Purpose

1. This Privacy Policy outlines the types of personal information we collect, how we use and safeguard that information, and your rights in relation to your personal data. Design Systems Inc. [hereinafter referred to as DSI] is committed to protecting the privacy of our users.

Information We Collect

1. Personal Information: We may collect personal information that you voluntarily provide to us, such as your name, email address, phone number, or other personally identifiable information.

2. Automated Information: We may collect information automatically through technologies such as cookies, log files, and web beacons. This information may include IP addresses, browser types, device types, and other technical information. Users have the option of rejecting or accepting cookies within our website.

How We Use Your Information

1. Providing Services: We use your personal information to provide and personalize our services, communicate with you, and fulfill your requests.

2. Improving Services: We may use information for analytics, research, and to improve the functionality and quality of our services.

3. Marketing and Communications: With your consent, we may use your contact information to send you promotional materials, newsletters, and other communications.

How Do We Store Information

1. Information is securely handled, stored, and deleted

2. Secure servers are used to protect your data. Data files are encrypted to ensure all personal data is behind strict safeguards both in transit and at rest, and access is restricted to only authorized individuals. Once data is no longer needed or it expires it is deleted according to our internal data retention and disposal policy.

Data Security

1. Security Measures: DSI implements reasonable security measures to protect your information from unauthorized access, disclosure, alteration, and destruction.

Information Sharing

1. Third-Party Service Providers: We may share your information with third-party service providers who assist us in delivering our services, subject to confidentiality agreements.

2. Legal Obligations: We may disclose your information to comply with legal obligations, protect our rights, or respond to lawful requests from governmental authorities.

Your Rights

1. Access and Correction: You have the right to access and correct your personal information. You may contact us at <jmayer@dsidsc.com> to request access, correction, or deletion of your data.

2. Opt-out: You have the right to opt-out of receiving promotional communications. You can do this by following the instructions in the communication or contacting us directly.

Children’s Online Privacy Information

1. These Web sites are not intended for use by children under the age of 13. We do not knowingly collect information from children under the age of 13 although certain third-party sites that we link to may collect information. These third-party sites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce the Construction Owners Association of America’s Privacy Policy by instructing their children to never provide any personal information on our Web sites without their permission.

2. In accordance with the provisions of the Children’s Online Privacy Act, in the even that we do inadvertently begin collecting any personal information or data from children under the age of 13, we will notify parents first, and will seek parental or guardian consent to collect, use and/or disclose certain personal information from children under the age of 13. A parent may review and have deleted their child’s personal information and may refuse to permit further collection of use of their child’s information by contacting us as noted at the end of this Privacy Policy. Parents may consent to our collection and use of their child’s personal information without consenting to the disclosure of that information to others.

Additional California Privacy Disclosures

1. This section of the Design Systems, Inc. privacy policy only applies to you if you are a resident of California. As a resident of California, under California Law, you have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personally identifiable information, such as: name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request this information please contact the Design Systems, Inc. Human Resource Manager.

2. If you do not want your personally identifiable information to be shared with any third party who may use such information for direct marketing purposes, then you may opt out by contacting the Construction Owners Association of America at coaa@coaa.org.

Additional EU Privacy Disclosures

1. Design Systems, Inc. generally acts as the data controller of your information submitted through the Design Systems, Inc. website in order to provide you with certain services; however, under certain circumstances vendors may engage Design Systems, Inc. to provide them with certain information owned or controlled by Design Systems, Inc.. The Design Systems, Inc. is not responsible for any vendor’s use of information for which it is the owner or controller. To learn more about how a vendor may use such information, you should review the vendor’s privacy policy.

2. If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would however, appreciate the chance to review and respond to your concerns before you approach your Supervisory Authority so please contact the Design Systems, Inc. Human Resource Manager.

3. Provision of personal data and failure to provide personal data. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services, education, etc.). In this case, we will not be able to provide services to you.

4. Legal basis for our processing of your personnel data. Below are the types of lawful basis that we will rely on to process your personal data:

   • Legitimate Interest means the interest of our business and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting the Design Systems, Inc., Human Resource Manager.

   • Provide Educational Services means enabling us to provide you with the most beneficial education services that Design Systems, Inc. is able.

   • To Communicate with You means that Design Systems, Inc. may use the information collected to directly communicate with you.

   • To Provide You with Other Opportunities means that Design Systems, Inc. may provide your collected information to vendors which you may find useful.

   • To Create Statistical Data means Design Systems, Inc. may use the information collected to create additional statistical data which may or may not identify you individually to analyze the impact or usefulness of certain services available.

   • Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that Design Systems, Inc. is subject.

Change of Purpose.

1. Design Systems, Inc. will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Design Systems, Inc. Human Resource Manager

2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Collection of Personal Data from Third Party Sources.

Design Systems, Inc. does not collect personal data from third party sources.

Rights of EU Data Subjects.

Under certain circumstances, you have rights under data protection laws in relation to your personal data, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we have about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is not a good reason for us continuing to process it. You also have the right to ask us delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. It should be noted that we may not always be able to comply with your request of erasure for specific legal reasons which will be provided to you, if applicable, at the time of processing your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following circumstances: if you want us to establish the accuracy of the data, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information where you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

1. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

2. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

3. We will try to respond to all legitimate requests within one month. Occasionally, it may take us longer than one month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

4. To exercise your rights, please contact the Design Systems, Inc. Human Resource Manager.

5. Additionally, in a situation where a vendor is the data controller and you would like the vendor to delete information which they have collected about you, Design Systems, Inc. encourages you to contact the vendor directly.

Changes to this Statement.

Design Systems, Inc. will occasionally update its Privacy Policy to reflect company and customer feedback, but Design Systems, Inc. will not individually notify you of any such updates to the Privacy Policy. As such, Design Systems, Inc. encourages you to periodically review this Privacy Policy to be informed of how Design Systems, Inc. is protecting your information.

Opting Out or Changing Personal Information.

To opt out of any of the Privacy Policies listed here, contact Design Systems, Inc. Human Resource Manager

Contact Information.

Design Systems, Inc. welcomes your comments regarding this Statement of Privacy. If you believe that Design Systems, Inc. has not adhered to this Statement, please contact Design Systems, Inc. Human Resource Manager. We will use commercially reasonable efforts to promptly determine and remedy the problem.