Privacy Policy

EFFECTIVE DATE: December 6, 2023

Distributional values your privacy.  In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of our website at (“Site”) and any services we may offer through the Site (“Services”). By accessing or using the Site or Services, you agree that your Personal Data may be handled as described in this Policy.  

Defined Terms

These capitalized terms have the meanings ascribed to them as used in this Policy:

  • Personal Data” means any personally-identifiable information, personal data or personal information, as those terms are defined under all applicable laws.
  • User,“ “you,“ or “ your” means any person that visits or registers to use the Site or the Services, either individually or collectively.
  • Distributional,” “we,” “our,” “us” means Distributional, Inc. and its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors.

The Information and Personal Data We Collect About You

We collect information about you directly from you and from third parties, as well as automatically through your use of the Site and Services.

Information and Personal Data We Collect Directly From You. We collect the following types of Personal Data from users of the Site and Services:  your name, email address, company name and other contact information if you email us or complete a contact form on the Site.   If you apply for a job through our site, we may collect your employment and educational background, home address, phone number and other Personal Data contained in your resume.

Information and Personal Data We Collect Automatically. We may automatically collect the following information about your use of our Site or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site or use our Services; and the referring URL, or the webpage that led you to our Site.  We may combine this information with other information that we have collected about you, including, where applicable, your name and other Personal Data   Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.  

How We Use Your Personal Data

We use your information, including Personal Data, for the following purposes:

  • provide, maintain and improve our Site and Services;
  • fulfill orders, complete transactions, and provide and deliver the information and Services you request;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • respond to your comments, questions and requests and provide customer service;
  • communicate with you about employment opportunities, products, services, offers, promotions, rewards, and events offered by Distributional and others, and provide news and information we think will be of interest to you;
  • monitor and analyze trends, usage and activities in connection with our Site;
  • personalize and improve the Site and provide content and features that match user profiles or interests;
  • process and deliver contests, sweepstakes, and other promotional entries and rewards
  • link or combine with information we get from others to help understand your needs and provide you with better service;
  • process job applications that are submitted through the Site;
  • monitor compliance with the Terms, comply with legal obligations, respond to law enforcement and governmental requests, and exercise or defend legal claims; and
  • carry out any other purpose for which the information was collected.

How We Share Your Personal Data

We may share your information, including Personal Data, as follows:

  • Consent. Where you have provided consent, we share your information, including Personal Data, as described at the time of consent, such as when you authorize a third party application or website to access your account or when you participate in promotional activities conducted by our partners or third parties.
  • Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
  • Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company or entity, including as part of a bankruptcy proceeding or corporate reorganization, or are in negotiations for any of these types of transactions, we may transfer the information we have collected from you to the other company or entity.
  • In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
  • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
  • Aggregate and De-Identified Information. We may share aggregate or de-identified information about users and their use of the Services with third parties and publicly for marketing, advertising, research or similar purposes.  

Please note that except as noted above, we will not sell or share your Personal Data with any third party for their direct marketing purposes without your consent. 

Our Use of Cookies and Other Tracking Mechanisms 

We and our service providers may use cookies and other tracking mechanisms to track information about your use of our Site and Services, including but not limited to Google Analytics’ technologies. We may combine this information with other Personal Data we collect from you (and our third party service providers may do so on our behalf).  The use of these technologies as configured may include the sending of cookies to your computer or mobile device.  Cookies are small data files stored on your hard drive or in device memory that help us to improve our Site and your experience, to see which areas and features of our Site are popular, and to count visits.  

We may use the following types of cookies:

  • Strictly Necessary: These are used to enable and protect your use of the Site and the Services.  You cannot disable these cookies.
  • Functionality: These are used to provide enhanced functionality and customization that help us deliver our Site and Services.  For example, we may use these to record your settings and preferences to help you log into your account by pre-filling fields, and providing you with customized content and experience.  
  • Analytics and Performance: These tracking technologies are used to understand how you interact with our Site and Services and monitor the performance of our Site and Services. They also help us analyze, improve, and develop our Sites and Service. For example, we may use these technologies to understand how you are using Site features, and segment audiences for feature testing.  Google Analytics (discussed in third-party analytics below) is an example of such a technology.
  • Advertising: These are tracking technologies designed to display and measure the effectiveness of personalized ads for our Service on third-party apps or websites, including social media.  
  • Tracking: You may be able to disable certain tracking through features in your web browser, but such disabling may impair use of the Site and Services.  However, our systems do not recognize browser “do-not-track” requests. 

Third Party Analytics

We use Fathom Analytics for our website analytics, which doesn’t use cookies. Using this privacy-friendly analytics software, your IP address is only briefly processed, and we (running this Site) have no way of identifying you through this software. Your  Personal Data is de-identified. You can read more about this on Fathom Analytics’ website at 

Third-Party Links

Our Site and Services may contain links to third-party websites.  Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Retention of Information and Personal Data

We generally retain Information and Personal Data for as long as reasonably required to fulfill the purposes of collecting such information.  We may retain certain Personal Data for longer periods if required by law or for legitimate business purposes.  We may also retain cached or achieved copies of information collected via this Site as required by law or for legitimate business purposes.

Security of My Personal Data 

We strive to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction; however, we cannot assure or guarantee the security of transactions on the blockchain and transmissions through the Internet. 

What Rights Do I Have Regarding My Personal Data

You may request access, a copy, correction or deletion of Personal Data that you have submitted to us by contacting us at We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain Personal Data to comply with legal obligations, accounting requirements, or for other business purposes.  We may request additional information to verify the identity of the requesting party before responding to a request.  Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time. If you are a resident of the EU or the United Kingdom, you may have additional rights as set forth below.

EU and UK Residents

If you are a resident of the UK or the EU, you may request the following:  

  • Right to access and rectification: you can request Personal Data we hold and the correction of any errors of your Personal Data.
  • Right to erasure/deletion: the right, in certain circumstances, to ask for your Personal Data to be deleted. In specific cases, we may not be able to delete some types of Personal Data, in particular, where we have a legal obligation to keep that  Personal Data (e.g., for regulatory reporting purposes), or where you want us to continue to provide you with a Service and the processing of the Personal Data is necessary for the provision of that Service.
  • Right to restriction of processing: the right, in certain circumstances, to restrict further processing of your Personal Data. 
  • Right to portability: the right in some cases to receive your Personal Data in a digital format or to have it transmitted directly to another controller (where technically feasible)
  • Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Personal Data on the basis of our legitimate interests, including for direct marketing purposes.
  • Right to withdraw consent: you can withdraw your consent at any time in respect of any processing of Personal Data which is based upon a consent.
  • Right to lodge a complaint before the supervisory authority for data protection in your country, if you consider that your rights under the applicable privacy legislation have been infringed. 

Legal Basis for Processing

To the extent required by applicable laws, we rely on the following legal bases for processing Personal Data:

  • Our legitimate interests where those interests are not overridden by the interests or fundamental rights and freedoms of the data subject.  
  • As necessary to enter or perform a contract.
  • Where the data subject has given consent to the processing of his or her Personal Data for one or more specific purposes.
  • To comply with our legal obligations.

What Choices Do I Have Regarding Use of My Personal Data for Marketing?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us. In addition, you can turn off certain kinds of tracking technologies through the preferences in the cookies setting. 

Location of Information and Personal Data

Our Site and Services are offered from the United States.  We store any information we collect in the United States.  If you access the Services or Site from outside the United States, you agree to the transfer of your information to the United States, which may have less protections for your Personal Data than your jurisdiction of residence.

Children Under 13

Our Site and Services are not designed for children under 13.  If we discover that a child under 13 has provided us with Personal Data, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time in our sole discretion, so please be sure to check back periodically.  We will post any changes to this Policy on the Site and provide notice if required by applicable law.  To the extent permitted by law, your  use of the Site and Services after such posting or notice constitutes your acceptance of such change.