Introduction
This Privacy Policy explains how dm2, LLC ("we", "us", or "our") collects, uses, discloses, and protects personal information when you visit or interact with our website, mobile applications, services, or other online products (collectively, the "Services"). This Policy describes the types of information we collect, the purposes for which we use that information, the legal bases on which we rely to process personal data where applicable, how we share information, and the rights available to individuals. By using the Services, you acknowledge that you have read and understood this Privacy Policy.
Definitions
For the purposes of this Policy:
Personal Data means any information relating to an identified or identifiable natural person (for example, name, email address, postal address).
Usage Data means information collected automatically about how the Services are accessed and used (for example, IP address, browser type, operating system, pages visited, and timestamps).
Processing means any operation performed on Personal Data (for example, collection, recording, organization, storage, adaptation, retrieval, consultation, disclosure, erasure).
Controller means the entity that determines the purposes and means of Processing Personal Data. When we collect Personal Data through the Services, we act as Controller unless otherwise stated.
Information We Collect
Personal Data
We may collect Personal Data that you provide directly to us, including but not limited to:
Identity information: name, title;
Contact information: email address, postal address, telephone number;
Account information: usernames, passwords, profile information;
Transactional information: records of purchases, billing and payment details (excluding full payment card numbers where those are processed by payment processors);
Communications: any content you submit through contact forms, support requests, surveys, or correspondence with us.
Example: When you create an account or contact customer support, you typically provide your name, email address, and details necessary to fulfill your request.
Usage Data
We automatically collect Usage Data when you interact with the Services. This includes:
Device and connection information: IP address, device identifiers, browser type and version, operating system, screen resolution;
Usage patterns: pages or content viewed, search terms, referral URLs, click and scroll behavior, timestamps, and session duration;
Error reports and performance data.
Usage Data helps us analyze and improve our Services and detect and prevent fraud and abuse.
Cookies and Tracking Technologies
We and our third-party partners use cookies, web beacons, pixel tags, local storage, and similar technologies to collect information and enhance your experience. Cookies are small text files stored on your device that remember preferences and enable features such as authentication and shopping carts.
Typical cookie categories include:
Strictly necessary cookies: required for core site functionality (e.g., session management).
Performance and analytics cookies: used to collect aggregated usage data to improve the Services.
Functional cookies: remember user preferences and choices.
Advertising and targeting cookies: used to deliver relevant advertisements and measure campaign effectiveness.
Most browsers allow you to block or delete cookies. Blocking cookies may limit access to certain features of the Services.
How We Use Information
We process Personal Data for the following purposes:
To provide and operate the Services, including account administration, order fulfillment, and customer support;
To communicate with you about your account, transactions, and updates to policies or Services;
To improve, personalize, and develop new features and products by analyzing Usage Data;
To protect the security and integrity of our Services and to detect, prevent, and mitigate fraud, abuse, or illegal activity;
To comply with legal obligations, resolve disputes, and enforce our agreements;
For marketing and advertising purposes, where permitted; examples include sending newsletters or promotional offers, or delivering tailored advertisements.
We only retain and use Personal Data for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.
Legal Bases for Processing (Where Applicable)
Where applicable, and particularly for residents of jurisdictions that require a legal basis (for example, the European Economic Area), we rely on one or more of the following legal bases to process Personal Data:
Consent: You have given clear consent for us to process your Personal Data for a specific purpose (for example, receiving marketing emails). You may withdraw consent at any time as described below.
Performance of a contract: Processing is necessary to perform a contract to which you are a party (for example, to deliver products or services you have ordered).
Legal obligation: Processing is necessary to comply with a legal obligation (for example, tax or accounting requirements).
Vital interests: Processing is necessary to protect someone’s life.
Legitimate interests: Processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms (for example, improving Services, preventing fraud, or ensuring network and information security).
Cookies and Tracking Technologies (Detailed)
We use third-party analytics and advertising providers (for example, Google Analytics, advertising networks) that may place cookies or similar technologies. These providers collect Usage Data and may use such data to build profiles of interests for advertising purposes. Where required by law, we will obtain your consent before placing non-essential cookies.
Practical details: to manage cookie preferences, you can adjust your browser settings, use an in-product cookie preference tool where available, or follow the opt-out links provided by certain third-party services.
SMS and Text Message Communications
Digital Street Smart Academy, operated by dm2, LLC, may send you automated marketing and promotional text messages (SMS/MMS) to the mobile phone number you provide when opting in through our website forms or other contact points. Message frequency varies, approximately 4 messages per month. Consent is NOT a condition of purchase of any goods or services. You must be 18 years of age or older to opt in. Standard message and data rates may apply depending on your mobile carrier and plan. To opt out at any time, reply STOP to any message. After texting STOP, you will receive one final confirmation message and no further messages will be sent. For help, reply HELP or contact us at +1 888 990 7147. Carriers are not liable for delayed or undelivered messages. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Text messaging originator opt-in data and consent will not be shared with any third parties, except for aggregators and providers of the Text Message services.
Data Sharing and Disclosure
We may disclose Personal Data in the following circumstances:
Service providers: To vendors and service providers who perform services on our behalf, such as payment processors, hosting providers, analytics providers, marketing platforms, and customer support service vendors. These service providers are contractually limited to use Personal Data only to provide services to us.
Business transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, Personal Data may be transferred as part of the transaction.
Legal requirements: When required to do so by law, subpoena, court order, or governmental request, or to respond to lawful requests by public authorities.
To protect rights: To enforce our Terms of Service, protect our rights, property, or safety, or that of others, or to prevent fraud or illegal activity.
We do not sell Personal Data for monetary consideration. If our practices change, we will provide notice and, where required, obtain consent. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.
Third-Party Services and Links
The Services may contain links to third-party websites, products, or services. We do not control the privacy practices of third parties and are not responsible for their content. We encourage you to review the privacy policies of those third parties before providing any Personal Data.
International Data Transfers
Personal Data collected through the Services may be stored and processed in the United States or other countries where our service providers operate. These countries may have different data protection laws than your country. Where required by law, we implement appropriate safeguards for international transfers (for example, standard contractual clauses, adequacy decisions, or other legal mechanisms).
Data Retention
We retain Personal Data only as long as necessary to fulfill the purposes described in this Policy, including to comply with legal, accounting, or reporting requirements. Retention periods vary by data category and purpose. For example:
Account and transactional records: retained for the duration of the account and thereafter for legal or tax purposes (commonly several years);
Support and correspondence records: retained for as long as reasonably necessary to resolve issues and maintain records of communications;
Usage Data and analytics: retained in aggregated or de-identified form where feasible; raw logs may be retained for a limited period for security and diagnostic purposes.
Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, and destruction. Examples of these measures include encryption in transit (TLS), access controls, network security measures, and regular security assessments.
No system is completely secure; despite our efforts, we cannot guarantee absolute security. If we become aware of a data breach that is likely to result in a risk to your rights and freedoms, we will follow applicable law and notify affected individuals and regulators when required.
Your Rights
Subject to applicable law, you may have the following rights with respect to your Personal Data:
Access: Request confirmation of whether we process your Personal Data and request a copy of such data.
Correction: Request correction of inaccurate or incomplete Personal Data.
Deletion: Request deletion of Personal Data where processing is no longer necessary or lawful.
Portability: Request a machine-readable copy of Personal Data you provided and, where technically feasible, transmit that data to another controller.
Object: Object to processing based on legitimate interests or direct marketing.
Withdraw consent: Withdraw consent where processing is based on consent; withdrawal does not affect the lawfulness of processing before withdrawal.
How to Exercise Your Rights
To exercise any of the rights described above, please contact us at [email protected] with a clear description of your request and any required verification information. We will respond in accordance with applicable law and may request additional information to confirm your identity before fulfilling a request. If you are a resident of a jurisdiction with a supervisory authority, you may also file a complaint with that authority.
Children’s Privacy
Our Services are not intended for children under the age of 16 unless otherwise stated. We do not knowingly collect Personal Data from children under the applicable minimum age. If we learn that we have collected Personal Data from a child without required parental consent, we will take steps to delete that information. If you believe we may have collected information from a child, please contact us at [email protected].
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will post the updated Policy on the Services with a revised "Effective Date." When changes are material, we will provide prominent notice and, where required, obtain consent. Your continued use of the Services after the Effective Date constitutes acceptance of the updated Policy.
Contact Information and Effective Date
If you have questions, requests, or concerns about this Privacy Policy or our data practices, please contact us at [email protected]. The effective date of this Policy is 2026. For mail inquiries, please contact: Digital Street Smart Academy, operated by dm2, LLC, Casper, WY.
