This Privacy Policy explains how Direct Access Group LLC ("Direct Access Group," "we," "us" or "our") collects, uses, discloses and protects personal information in connection with this website (the "Website") and the business inquiries made through it. It also explains the choices and rights available to you. This Policy should be read together with our Terms of Service.
1. Who We Are and Scope
Direct Access Group LLC is a limited liability company organized under the laws of the State of Florida, with its principal place of business at 3650 NW 115th Avenue, Doral, FL 33178, United States. For the purposes of this Policy, Direct Access Group is the business responsible for (the "controller" of) personal information collected through the Website.
This Policy applies to personal information collected through the Website and through communications that follow from a Website inquiry. It does not apply to: (a) information we process on behalf of customers or partners under a separate written agreement, which is governed by that agreement; (b) information about our employees, contractors and job applicants, which is covered by separate notices; or (c) third-party websites or services that link to or from the Website.
The Website is intended for business-to-business use. Most information we receive relates to individuals acting on behalf of a business or organization.
2. Information We Collect
2.1 Information you provide to us. When you submit an inquiry or otherwise contact us, we collect the information you choose to provide, which may include:
- Identifiers and contact details: your full name, email address and, if you choose to provide it, your telephone number;
- Professional information: the name of your company or organization and your role;
- Inquiry details: the inquiry type you select and the content of your message, along with any further information you share in later correspondence.
2.2 Information collected automatically. When you visit the Website, our hosting, content delivery and security providers automatically record limited technical information in server and security logs, which may include your Internet Protocol (IP) address, browser type and version, device and operating system type, the referring web page, the pages requested, and the date and time of each request. We use this information to deliver the Website, keep it secure, prevent abuse and diagnose technical problems.
2.3 Information from other sources. If you or your organization pursue a business relationship with us, we may collect business contact information and information about your organization from publicly available sources, business references, our partners, and sanctions-screening, export-compliance, credit and due diligence providers, as permitted by law.
2.4 Information we do not request. We do not ask for, and you should not send us through the Website, Social Security numbers, driver's license, passport or other government identification numbers, financial account or payment card numbers, passwords, health or medical information, biometric data, precise geolocation, or information about racial or ethnic origin, religious beliefs, sexual orientation or other sensitive characteristics. If you send us such information, we may delete it.
3. How We Use Personal Information
We use personal information for the following purposes:
- Responding to inquiries: to review your inquiry, route it to the appropriate person within the group, respond to you and carry on the business discussion that follows;
- Business relationships: to evaluate, establish, manage and perform supply, distribution, sourcing, partnership, investment and other commercial relationships;
- Compliance and due diligence: to conduct identity, beneficial ownership, sanctions, export control, anti-corruption, anti-money laundering and reputational screening, and to keep records required by law;
- Security and fraud prevention: to protect the Website, our systems, our business and others; to detect, investigate and prevent spam, abuse, fraud, security incidents and other harmful or unlawful activity; and to enforce our Terms of Service;
- Operating and improving the Website: to host, maintain, troubleshoot and improve the Website and its accessibility;
- Legal purposes: to comply with applicable laws, regulations, legal process and lawful requests by public authorities; to establish, exercise or defend legal claims; and to protect the rights, property and safety of Direct Access Group, our partners and others;
- Corporate transactions: in connection with a merger, acquisition, financing, reorganization, sale of assets or similar transaction, subject to appropriate confidentiality protections.
We do not use personal information collected through the Website for targeted advertising, and we do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
4. Legal Bases for Processing (Visitors from the EEA, United Kingdom and Similar Jurisdictions)
If data protection laws such as the EU or UK General Data Protection Regulation apply to our processing of your personal information, we rely on the following legal bases: (a) steps at your request before entering into a contract, and performance of a contract, when we respond to your inquiry and manage a business relationship; (b) our legitimate interests in operating our business, responding to business inquiries, maintaining security and preventing fraud, where those interests are not overridden by your rights; (c) compliance with legal obligations, such as sanctions, export control, tax and record-keeping requirements; and (d) your consent, where we ask for it, which you may withdraw at any time without affecting processing that took place before withdrawal.
5. How We Disclose Personal Information
We disclose personal information only as described below:
- Service providers: to vendors that provide services to us, such as website hosting, content delivery, database, email delivery, IT support, security and compliance-screening services, under contracts that limit their use of the information to providing those services to us and require them to protect it;
- Affiliates: to companies under common ownership or control with Direct Access Group, where needed to respond to your inquiry or manage a business relationship, subject to this Policy;
- Professional advisers: to our lawyers, accountants, auditors, insurers and banks, under duties of confidentiality;
- Legal and safety: to government authorities, courts, regulators, law enforcement or other third parties where we believe disclosure is required by law or legal process, or is necessary to protect the rights, property or safety of Direct Access Group, our partners or others, or to investigate fraud, security incidents or violations of our Terms;
- Corporate transactions: to a buyer, successor, investor or other party in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy or sale of all or part of our business or assets;
- With your direction or consent: to other parties when you ask us to or agree that we may.
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising. We have not done so in the preceding twelve months. We do not sell sensitive personal data or biometric personal data.
6. Cookies, Local Storage and Similar Technologies
The Website does not use advertising cookies, third-party analytics, tracking pixels, session-replay tools or similar tracking technologies. We use only technologies that are strictly necessary to deliver and secure the Website, such as security and load-balancing functions operated by our hosting provider, and, where a page needs to remember a setting during your visit, your browser's local storage. These technologies do not track you across other websites.
If we decide to introduce analytics or other non-essential technologies in the future, we will update this Policy before doing so and, where required by law, ask for your consent.
Global Privacy Control and Do Not Track. Because we do not sell or share personal information or engage in targeted advertising, there is nothing for an opt-out signal to switch off. We nonetheless treat a Global Privacy Control signal received from your browser as a valid request to opt out of any sale or sharing of personal information associated with that browser. There is no common industry standard for "Do Not Track" signals, and the Website does not change its behavior in response to them.
7. Communications and Marketing
We use your contact details to respond to your inquiry and to conduct the business relationship that follows. We do not send marketing emails unless you have asked to receive them, and every marketing email we send will identify us, include our physical address and contain a working unsubscribe mechanism, consistent with the CAN-SPAM Act.
We do not make telephone solicitations, and we do not send marketing text messages or make marketing calls using an automated telephone dialing system or an artificial or prerecorded voice. Providing your telephone number does not constitute consent to receive such communications. If we ever ask for consent to send marketing messages, we will do so separately and expressly, consistent with the Telephone Consumer Protection Act and the Florida Telephone Solicitation Act, and you may withdraw consent at any time by replying "STOP" or contacting us.
8. How Long We Keep Personal Information
We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including to meet legal, regulatory, tax, accounting and reporting requirements and to resolve disputes. In general:
- Inquiries that do not result in a business relationship are kept for up to 24 months after our last communication with you, then deleted;
- Records of business relationships, including related correspondence and due diligence records, are kept for the duration of the relationship and for as long afterward as required or permitted by law, which may be five (5) years or longer where export control, sanctions, tax or other record-keeping laws require it;
- Server and security logs are kept for up to 90 days, unless needed longer to investigate a security incident or abuse.
When personal information is no longer needed, we delete it or de-identify it so that it can no longer be associated with you, using methods appropriate to the medium on which it is stored.
9. How We Protect Personal Information
We maintain reasonable administrative, technical and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration and destruction, appropriate to the nature of the information and the risks involved. These measures include encryption of data in transit using Transport Layer Security (TLS), restricted access on a need-to-know basis, multi-factor authentication on administrative accounts, security monitoring and logging, server-side validation and anti-abuse controls on our inquiry form, and the use of service providers that maintain recognized security programs.
No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach of security affecting personal information, we will notify affected individuals and regulators as required by applicable law, including the Florida Information Protection Act of 2014 (Fla. Stat. § 501.171), which generally requires notice to affected Florida residents no later than 30 days after a breach is determined.
10. Your Privacy Choices and Rights
10.1 Rights available to everyone. Regardless of where you live, you may ask us to:
- confirm whether we hold personal information about you, and provide a copy of it;
- correct personal information that is inaccurate or incomplete;
- delete personal information we hold about you;
- stop sending you any marketing communications.
We will honor these requests unless an exception applies, for example where we must keep information to comply with a legal obligation, to complete a transaction you requested, to detect and prevent security incidents or fraud, or to establish, exercise or defend legal claims.
10.2 Florida residents. Florida's comprehensive consumer privacy law, the Florida Digital Bill of Rights (Fla. Stat. § 501.701 et seq.), applies only to a limited group of very large businesses. Whether or not it applies to us, we extend to Florida residents the access, correction and deletion choices described in Section 10.1, and we confirm that we do not sell personal data, sensitive personal data or biometric personal data, and do not process personal data for targeted advertising.
10.3 Residents of other U.S. states. Residents of certain states, including California, Colorado, Connecticut, Virginia, Texas, Oregon and others, may have additional rights under their state's privacy laws where those laws apply to us, such as the right to know the categories of personal information collected and disclosed, the right to data portability, the right to opt out of sale, sharing, targeted advertising and certain profiling, and the right to limit use of sensitive personal information. Where those laws apply, we will honor these rights as required. We will not discriminate or retaliate against you for exercising any privacy right.
10.4 Individuals in the EEA, United Kingdom and similar jurisdictions. Where applicable law grants them, you also have the right to restrict or object to our processing, to data portability, to withdraw consent at any time, and to lodge a complaint with your local data protection authority.
10.5 How to make a request. To exercise any right, email info@directaccessgroup.net or write to us at the address in Section 15. Please describe your request and tell us how to reach you. To protect your information, we will take reasonable steps to verify your identity before acting on a request, which may include asking you to confirm information we already hold. You may use an authorized agent to make a request on your behalf where the law permits; we may require the agent to provide proof of authorization and may ask you to verify your identity directly.
We will respond within forty-five (45) days of receiving a verifiable request. Where permitted by law, we may extend this period once by an additional forty-five (45) days when reasonably necessary, and we will tell you if we do. If we decline your request, we will explain why, and, where your state's law provides one, you may appeal our decision by replying to our response with the subject line "Privacy Appeal." We will respond to an appeal within the time required by law.
11. International Visitors and Data Transfers
Direct Access Group is based in the United States, and the Website is hosted and operated from the United States and other locations where our service providers operate. If you access the Website or contact us from outside the United States, including from the Caribbean, Latin America, the European Economic Area or the United Kingdom, your personal information will be transferred to, stored in and processed in the United States and other countries whose data protection laws may differ from those of your country. Where required by applicable law, we put appropriate safeguards in place for such transfers, such as standard contractual clauses approved by the relevant authorities.
12. Children's Privacy
The Website is intended for business use and is not directed to children. We do not knowingly collect personal information from children under the age of 16, and we do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act. If you believe a child has provided us with personal information, please contact us and we will delete it.
13. Third-Party Websites and Services
The Website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to them. We encourage you to read their privacy policies.
14. Changes to This Policy
We review this Policy at least once a year and may update it from time to time. When we do, we will revise the "Last updated" date at the top of this page. If we make material changes to how we collect, use or disclose personal information, we will provide a more prominent notice, such as a notice on the Website, before the change takes effect and, where required by law, seek your consent.
15. Contact Us
If you have any questions about this Policy or our privacy practices, or wish to exercise a privacy right, please contact:
Direct Access Group LLC
Attention: Privacy
3650 NW 115th Avenue, Doral, FL 33178, United States
Email: info@directaccessgroup.net