D4 Solutions Privacy Policy

Effective Date:10/1/2025

Com-Graphics, Inc. d/b/a D4 Solutions, (referred to as “D4”, “we, “our” or “us”, as the context may require) values our relationships with our users, website visitors, and customers, and we respect your privacy. We are committed to protecting your privacy and the security of information that can directly or indirectly be used to identify a natural person or household (hereinafter “Personal Information”) through compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from individuals (“you”) with whom we interact when using our websites and portals located at www.d-4solutions.com, other websites and portals we own and operate (collectively, “Sites”), the D4™ mobile application, other D4 applications and online services that reference this Policy and via offline interactions (together with the Sites, “D4 Offerings”) and our policies and practices for collecting, using, maintaining, protecting, and sharing that information.

I. Introduction and Acceptance

The Policy applies to any D4 Offerings we provide to you in our role as controller of your Personal Information. This Policy does not apply to any products, services, websites, experiences, applications, events and content that are offered by third parties or have their own privacy policy or notice. You should read external website privacy notices carefully and check back frequently to ensure you understand each current policy. This Policy also does not include information we collect about our customers that are business entities, who are the majority of our customers.

The Personal Information we collect depends on how we interact with you. We collect Personal Information from you when you interact with us in the following ways:

“Customers” are individuals who purchase our services or D4 Offerings, whether online or offline. Customers does not include any information about buyers of our services that are business entities.

“Users” are individual users of the D4 Offerings, whether our direct Customers or end recipients of our Customers’ electronic communications or digital or physical documents.

“Visitors” are individuals who visit our Sites or use our mobile application.

This Policy does not apply to the extent we process Personal Information in the role of processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our Customers, including where we offer to our Customers various cloud products and services such as our portals, through which our Customers (and/or their affiliates) send electronic communications and digital or physical documents to Users, or otherwise collect, use, share, or process Personal Information via our portals. Use of this information by D4 is governed by agreements between D4 and the Customer. For detailed privacy information applicable to situations where a D4 Customer (and/or a Customer affiliate) who uses D4’s products and services is the controller, please reach out to the respective Customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Policy.

By using D4 Offerings, you acknowledge and consent to our data collection and usage practices as set forth in this Policy. Your use of D4 Offerings also confirms your agreement to our website terms of use, found at www.d-4solutions.com/termsofuse, (“Terms of Use”) and our Dispute Resolution Policy, found at www.d-4solutions.com/disputeresolution (“Dispute Resolution Policy”). If you do not want to agree to these Terms of Use and/or Dispute Resolution Policy, or if you do not acknowledge and consent to the terms of this Policy, you must not access or use the D4 Offerings. This Policy may be updated by D4 from time to time by posting a new version on the Sites.  It is our practice to post any new version we make to our Policy on this page, and with a posting to notifications by pull down menu for mobile applications, that this Policy has been updated.  Use of any of the Sites or other D4 Offerings following such changes will be deemed acceptance of such changes. The date this Policy was last revised is identified at the top of this Policy (see Effective Date above). Our business develops and changes (see Changes to Our Policy below). You should check this page frequently to ensure you understand our current Policy.

The Sites and D4 Offerings are operated in the United States, and please be on notice that any information you provide to us directly or through your use of the Sites will be transferred to and through the United States. Your use of the Sites and D4 Offerings is your consent to such transfer and consent and awareness that the United States may not provide the same types or levels of protection as required by the laws, codes and/or regulations in other countries.

If you are a California resident, please review the Information for California Residents section of this Policy. If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”), or California, please review the Privacy Rights and Choices section of this Policy.

II. Information We May Collect and How We Collect It:

We collect Personal Information you provide directly to us, through automatic data collection technologies, and from other sources as described below.

Information You Provide Directly to Us:

As a D4 Customer, a User of D4 Offerings, or a Visitor to our Sites, you may provide us with the categories of Personal Information below in the course of our business relationship with you, including when you contact us, subscribe to our communications or otherwise request information from us. Personal Information obtained from or relating to our prospective, current, and former Customers and Users (generally the customers or employees of D4 Customers) may be subject to additional or separate terms of any notice or agreement with the D4 Customer.

  • Contact Data. We collect your name and business contact methods, such as telephone number, email address, and office or other mailing address when you communicate with us either in person or electronically, and through our Sites. For example, you provide your contact information to us when you fill out a contact form on our Sites, download content, or visit our offices. Occasionally, we may require a recipient’s signature to receive a delivery at our Customers’ request.
  • Professional Data. We collect Professional Data from you in person, through communications, and through the D4 Offerings, such as when you fill out a contact form on our Sites. Professional Data includes details such as the organization you are affiliated with, your job title, and industry.
  • Financial Data. This may include your bank account number, payment information such as ACH information, payment status, and invoices.
  • Audio, Electronic, or Visual Data. This may include a virtual face or picture that a User may create in an account or a still photograph of a User.
  • Account Data. This may include login details to our portals, including your email address, administrator/user role, and other information provided through your account such as account creation date, document download activity, preferred authentication method for multifactor authentication (either email, mobile phone number, or authenticator application), and order history.

As you navigate through and interact with our Sites and other D4 Offerings, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Usage Data. This includes details of your visits to the Sites, including traffic data, referring/exit pages, logs, and other communication data and other resources that you access and use on the Sites, as well as whether you have interacted with our marketing communications; and
  • Device Data. This is information about your computer and internet connection, including your IP address, operating system, and browser type.

Please see Cookies and Analytics Tools below for more information.

Information from Third Parties

We also indirectly receive Personal Information from our Customers about Users to provide our services. When we receive this Personal Information indirectly, we rely on the Customer for the accuracy of the information and that the Customer has the authority to provide that information to D4. Examples of the type of Personal Information D4 receives from our Customers about Users are:

  • The first and last name, mailing address, and phone number of the User.
  • The email address of the User to either provide digital access to a document or to send tracking notifications.

In addition to the above categories of Personal Information, we may collect other types of information which may or may not contain Personal Information. Information related to shipments and related services may include shipment tracking number, location data, status of a delivery, delivery location, weight, and picture of the delivery. Depending on your interaction with D4, we may also get information about you from third parties and service providers that we engage to send promotional communications for us or provide marketing, advertising, or analytics services. On occasion we also receive contact lists from attendees at trade shows (provided with the individual’s consent). We may also collect your Personal Information from (i) social media networks to the extent you have made it available or interact with our profile or posts, (ii) promotions and other offers, interactions with customer service and account representatives, and (iii) publicly available information sources.

We may maintain and share aggregated or deidentified data, or data and information derived from Personal Information with other entities for the purpose of performing activities that may help us provide and improve our products and services.

Cookies and Analytics Tools

The technologies we use for automatic data collection may include first and third-party products and services such as “cookies” or “browser cookies,” as well as other technologies such as pixels or beacons. A cookie is a small file placed on the hard drive of your computer for record-keeping purposes and sometimes to track information about you. We use these technologies to perform analytics on our Sites, determine the effectiveness of a marketing or promotional campaign, to recognize our new or past customers, store your password if you are registered on our Sites, improve our Sites, and better understand the interests of our customers and website visitors and offer personalized advertising.

We use strictly necessary, functional, analytical, and tracking cookies on our Sites, as well as pixel tags and web beacons:

  • Technical or Functional Cookies: These cookies are always active and are required for basic functionality of the Sites.
  • Statistics or Analytical Cookies: These cookies help us understand how Visitors interact with the Sites.
  • Tracking/Marketing Cookies: We permit certain third-party business partners and advertisers to collect Personal Information through cookies or other similar technologies placed on our Sites and D4 Offerings. These companies may use the Personal Information collected through these cookies to track your behavior on our Sites and D4 Offerings, gather information about your use of the Sites and D4 Offerings, and other online services over time and across different businesses’ websites and services. Additionally, some companies may use information collected to deliver targeted advertisements on behalf of us or other companies, including on other applications, websites, or online services. We are not responsible for, and do not always control third parties’ collection or use of your information to serve targeted advertising.
  • Pixel Tags, Web Beacons, and Transparent GIFs. Pixel tags and web beacons are small graphic images placed on our Sites pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure responses to our communications and improve our Sites. If you would like to manage your email subscriptions with us, please visit the section below on Your Privacy Rights.

Where required, we will obtain your consent prior to placing or using optional cookies that are not strictly necessary or for the purpose of facilitating communications. If your consent is required, residents of appropriate jurisdictions can withdraw or change their consent at any time by clicking the Cookie Notice Banner or Do Not Sell or Share My Personal Information link in our footer. You may also modify the settings on your browser so that you refuse to accept browser cookies or so that you are alerted when cookies are being sent by activating the appropriate setting on your browser.  However, if you select this setting or block certain cookies, you may be unable to access certain parts of our services, Sites or other D4 Offerings.

For more information about the cookies and tracking technologies present on our D4 Offerings, please visit our Cookie Notice available on the Cookie banner.

Advertising:

We partner with third-party ad networks to display advertising on our Sites or to manage our advertising on other websites, apps, and platforms. These ad networks may use cookies, pixels, and web beacons to collect information about your activities on the Sites and other websites to provide you targeted advertising based on your interests. If you would prefer not to receive certain interest-based advertising, you can opt-out of this activity at the Digital Advertising Alliance (DAA) website at https://optout.aboutads.info/ or https://optout.networkadvertising.org/. Please note that this will not opt you out of all advertising as you will continue to see generic ads.

Social Media:

D4’s Sites and D4 Offerings may use social media features, such as the Facebook “like” button, the Instagram “heart” button, LinkedIn sharing features, and other similar widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our Sites, the latter may receive information showing that you have visited our Sites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our Sites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies (and any other applicable terms) of the respective companies that provide the relevant Social Media Features.

III. How We Use the Information We Collect

We may use the information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:

  • To present, administer, and improve the Sites (along with your browsing experience) and other D4 Offerings and their contents to our Customers, Users, and Visitors, and to carry out our day-to-day activities, such as providing digital downloads and shipping services to Users.
    • We process this Personal Information to fulfill a contract with you or where necessary for our legitimate interests in providing D4 Offerings.
  • To enable your use of the services available on the Sites and other D4 Offerings.
    • We process this Personal Information to fulfill a contract with you or where necessary for our legitimate interests in providing D4 Offerings.
  • To communicate with you about our products and services and facilitate other interactions. We may use your Personal Information, such as Contact and Professional Data and metadata, to send you transactional communications, notices, updates, and administrative messages, to provide you with customer service, notices about any orders, provide you with account updates (about your account, settings, security, billing, feature and product updates and other similar content), to inform you of or changes to or new services, products or provide other information we need to communicate to you or that you have requested. We may also use Account Data to communicate with you for various purposes, including to provide you with account updates.
    • We process this Personal Information to fulfill a contract with you or where necessary for our legitimate interests in providing and improving D4 Offerings and maintaining customer relationships.
  • For product development, research, and improvement of the D4 Offerings.
    • We process Personal Information where necessary for our legitimate interests to research and develop new products and services for the D4 Offerings, and in some cases with your consent (such as if you take a survey from us).
  • To advertise and market to you, including sending promotional communications and presenting you with relevant offers and for targeted marketing activities.
    • We process Personal Information where necessary for our legitimate interests to advertise and market to you, and where necessary on the basis of your consent.
  • For our internal business operations, such as billing and collection, finance and accounting, implementing business processes, conducting any reporting and auditing activities, and if necessary to manage any mergers, acquisitions, or other business transaction.
    • We process Personal Information to fulfill a contract with you or where necessary for our legitimate interests to run our business and perform our internal business processes.
  • To support safety, security, and manage operations, including to authenticate customers and other Users and access rights to our D4 Offerings.
    • We process Personal Information where necessary for our legitimate interest in providing the D4 Offerings in a safe and secure manner, including guarding against fraud or other unlawful activity, and in some cases to comply with legal obligations.
  • To comply with our legal obligations.
    • We process Personal Information where necessary to comply with our legal obligations.
  • For any other purpose with your consent.
    • We may process your Personal Information in additional ways if we obtain your consent to do so at the time we collect your Personal Information.

If you have consented to our use of Personal Information about you for a specific purpose, you have the right to change your mind at any time, subject to contractual and legal restrictions, and reasonable prior written notice. This will not affect any processing that has already taken place. Where we are using your Personal Information because we or another entity (for example, your employer or professional services provider) have a legitimate interest to do so (which legitimate interest is not overridden by your interests or fundamental rights or freedoms), you have the right to object to that use; however, in some cases, this may mean that you no longer use our products and services.

In the event that we de-identify any Personal Information for further use, we commit to maintain and use the information in de-identified form and will not attempt to re-identify the information, except for the purpose of determining if our de-identification processes satisfy applicable legal requirements.

IV. With Whom We Share Information

In the course of doing business, D4 may disclose Personal Information as described below:

  • To service providers. For all categories of information that we collect, we disclose Personal Information to our service providers for various business purposes, including but not limited to auditing interactions with Users, debugging our Sites, products and services, security purposes, for shipping and mailing, internal research, marketing and advertising, short-term uses such as payment processing, IT and cloud services, quality control and safety, data analytics, event management, and to perform other services on our behalf. These service providers are obligated to use any Personal Information only for the purposes for which we disclose it to them.
  • To third parties or business partners pursuant to a written contract. For example, some features on the Sites are plugins, widgets, and/or other tools made available by social media platforms and advertising networks that may result in information being collected or disclosed between us and such third parties. Such parties’ use of your information is governed by their privacy notice.
  • To a potential or actual buyer or other successor in the event of a merger, reorganization, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about the Sites, other D4 Offerings, and our users is among the assets transferred; and
  • At your option, to others with your consent after you have received notice when Personal Information about you might be shared with third parties.

We may also disclose your Personal Information:

  • To the extent we are required to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To establish, exercise or defend our legal rights and to enforce or apply our terms and conditions and any other agreements, including for billing and collection purposes; and
  • For the protection of us, our Customers and others if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of D4, such as exchanging information for the purposes of fraud protection and credit risk reduction.

V. Privacy Rights and Choices

Based on the law applicable to the use of your Personal Information, such as the laws of the EEA/UK or California, you may have rights that you can exercise in relation to your Personal Information. Note that in some cases we are not required to comply with your request, for example because such rights may be conditional or because we have to balance your rights against our rights and obligations to process your Personal Information and to protect the rights and freedoms of others. We will also need to verify your identity for any access, deletion, or correction requests. A number of the rights you may have in relation to your Personal Information, as applicable to the use of your Personal Information, are explained below:

  • Right of access/right to know. You may be entitled to a copy of the Personal Information we hold about you and to learn details about how we use it. Your Personal Information will usually be provided to you digitally. We may require you to prove your identity before providing the requested information, such as by providing your name, physical address, email address, contact information or other information about your account.
  • Right to rectification/correction. We take reasonable steps to ensure that the information we hold about you is accurate and complete, including by relying on our customers to provide us with accurate information about Users. However, if you believe that this data is inaccurate, you may have the right to request that any incomplete or inaccurate Personal Information that we process about you is amended. Users may also make certain changes to their own Personal Information through their accounts using the available Sites or other D4 Offerings resources and user profile on the application.
  • Right to deletion. You may have the right to ask us to erase your Personal Information, for example where the Personal Information we have about you is no longer necessary for the original purpose, where Personal Information has become obsolete or where you withdraw your consent (if we are processing your Personal Information based on consent). However, this will need to be balanced against other factors. For example, we may not be able to comply with your request due to certain legal or regulatory obligations.
  • Right to restriction of processing. You may be entitled to ask us to (temporarily) stop using your Personal Information, for example where you think the Personal Information we hold about you may be inaccurate or where you think that we no longer need to use your Personal Information.
  • Right to data portability. You may have the right to ask that we transfer Personal Information that you have provided to us to a third party of your choice. This right can only be exercised when you have provided the Personal Information to us, and when we are processing that data by automated means on the basis of your consent or in order to perform our obligations under a contract with you.
  • Right to opt-out of sale or sharing/targeted advertising (Do Not Sell or Share My Personal Information). You may request to opt out of the “sale” or “sharing” (as defined by applicable laws) of Personal Information, specifically with regard to certain types of behavioral or targeted advertising based on information collected about you on non-affiliated websites, applications, or services through cookies or website technologies. You may also revoke your consent to the use of these cookies, including previously enabled cookies, by clicking on the Cookie Notice Banner or Do Not Sell or Share My Personal Information link in our footer.
  • Right to object. You may have the right to object to processing which is based on our legitimate interests. In case of the processing of Personal Information for marketing purposes, you have the right to object at any time. When you ask us to stop using your Personal Information for marketing purposes, D4 will immediately cease to use your Personal Information. For other purposes based on our legitimate interests, we will no longer process the Personal Information on that basis when you file an objection based on your grounds relating to your particular situation, unless we have a compelling legitimate ground for the processing. Note, however, that we may not be able to provide certain services or benefits if we are unable to process the necessary Personal Information for that purpose.
  • Right to withdraw consent. For EEA/UK residents, when we use consent as our lawful basis you have the right to withdraw your consent at any time. D4 will stop the further processing of your Personal Information as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
  • Rights relating to automated decision-making. You may have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. D4 does not engage in any automated decision-making processes.
  • Nondiscrimination: We will not discriminate against you for exercising any of your privacy rights and choices.

Exercising Your Rights

Please note that some of the above rights may not always apply, as there are sometimes requirements and exemptions which may mean we need to keep processing the Personal Information or not disclose it, or other times when the rights may not apply at all. If you wish to exercise any of these rights, please contact us at security@d-4solutions.com or use our toll-free number (866) 597-5373. California residents may also exercise their rights using our webform Do Not Sell or Share My Personal Information and California Privacy Choices.

You may also designate an agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us via the information provided in the General Contact Information section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

  • The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
  • You to verify your identity directly with us; or
  • You to directly confirm with us that you provided the authorized agent permission to submit the request.

Residents of the EEA/UK also have the right to complain to us and/or the applicable supervisory authority including the UK Information Commissioner’s Office (www.ico.org.uk). A full list of Supervisory Authorities in the EEA can be found at www.edpb.europa.eu/about-edpb/about-edpb/members_en.

Additionally, all Customers, Users, and Visitors have the right to opt out of marketing communications from us. Please note that you cannot unsubscribe from non-promotional and transactional communications. Such communications can only be unsubscribed from by cancelling the User’s account. For promotional communications, you may manage your communication preferences via your portal account or select “unsubscribe” in any promotional email you receive.

All users may also choose to block certain cookies in their browser by changing the settings on their browser.

VI. Information for California Residents

If you are a California resident, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. The information we have obtained as categorized by California law includes the following:

Categories of Personal Information Collected Purpose for Collection and Use Categories of Personal Information Recipients
Identifiers, Contact and Verification Information (name and contact details such as your email address, mailing address, phone number, signature (only for certain deliveries), account username, and social media handles).
  • Providing and maintaining D4 Offerings
  • To facilitate our business and operational purposes in relation to the D4 Offerings we provide to you
  • To comply with the law
  •  Communicating with you
  • Data security incident detection
  • Debugging and repair of technical systems
  • For our marketing and business purposes
  • Purposes described in Section III
  • Our service Providers such as as cloud hosting and web platform providers, shipping and mailing providers
  • Marketing Service Providers, such as promotional email providers and analytics providers
  • Law Enforcement, public and government authorities, and other entities we deem necessary to comply with the law, support investigations, and protect the rights and properties of you, us and others
Financial Information (bank account, invoicing, and invoice record information).
  • Providing and maintaining D4 Offerings
  • To facilitate our business and operations purposes in relation to the D4 Offerings we provide to you
  • To comply with the law
  • Purposes described in section III
  • Our Service Providers such as accounting providers
Audio, Electronic, or Visual Information (virtual photo or still photograph of an account User)
  • Providing and maintaining D4 Offerings
  • To facilitate our business and operational purposes in relation to the D4 Offerings we provide to you
  • Data security incident detection
  • Debugging and repair of technical systems
  • Purposes described in section III
  • Our Service Providers such as cloud hosting and web platform providers
  • Law enforcement, public and government authorities, and other entities we deem necessary to comply with the law, support investigations, and protect the rights and properties of you, us and others
Internet or Network Activity Information (device information, including your browser type and language, IP address, device type, unique device identifiers, mobile network information and operating system, and website interactions, such as login items, account creation date, and other log activity).
  • Providing and maintaining D4 Offerings
  • Maintaining the security and operation of our D4 Offerings
  • Troubleshooting, and our internal analytics and reporting purposes.
  • Data security incident detection
  • Debugging and repair of technical systems
  • For our marketing and business purposes
  • Purposes described in section III
  • Our Service Providers such as data analytics providers
  • Marketing Service Providers
  • Law enforcement, public and government authorities, and other entities we deem necessary to comply with the law, support investigations, and protect the rights and properties of you, us and others
Inferences (preferences, such as which areas of our Sites you are interested in).
  • Providing and maintaining D4 Offerings
  • Communicating with you
  • For our business purposes
  • Purposes described in section III
  • Our service Providers and marketing Service Providers

Disclosures for a Business or Commercial Purpose. In the preceding 12 months, D4 has disclosed the categories of Personal Information in the above chart to our service providers for specific, limited business purposes and commercial purposes, including the purposes listed in the How We Use Information section of this Policy.

Sensitive Personal Information. We do not collect Sensitive Personal Information from any California consumers as defined under California law.

We do not knowingly “sell” or “share” the Personal Information of children under the age of 16, as those terms are defined under California law and have not done so in the previous twelve months. We do not currently respond to Do Not Track signals.

Analytics and Advertising, Marketing: Some of our analytics and marketing practices on the D4 Offerings may be considered a “sale” or “sharing” of Personal Information under California law. To opt out of your Personal Information being collected and used for analytics or targeted advertising, you can either set your browser to block all cookies, you can click the Do Not Sell or Share My Personal Information link, or you can email us for further information at security@d-4solutions.com.

Global Privacy Control. If we receive and are able to process a signal from your device indicating your preference to opt out from sales or sharing of Personal Information, as defined by law, such as the Global Privacy Control signal, then we will apply that preference to Personal Information we collect from that device, provided that we may not be able to associate the signal to the same device if: (i) you use a different web browser or other tool to interact with us, (ii) you make changes to your browser, such as an update, that impacts our ability to associate the device with your signal, and (iii) you clear cookies or browsing data from your browser or device in a way that impacts our ability to associate the device with the signal your device originally sent.

Data Sharing for Direct Marketing: California Civil Code Section § 1798.83 permits Users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. D4 does not disclose any Personal Information to third parties for their direct marketing purposes.

I. Data Security and How We Protect Your Information

We take the security of your Personal Information very seriously and we have implemented and adopted appropriate commercially reasonable measures designed to secure your Personal Information against unauthorized access, alteration, disclosure or destruction. All information you provide to us is stored on secure servers behind firewalls. Any Personal Information or payment-related information exchanged will be protected using encrypted, protected with digital signatures, and transported over an SSL secured communication channel.

However, no transmission of information via the internet or any electronic commerce is completely secure. Although we use appropriate commercially reasonable efforts and standards to protect your Personal Information, we cannot guarantee the security of the Personal Information transmitted to our Sites and through our D4 Offerings.  Any transmission of Personal Information is at your own risk and you should consider taking pro-active steps to secure and protect yourself, your Personal Information and all information online and with any electronic commerce. You are responsible for keeping your password and user details confidential and we will not ask for your password in any correspondence between us.  We are not responsible for circumvention of any privacy settings or security measures of mobile applications or on the Sites.  We reserve the right to contact or notify you about any information regarding this Policy, security, our services, the Sites, and other D4 Offerings electronically along with other means of notification. Use of the D4 Offerings involves third-party hardware (i.e. smart phones and other mobile devices) as well as software integrated into the service or third-party service providers or carrier or platforms (i.e. Google Drive, Box or Dropbox, Google Play, App Store). D4 does not control third parties. User information will be handled by such third-party and D4 cannot assure User that such information will be handled in a secure manner.

II. International Data Transfers

Your Personal Information will be collected, transferred to, processed, and stored by us in the United States, and by our service providers and third parties that may be based in other countries. Data transferred to us by our Customers generally originates in the United States. The Sites are operated in the United States, and please be on notice that any information you provide to us or through your use of the Sites will be transferred to and through the United States. Your use of the Sites and other D4 Offerings is your consent to such transfer and consent and awareness that the United States may not provide the same types or levels of protection as required by the laws, codes and/or regulations in other countries.

In the event that we transfer any Personal Information from the EEA/UK to the United States, we will protect that information as described in this Policy and in accordance with applicable law. We will use adequate safeguards such as the European Commission’s standard contractual clauses, if and when any such international data transfer occurs.

III. Children’s Information

Our Sites are not intended for use by any minors under the age of 18 and we do not knowingly collect Personal Information directly from children under the age of 16. If we learn we have collected or received Personal Information from a child under the age of 16 without parental/guardian consent, we will take commercially reasonable efforts to delete that information. If you believe we might have any Personal Information from or about a child under the age of 16 without appropriate parental/guardian consent, please contact us using the information in the Contact Us section below.

IV. Additional Users

When a Customer requests that an individual be given access to Customer’s account, D4 will send the potential individual user an invitation to register to access the site.  By requesting that access be given to an individual user, Customer represents and warrants to D4 that Customer has an existing business relationship with such additional User sufficient to avoid liability under any law that applies to unsolicited email or other applicable law. Customer will be deemed to be the sender of any such email (or other electronic communication) and D4 will be deemed to merely be a service provider facilitating Customer’s sending of the email (or other electronic communication).

V. Retention of Personal Information

D4 keeps your Personal Information only for as long as necessary to provide services, the relevant purposes described in this Policy or as we otherwise notify you if there is an update to this Policy (under Introduction and Acceptance of this Policy), and as may be required by law (including for our tax, audit, and accounting purposes). To determine the appropriate retention period for Personal Information, we consider our statutory obligations, the amount, nature, and sensitivity of the Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means. After the retention period, we will delete or anonymize your Personal Information. To the extent we retain de-identified data, we will not attempt to re-identify that Personal Information.

VI. Changes to this Policy

The Effective Date of this Policy is set forth at the top of this webpage. As business needs change, we may amend this Policy. The amended Policy supersedes all previous versions. If we update this Policy, we will notify you by posting a new Policy on this page. If we make any material changes to this Policy, we will notify you as required by law, which may include by email to the email address you provided to us, if available. We encourage you periodically to check this page for updates.

VII. General Contact Information

If you have any questions or concerns about this Policy, please contact us at security@d-4solutions.com. You may also contact us using the information below:

Com-Graphics, Inc. d/b/a D4 Solutions

Attn: Director of IT

201 S. Swift Rd.

Addison, IL 60101

(312) 226-0900