your browser or device when you visit our Site; From our business clients; From third-party data providers.
To provide and manage our Services; To communicate with you; For marketing and advertising on behalf of our clients; To personalize your experience on our Site; For security and fraud prevention.
For the duration of our relationship with you or our client, plus a period of [e.g., 24 months] for record-keeping, or as long as necessary for security logs.
Internet or Other Electronic Network Activity Information
Browsing history, search history, and information regarding your interaction with our Site, our clients' websites, or advertisements we manage.
From your browser or device when you interact with our Site or our ads.
To provide our Services, particularly analytics and advertising; To measure campaign performance; To improve our Site and Services; For debugging and security.
Session data is deleted after the session. Other analytics data is retained for [e.g., 26 months] from your last interaction.
Geolocation Data
General location derived from your IP address. Precise geolocation (if you grant permission on a mobile device).
From your browser or device.
To provide localized content or advertising; For analytics to understand our audience distribution.
General location data is retained with other analytics data for [e.g., 26 months]. Precise geolocation is not stored after use unless necessary for a specific service, in which case it is retained for [e.g., 48 hours].
Commercial Information
Records of services purchased or considered from us or our clients.
Directly from you; From our business clients.
To fulfill transactions; To provide client services and support; For internal record-keeping and analytics.
Retained for the duration of the client relationship plus any legally required period (e.g., 7 years for financial records).
Inferences Drawn from Other Personal Information
Profiles reflecting an individual's preferences, characteristics, or behaviors, used to create audience segments for advertising (e.g., "interested in outdoor gear").
Created by us or our partners based on the other information we collect.
To provide our Services, specifically for creating targeted advertising campaigns on behalf of our clients.
Inferred profiles are refreshed or deleted when the underlying data is deleted according to its retention period.
Sensitive Personal Information (SPI)
** For example: Account log-in credentials for our client portal.
Directly from you when you register for an account.
To provide secure access to our Services.
Retained for as long as you maintain an account with us.
We do not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.
Our Disclosure, Sale, and Sharing of Personal Information
*** You must be precise. "Disclosing for a business purpose" refers to sharing with your Service Providers. "Selling" or "Sharing" refers to disclosing to Third Parties, particularly for cross-context behavioral advertising. Be honest and transparent here, as this is a key enforcement area.]*
We may disclose your personal information to a third party for a business purpose, or "sell" or "share" your personal information, subject to your right to opt out.
Disclosures for a Business Purpose In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the following categories of recipients:
Table 3: Disclosure of Personal Information for Business Purposes
Category of Personal Information
Categories of Recipients (Our Service Providers)
Identifiers
Cloud Hosting Providers; Analytics Providers; Payment Processors; CRM and Email Marketing Platforms; Security Service Providers.
Internet or Other Electronic Network Activity
Cloud Hosting Providers; Analytics Providers; Security Service Providers.
Commercial Information
Payment Processors; CRM Platforms.
Geolocation Data
Cloud Hosting Providers; Analytics Providers.
We only disclose information to these service providers pursuant to a written contract that requires them to use the data only for the specified purpose and to maintain its confidentiality and security.
Sale or Sharing of Personal Information The CCPA defines "sharing" as disclosing personal information for cross-context behavioral advertising. When we use advertising services to deliver interest-based ads to you on other websites, this may be considered "sharing" under the law.
In the preceding 12 months, we have "shared" the following categories of personal information with the following categories of third parties:
Table 4: Sale or Sharing of Personal Information
Category of Personal Information
Categories of Third Parties
Purpose of Sale/Sharing
Identifiers (e.g., Cookie ID, IP Address)
Advertising Networks; Social Media Platforms.
To facilitate cross-context behavioral advertising and measure ad performance.
Internet or Other Electronic Network Activity
Advertising Networks; Social Media Platforms.
To facilitate cross-context behavioral advertising and measure ad performance.
Inferences
Advertising Networks; Social Media Platforms.
To create audience segments for targeted advertising.
You have the right to opt out of this sale or sharing of your personal information at any time.
Your California Privacy Rights
*** Use clear headings for each right to make the section easy to navigate.]*
If you are a California resident, you have the following rights regarding your personal information:
- The Right to Know and Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
- The Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- The Right to Correct. You have the right to request that we correct any inaccurate personal information that we maintain about you.
- The Right to Opt-Out of Sale or Sharing. You have the right to direct us not to sell or share your personal information.
- The Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected.
- The Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
How to Exercise Your Rights
To exercise your right to opt-out of the sale or sharing of your personal information, or to limit the use of your sensitive personal information, please email us at [privacy@dreamaspect.co] with the corresponding subject:
- Do Not Sell or Share My Personal Information
- Limit the Use of My Sensitive Personal Information
We also recognize and process the Global Privacy Control (GPC) signal as a valid request to opt out of the sale and sharing of your personal information. If your browser or browser extension has GPC enabled, you will be automatically opted out of the sale and sharing of your data via cookies and tracking technologies on our Site.
Verification Process. Only you, or a person legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To verify your identity, we may ask you to provide 2-3 pieces of personal information that we can match against our records. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Data Security and Retention
[Annotation: Here, you describe your commitment to security and your retention policy. You don't need to detail your entire security architecture, but you should describe the types of measures you take (e.g., technical, administrative). The retention statement should align with the table in the "Information We Collect" section.]
We have implemented and maintain reasonable administrative, technical, and physical security measures to protect the personal information we process from unauthorized access, destruction, use, modification, or disclosure.
We retain personal information for as long as is reasonably necessary and proportionate to achieve the purposes for which it was collected, as described in this Policy, or to comply with our legal obligations. Please see Table 2 for more details on our retention periods for specific categories of personal information.
Information Concerning Children
Our Site and Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without verification of parental consent, we will take steps to delete that information. We do not sell or share the personal information of consumers we know to be less than 16 years of age.
Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Site and update the policy's "Last Updated" date.
Contact Us
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: [privacy@dreamaspect.co]
