Privacy Policy

Last updated: April 1, 2023

This Privacy Policy describes Dolphin Group Companies’s policies and procedures on the collection, use, retention and disclosure of your personal information that we collect both online and offline. Federal law limits how we can use your personal information.

By using our website and/or engaging in our application process, you are agreeing to the collection and use of your personal information in accordance with this Privacy Policy.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using the Dolphin Group Companies website and/or engaging in our application process, you may be asked to provide certain pieces of personal information that can be used to contact or identify you. Personal information may include, but is not limited to:

• Name

• Telephone Number

• Address

• Email Address

• Social Security Number

• Banking Details

Usage Data

Usage Data is collected automatically when using the Dolphin Group Companies website.

Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Dolphin Group Companies website through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. Dolphin Group Companies may also collect information that your browser sends.

Information from Third-Party Social Media Services

Dolphin Group Companies allows you to link your Third-Party Social Media Services to your account and log in to use our website through the following Third-Party Social Media Services:

• Google
• Facebook

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, Dolphin Group Companies may collect personal data that is already associated with Your Third-Party Social Media Service's account.

You may also have the option of sharing additional information with us through your Third-Party Social Media Service's account. If you choose to provide such information and personal data, during registration or otherwise, you are giving Dolphin Group Companies permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

Dolphin Group Companies uses Cookies and similar tracking technologies to track the activity on our website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our website. The technologies we use may include:

• Cookies or Browser Cookies. A Cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our website. Unless you have adjusted your browser setting so that it will refuse Cookies, our website may use Cookies.
• Web Beacons. Certain sections of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Dolphin Group Companies, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go off-line, while Session Cookies are deleted as soon as you close your web browser. You can learn more about Cookies here: All About Cookies by TermsFeed.

We use both Session and Persistent Cookies for the purposes below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Dolphin Group Companies

  Purpose: These Cookies are essential to provide you with services available through our website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies the services that you have asked for cannot be provided and Dolphin Group Companies only uses these Cookies to provide you with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Dolphin Group Companies

  Purpose: These Cookies identify if users have accepted the use of Cookies on the website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Dolphin Group Companies

  Purpose: These Cookies allow us to remember choices you make when using our website, such as remembering your login details or language preference. The purpose of these Cookies is to provide more personal experience and to avoid having to re-enter your preferences every time you use our website.

• Tracking and Performance Cookies

  Type: Persistent Cookies

  Administered by: Third-Parties

  Purpose: These Cookies are used to track information about traffic to the website and how users use the website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our website. We may also use these Cookies to test new pages, features or new functionality of our website to see how our users react to them.

Use and Disclosure of Your Personal Data

Dolphin Group Companies may use your Personal Data:

• To provide and maintain our website.
• To manage your account by providing you access to different functionalities of our website that are available to you as a registered user.
• To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with general information regarding your employment and potential opportunities with Dolphin Group Companies.
• To manage your requests to Dolphin Group Companies.
• To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our website products, services, marketing and your experience.

Dolphin Group Companies may disclose your personal information:

• With service providers to monitor and analyze the use of our website or to contact you.
• When required to do so by law or in response to valid requests by public authorities.
• For business transfers in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Dolphin Group Companies business to another company.
• With joint venture partners and other companies that are under common control, who we will require to honor this Privacy Policy.
• With business partners to offer you certain services or promotions.
• With other users when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
• Dolphin Group Companies may disclose your Personal Data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of Dolphin Group Companies
  • Prevent or investigate possible wrongdoing in connection with our website
  • Protect the personal safety of users of our website or the public
  • Protect against legal liability
• With your consent, Dolphin Group Companies may disclose your personal information for any other purpose.

Retention of Your Personal Data

Dolphin Group Companies will retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Personal Data of job applicants and individuals whose assignment has ended may also be maintained in our system to potentially contact you regarding other employment opportunities.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or if we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Dolphin Group Companies’s main office and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Dolphin Group Companies will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, Dolphin Group Companies cannot guarantee its absolute security.

Removal of Your Personal Data

A request for removal of your Personal Data must be submitted in writing to Dolphin Group Companies including a description of what data should be removed, your address, telephone number, and email address. Dolphin Group Companies reserves the right to refuse removal of some or all of the requested data if the data is still needed for legal or financial records. Upon receipt of a removal request, we will take whatever action, in its sole discretion, it deems appropriate, including removal of the requested data from the website.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to your Personal Data only to perform their tasks on Dolphin Group Companies’s behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use Third-Party Service providers to monitor and analyze the use of our website.

• 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 website. 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 (ga.js, analytics.js and dc.js) 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?hl=en

Email Marketing

Dolphin Group Companies may use your Personal Data to contact you with marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Dolphin Group Companies by following the instructions provided in any email or text we send.

We may use Email Marketing Service Providers to manage and send emails to you.

• Twilio SendGrid

  Twilio Send Grid is an email marketing and transactional email sending service provided by Twilio.

  For more information on the privacy practices of Twilio, please visit their Privacy policy: https://www.twilio.com/legal/privacy

Usage, Performance and Miscellaneous

Dolphin Group Companies may use Third-Party Service Providers to provide better improvement of our website.

• Google Business

  Google Business is a service that returns information about places using HTTP requests. It is operated by Google.

  Google Business service may collect information from you and from your device for security purposes.

  The information gathered by Google Business is held in accordance with the Privacy Policy of Google: https://policies.google.com/privacy?hl=en

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light Law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with Third-Parties for the Third-Parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light Law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact Dolphin Group Companies using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our website may contain links to Third-Party websites and applications of interest, including advertisements and external services that are not affiliated with Dolphin Group Companies. Once you have used these links to leave our website, any information you provide to these Third-Parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any Third-Party websites, you should inform yourself of the privacy policies and practices (if any) of the Third-Party responsible for that service or website, and should take the steps necessary to, in your discretion, protect the privacy of your information.

Dolphin Group Companies is not responsible for the content or privacy and security practices and policies of any Third- Parties, including other sites, services or applications that may be linked to or from our website.

We have no control over and assume no responsibility for the content, Privacy Policies or practices of any Third-Party sites or services.

Changes to this Privacy Policy

Dolphin Group Companies reserves the right, at our sole discretion, to modify or replace this Privacy Policy at any time.

By continuing to access or use our website after revisions become effective, you will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy. If you do not agree to the new terms, in whole or in part, please stop using our website.

You are advised to review this Privacy Policy periodically for any changes and stay informed of updates. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact Dolphin Group Companies at:

• By email: privacy@MyDolphinGroup.com