DRRT Privacy Policy

September 4, 2024

Alexander Reus, P.A. d/b/a DRRT (“Company” or “DRRT” or “we” or “us” or “our”) are committed to protecting the privacy of our clients, potential clients, and users of our website located at www.drrt.com (“you”). (Please note that our website also includes other media forms, media channels, mobile website or mobile application-related or connected thereto, which, along with www.drrt.com are collectively referred to hereafter as “Website”). The following Company privacy policy (“Privacy Policy”) explains the types of information that we may gather about or collect from you in connection with our services and/or your use of our Website and describes the conditions under which we use and disclose that information, and your rights in relation to that information.

By communicating with us and using our services, including the access of our Website from another jurisdiction, you consent to the transfer of your personal information into the United States. You also agree to abide by U.S. federal and state law, as the case may be, concerning your use of our Website and any related agreements. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the United States may only use the Website in a manner lawful in their jurisdiction. It is the sole responsibility of the user to determine whether use of the Website is lawful in the particular jurisdiction where the user may be found. If your use of the Website would be unlawful in your jurisdiction, we recommend that you do not use the Website, and we disclaim any and all liability stemming from your unlawful use of the Website.

TYPES OF DATA COLLECTED

DRRT may gather or collect from you two types of data in connection with your use of our services or Website, namely “Non-Personally Identifying Information” and “Personally Identifying Information.”

“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific natural person.

“Personally Identifying Information” is any information that without additional information can be, directly or indirectly, associated with a particular natural person, such as a name, an identification number, location data, an online identifier or information specific identifying the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

BY USING OUR SERVICES OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE TERMS AND CONDITIONS DESCRIBED IN THIS PRIVACY POLICY.

COLLECTION, USE AND DISCLOSURE OF NON-PERSONALLY IDENTIFYING INFORMATION

 Collection and Use of “Non-Personally Identifying Information”

Like most website operators, we gather from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally Identifying Information, it may be possible for us to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. We analyze Non- Personally Identifying Information gathered from users of the Website to help us better understand how the Website is being used. By identifying patterns and trends in usage, we are able to better design the Website to improve users’ experiences, both in terms of content and ease of use.

Cookies

A “Cookie” is a string of information that assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. We also use Cookies to track the pages that users visit during each Website session, both to help us improve users’ experiences and to help us understand how the Website is being used. As with other Non-Personally Identifying Information gathered from users of the Website, we analyze and disclose, in aggregated form, information gathered using Cookies, so as to help us, our partners and others better understand how the Website is being used. WEBSITE USERS WHO DO NOT WISH TO HAVE COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF COOKIES. WEBSITE USERS WHO REFUSE COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

 A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique we may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Cookies or modifying your browser setting to notify you each time a Cookie is tendered, permitting you to accept or decline Cookies on an individual basis.

Analytics

 We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/). We may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how you interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.

Aggregated and Non-Personally Identifying Information

 We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances, including, without limitation, sharing it with third parties and our affiliate companies. We may combine Non-Personally Identifying Information we collect with additional Non- Personally Identifying Information collected from other sources. We also may share aggregated information with third parties for the purpose of conducting general business analysis. This information does not contain any Personally Identifying Information, and may be used to develop website content and services that we hope you and other users will find of interest and to target content.

Mobile Device Additional Terms

  •  Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for us to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
  • Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application.

SOCIAL MEDIA

 We may use hyperlinks on the Website, which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. These third-party services may collect and share information about a user. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. For example, when you click on Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION

Website Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person without further information. We may collect a range of Personally Identifying Information from and about people we are in contact with, including Website users. Much of the Personally Identifying Information collected by us is information provided to us by clients, potential clients, business partners, vendors or Website users when: (1) registering for and using our services;

(2) participating in polls, surveys or responding to offers; (3) communicating with us; (4) creating a public profile; or (5) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number. Clients, potential clients, and users of the Website are under no obligation to provide us with Personally Identifying Information of any kind, with the caveat that their refusal to do so may prevent them from benefitting from our services or using certain Website features.

BY USING OUR SERVICES OR REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION” SECTION.

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by DRRT or other information that we think you may find valuable. Generally, you may opt-out of such emails by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.

Company Disclosures

Since DRRT is a global provider of legal services, we may share users’ information with our offices and co-counsel throughout the world. Additionally, we will disclose Personally Identifying Information under the following circumstances:

  • By Law or to Protect Rights When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate or prevent illegal activity such as fraud or any other wrong doing; to protect and defend our rights, property, safety, users, employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Privacy Policy or other agreements and policies; in response to a subpoena or similar investigative demand, court order or a request for cooperation from a law enforcement or government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by In such cases, we may raise or waive any legal objection or right available to us.
  • Business Transfers We reserve the right to transfer all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, or other corporate restructuring or sale of all or a portion of Company’s Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing and/or Erasing Personally Identifying Information; Account Termination

 You may at any time review or change your Personally Identifying Information by going to your account settings (if applicable) or contacting us by using the contact information listed below. Upon your request, we will deactivate or delete your account on our Website and/or Personally Identifying Information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and in accordance with applicable law. We reserve the right to retain in our files some Personally Identifying Information to prevent fraud, to assist with any legal investigations, and to comply with any other legal or contractual requirements as is permitted by law. Therefore, you should not expect that all of your Personally Identifying Information will be completely removed from our databases in response to your requests.

INFORMATION BY THIRD PARTIES

 We share information with our service providers, suppliers, subcontractors and similar third parties who provide services to us or act on our behalf. We contractually prohibit these third-party providers from disclosing Personally Identifying Information received from us, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. This Privacy Policy only addresses the use and disclosure of information that we collect from you. You will be subject to the privacy policy of any third party that you provide with information. Use of the website to access client-specific information or for any other purpose does not constitute a waiver of any existing attorney-client privilege. Use of the website does not create an attorney-client relationship, as further described in the Terms of Use below.

TERMS OF USE

Our website does not create an attorney-client relationship between you and DRRT. An attorney-client relationship cannot be formed by reading the information on this website. The only way the attorney- client relationship is formed is to become our client by specific and explicit agreement with an individual attorney at DRRT. By providing information about our firm on our Website, we are not soliciting clients nor do we propose any type of transaction. You should not act or rely on any information contained on our Website without seeking the advice of an attorney. The determination and need for legal services as well as the choice of a lawyer is an extremely important decision and should not be based solely upon advertisements or self-proclaimed expertise. The website is intended for informational purposes only. None of the information contained in this website is intended to constitute, nor does it constitute legal advice.

SECURITY

We take the security of your Personally Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protecting all information. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password to our Website confidential and sending all sensitive Personally Identifying Information, such as identification documents, identification numbers, etc. to us via password encrypted electronic mail. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

DRRT PRIVACY & DATA PROTECTION POLICY

 European Union General Data Protection Regulation

As a global provider of legal services, DRRT complies with the European Union’s General Data Protection Regulation (“GDPR”) and the UK Data Protection Act of 2018 (“DPA”). The GDPR is applicable if you are a citizen of a European Union member state, you are using DRRT’s website or services from Europe, or you are in contact with DRRT’s offices in Frankfurt or Paris. The DPA is applicable if you are a citizen of the United Kingdom, you are using DRRT’s website or services from the UK, or you are in contact with DRRT’s office in London. Under both the GDPR and the DPA, DRRT will control and be responsible for the collection and processing of your personal data as both a data controller and processor.

Pursuant to the GDPR and the DPA, we process your Personally Identifying Information for specific, explicit and legitimate business purposes. “Legitimate interests” means the interests of our law firm in conducting and managing our business, cases, and clients, to enable us to provide to our clients the excellent legal representation and services and most secure experience possible. Our legitimate interests include some or all of the following:

  • To provide legal services to our clients, including, but not limited to, collecting, analyzing, and storing corporate documents, powers of attorney, affidavits, custodian confirmations, trade data, and other documentation, corresponding with clients regarding case proceedings, strategy, , coordinating and corresponding with co-counsel and other third-parties including claims administrators and custodians, and performing other duties required of our representation.
  • Where the processing enables us to enhance, modify, personalize, or otherwise improve our services/ communications for the benefit of our clients;
  • To identify and prevent fraud;
  • To enhance the security of our network and information systems;
  • To better understand how our clients interact with our website;

To provide communications which we think will be of interest to you, including case updates, alerts for potential case, notifications of upcoming conferences, roundtables, and other events, etc.

Outside of the legitimate interests listed above, DRRT will only process Personally Identifying Information for another purpose:

  • Where it has obtained the data subject’s prior consent;
  • Where necessary for the establishment, exercise or defense of legal claims in the context of specific administrative, regulatory or judicial proceedings; or
  • Where necessary in order to protect the vital interests of the data subject or of another natural

In compliance with the GDPR and the DPA, DRRT will take the following measures when processing Personally Identifying Information:

  • DRRT will process the personal data lawfully, fairly, and in a transparent manner;
  • DRRT will only collect data for specified, explicit, and legitimate purposes and not further process in a manner that is incompatible with those purposes;
  • DRRT will take every reasonable step to keep up to date Personally Identifying Information that is inaccurate, will be erased or rectified without delay;
  • DRRT will only keep Personally Identifying Information in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. DRRT has in place appropriate organizational measures to ensure compliance with this obligation, including erasure and/or anonymization of the data and all back-ups once the data is no longer relevant for any of the above enumerated processing purposes;
  • DRRT will receive, transmit, and process the Personally Identifying Information a manner that ensures appropriate security including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures. In the event of a personal data breach concerning Personally Identifying Information processed by DRRT, DRRT shall act appropriately to address the personal data breach, including measures to mitigate its possible adverse effects. In case of a data breach that is likely to result in a risk or high risk to the rights and freedoms of natural persons, DRRT shall without undue delay notify both the data exporter and the individuals concerned of the data breach and the competent supervisory authority including: (i) a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), (ii) its likely consequences, (iii) the measures taken or proposed to address the breach, and iv) the details of a contact point from whom more information can be obtained.
  • Where the transfer involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions or offences (hereinafter “sensitive data”), DRRT shall apply specific restrictions and/or additional safeguards adapted to the specific nature of the data and the risks involved. This may include restricting the personnel permitted to access the personal data, additional security measures (such as pseudonymization) and/or additional restrictions with respect to further disclosure.
  • Where DRRT intends to onward transfer the Personally Identifying Information to any third party/ies, as appropriate with a view to providing meaningful information, DRRT will inform the data subject of the purpose of such onward transfer and the ground DRRT will only transfer Personally Identifying Information to a third party where the third party is or agrees to be bound by the GDPR and/or the DPA.
  • DRRT shall ensure that any person acting under its authority, processes the Personally Identifying Information only on its instructions.

Whenever we process Personally Identifying Information for these purposes we will ensure that we always keep your rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please contact our Data Protection Officer using the contact information listed below. Please bear in mind that if you object this may affect our ability to carry out the above tasks for your benefit. Further we may process your data based on your express consent, or pursuant to a contractual or legal obligation to do so.

Under the GDPR and the DPA, you have the following rights, which apply in certain circumstances and subject to certain restrictions, in relation to your personal data:

  • The right to access your personal data;
  • The right to request the rectification and/or erasure of your personal data;
  • The right to restrict the use of your personal data;
  • The right to object to the processing of your personal data;
  • Where our processing of personal data is based on you having provided your consent or the processing is necessary for the performance of a contract with you, you have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and
  • Where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.

Pursuant to these rights, when we process personal information, we make sure to consider the balance any potential impact on the individual (both positive and negative), and their rights under relevant data protection laws, including the GDPR and the DPA. We will not use any personal data for activities where our interests are overridden by the impact on the individual (unless we have consent, a contractual obligation, or are otherwise required or permitted to by law).

If you wish to exercise your rights or would like more information on our legal bases to process your Personally Identifying Information please contact DRRT using the contact information provided below, where you will find a contact email address of our Data Protection Officer specifically dedicated to answering your comments, questions, and concerns relating to DRRT’s data privacy policy. DRRT’s EU-based representative is Christian Wefers, Director and Head of European Offices. He may be contacted at gdprinfo@drrt.com.

DRRT, where relevant with the assistance of the data exporter, shall deal with any enquiries and requests it receives from a data subject relating to the processing of his/her Personally Identifying Information and the exercise of his/her rights under the GDPR and/or the DPA without undue delay and at the latest within one month of the receipt of the enquiry or request. In particular, upon request by the data subject DRRT shall, free of charge: (i) provide confirmation to the data subject as to whether personal data concerning him/her is being processed and, where this is the case, a copy of the data relating to him/her; if personal data has been or will be onward transferred, provide information on recipients or categories of recipients, as appropriate with a view to providing meaningful information, to which the personal data has been or will be onward transferred, the purpose of such onward transfers and the grounds; and provide information on the right to lodge a complaint with a supervisory authority; (ii) rectify inaccurate or incomplete data concerning the data subject; (iii) erase Personally Identifying Data concerning the data subject if such data is being or has been processed in violation of any GDPR or DPA clauses ensuring third-party beneficiary rights, or if the data subject withdraws the consent on which the processing is based.

Data Privacy Framework

DRRT complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. DRRT has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DFP Principles) with regard to processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. DRRT has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF (collectively, the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles are hereinafter referred to as the “Principles”). If there is any conflict between the terms in this Privacy Policy and the Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.

In order to provide legal services to its clients, DRRT may gather or collect Personally Identifying Information from you such as your name, email address, location data, phone number, identification number etc.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, DRRT commits to resolve DPF Principles-related complaints about our collection and use of

your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact DRRT at:

DRRT

Attn: Diana Oliveira

340 West Flagler Street, 2nd Floor Miami, Florida 33130, USA

Email for General Privacy Policy inquiries: doliveira@drrt.com Phone: +1 (305) 760-8002

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, DRRT commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF the American Arbitration Association’s International Center of Dispute Resolution (“ICDR”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR are provided at no cost to you.

DRRT has also committed to cooperate with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (“ICO”) (and the Gibraltar Regulatory Authority (GRA)), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved Data Privacy complaints concerning human resources data transferred from the EU, UK, or Switzerland in the context of the employment relationship.

DRRT is committed to protecting the privacy of our clients. DRRT will use Personally Identifying Information or data we collect or receive only in a lawful manner and will not contact any individual without prior consent.

DRRT will never collect sensitive information about any individuals without their explicit consent and hold any personal information received or collected securely in accordance with the DRRT Privacy & Data Protection Policy as well as the Principles.

DRRT does not transfer, sell, trade, or rent Personally Identifying Information to others outside of DRRT, except in the following instances: (i) permission is given for DRRT to do so; (ii) when the sharing is with DRRT’s co-counsel or funding partners who are bound by contract to keep the information confidential; and (iii) when required to disclose the information pursuant to a court order. In rare instances, DRRT may have to share Personally Identifying Information a with law enforcement agencies, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests. Further, DRRT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In the context of an onward transfer DRRT is responsible for the processing of Personally-Identifying Information it receives under the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF by any third party acting as an agent on its behalf. DRRT shall remain liable under the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

While we may use technology to track patterns or behavior of visitors to our Website, it is not our current policy to do so. This could include using a “cookie” which would be stored on a visitor’s browser to allow future identification of such visitor, but any visitor can “disable cookies” to prevent this.

PRIVACY POLICY CHANGES

We may, in our sole discretion, change this Privacy Policy from time to time. The new version date will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. We will always post new versions of the Privacy Policy on the Website. However, we may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information. Please note, your continued use of the services with a new effective date will indicate that you agree to be bound by such changes.

CHILDREN

The Children’s Online Privacy Protection Act (COPPA) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to delete the information. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally Identifying Information to the Website, please contact us using our contact information below to have that child’s account terminated and information deleted.

DO-NOT-TRACK POLICY

 Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Our Website currently does respond to DNT browser signals or mechanisms.

LIMITATION OF LIABILITY

We are not responsible for any damages or injury, including but not limited to special, indirect, incidental or consequential damages, that result from your use of (or inability to use) this site, including any damages or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction. You understand and agree that your use of this site is predicated upon your waiver of any right to sue us or its affiliates directly or to participate in a suit for any losses or damages resulting from your use of this site.

GOVERNING LAW

 You agree that your use of this site and any disputes relating to any of them shall be governed in all respects by the laws of the State of Florida, United States. Any dispute relating to the above shall be resolved by arbitration, as the sole and exclusive legal recourse. The arbitration site shall be Miami, Florida, USA and the arbitration site’s procedural rules shall apply. The arbitration proceeding shall be conducted in the English language. All parties agree that the resulting arbitral award shall be the sole and exclusive remedy. The arbitral award may, in the arbitrator’s sole discretion, include reasonable attorney’s fees incurred in the proceeding.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Data Protection Officer at: DRRT

Attn: Diana Oliveira, Data Protection Officer 340 West Flagler Street, 2nd Floor

Miami, Florida 33130, USA

Email for General Privacy Policy inquiries: doliveira@drrt.com Phone: +1 (305) 760-8002

You may also contact our European Local Representative as required under Art. 27 GDPR as follows: DRRT

Attn: Christian Wefers, Director, Head of European Offices

Taunusanlage 9-10

60329 Frankfurt a. M., Germany Phone: +49 (69) 50 50 60 4267

Email: cwefers@drrt.com