The Dot Net Factory, LLC dba EmpowerID – Website Privacy Policy

Effective: October 10, 2018

At The Dot Net Factory, LLC dba EmpowerID. (“EmpowerID”, “we”, “us”, “our”), we are committed to respecting your privacy. We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner and to protect and safely manage any personal information that you share with us. This Privacy Statement explains who we are, how we collect, share and use personal information we collect about you and how you can exercise your privacy rights.

“Personal Information” means any information that may be used to identify an individual, either directly or indirectly.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the bottom of this Privacy Statement.

We recommend that you read this Privacy Statement in full to ensure you are fully informed.


“Affiliates” refers to present or future companies that, directly or indirectly, through one or more intermediaries, control, are controlled by, or are under common control with EmpowerID.

Materials” refers to the software, courseware, toolkits, documentation and all other information, whether tangible or intangible, that EmpowerID makes available on the website and related materials.

“Services” refers to the services provided by EmpowerID in connection with the Materials, as well as any other related education or training services provided by or through EmpowerID. “User Content” refers to any data, text, links, media, or other content that you submit to EmpowerID via a Website.

“Website” refers to the website and all other related sub-domains which includes text, media, documentation, pictures, and other content.

“Visitors” refers to individuals who visit a Website.

What does EmpowerID do?

EmpowerID is a provider of enterprise identity and access management software and services, headquartered in the United States.

For more information about EmpowerID please see the “Company” section of our Website at

Collection, Use and Purpose Limitations of Your Information

Information you provide voluntarily:

Certain parts of our Website may ask you to provide Personal Information voluntarily, such as in order to register an account with us, to subscribe to marketing communications from us, or in submitting enquiries to us. Where EmpowerID collects Personal Information on a Website, we will explain why such Personal Information will be collected. Information you provide voluntarily:

When you participate in, access or sign up to receive any of EmpowerID’s Services, activities or online content, such as email publications, blogs, newsletters, live chats, EmpowerID may receive Personal Information about you. This may consist of contact information but may also include other Personal Information that you voluntarily provide.

Automatic Collection of Information:

When you visit our Website, EmpowerID will gather certain information about your visit and your device automatically. This information may, for example, reflect how you found or were directed to or used the Website. It may collect the name and URL of the website that you visited immediately preceding your visit to a Website. EmpowerID may use this type of information on a cumulative basis to better understand what pages Visitors and prospective customers access or visit, and EmpowerID may disclose this information to business and trade partners as well as EmpowerID’s Affiliates in an aggregated form. For information on who we share your information with, and why, please see “Disclosures, Sharing and Onward Transfers of Your Information” below.

Our Cookie Policy and Use of Other Tracking Technologiesy

From time to time, some of EmpowerID’s Websites may utilize “cookies” and other tracking technologies. When you visit our Website, EmpowerID may place one or more “cookies” on your computer. A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a website Visitor. EmpowerID uses cookies for all or any of the following purposes:

  • Identify you when you access, visit, or log-in to any Website. This enables you to re-visit any Website without having to re-enter information upon each visit.
  • To note different areas of any Website which have recently been accessed through your computer. Information collected in this way may be used to develop and manage the online services of EmpowerID by, for example, storing information about your preferences so as to enable EmpowerID to customize any Website according to your individual interests.
  • Delivering content on any Website which is relevant to your individual interest.
  • Monitoring the effectiveness of any promotions or marketing campaigns by EmpowerID or its Affiliates.
  • Tracking your entries, submissions, and status in promotions, sweepstakes, and contests.
  • Improving any Website content and conducting various other diagnostics to improve EmpowerID’s services. EmpowerID may, for example, use cookies to monitor aggregate metrics such as total number of Visitors and pages viewed.
  • Analyzing and improving Website security.

The Websites do not respond to “do not track” signals from browsers. Thus, your selection of the “do not track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. To effectively manage our collection of cookie information, you may set most browsers to notify you if you receive a cookie, or you may choose to block cookies through the settings associated with your browser. But, please note that if you choose to erase or block cookies, you will need to re-enter your original information (e.g., user name, password, or general contact info) to gain access to certain parts of the Websites and may not be able to access other parts of the Websites.

EmpowerID may also use tracking technologies that record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that any Website are accessed by Visitors. EmpowerID may also analyze information for trends and statistics, such as through the use of Google Analytics or other similar analytics services.

Disclosures, Sharing and Onward Transfers of Your Information

Who does EmpowerID share my Personal Information with?

We may disclose your Personal Information to the following categories of recipients:

  • to our group companies, Affiliates, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or Services), or who otherwise process Personal Information for purposes that are described in this Privacy Statement or notified to you when we collect your Personal Information.
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Information only for the purposes disclosed in this Privacy Statement;
  • to any other person with your consent to the disclosure.

International data transfers

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your countr y (and, in some cases, may not be as protective).

Specifically, our Website servers are located in the United States, and our third-party service providers and partners operate around the world. This means that when we collect your Personal Information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Statement.

Privacy Shield

Where Personal Information originates from the European Economic Area or Switzerland and is transferred to the United States, EmpowerID agrees to comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, respectively. EmpowerID makes an affirmative commitment to adhere to EU-U.S. and Swiss-U.S. Privacy Shield Principles (the “Privacy Shield Principles”). With respect to such Personal Information, to the extent of any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles govern. More information on the EU-U.S. and Swiss-U.S. Privacy Shield programs can be found at

Legal Basis for Processing Personal Information (EEA visitors only)

If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the Contact Information heading below.


Wherever your Personal Information may be held within EmpowerID or on its behalf, EmpowerID takes reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. EmpowerID trains its employees on data handling practices. In addition, EmpowerID and its business partners enter into confidentiality agreements which require that care and precautions be taken to prevent loss, misuse, or disclosure of your Personal Information.

Data Retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Your Data Protection Rights and Choices

  • If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided under the Contact Information heading below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the Contact Information heading below.
  • object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the Contact Information heading below.
  • Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Privacy Policies of Third-Party Websites

Our Website may contain or reference links to non-EmpowerID websites. EmpowerID has no control over, and assumes no responsibility for, the content, privacy policies (if any), or practices of any third-party website or any link contained in a third-party website. The inclusion of a link within any Website does not imply any endorsement by or any affiliation with EmpowerID. Access to any third-party website is at your own risk, and you should be aware that third-party websites may contain privacy policies that have terms that are different from that of this Privacy Statement.

In connection with your use of any Website, you may be made aware of services, products, articles, offers, and promotions provided by third parties, and not by us.

Change Management of Privacy Statement

EmpowerID may amend this Privacy Statement from time to time by posting a revised policy on our Website. If EmpowerID makes material changes to this Privacy Statement, EmpowerID will endeavor to notify you of such changes (e.g., by email or an alert on any Website for a period of time). However, regularly reviewing this page is the best method to ensure you are always aware of the information EmpowerID collects, how it is used and under what circumstances.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.

Children’s Personal Information Policy

EmpowerID does not knowingly solicit any Personal Information from children under the age of 16. If EmpowerID is made aware that EmpowerID has Contact Information collected Personal Information from a child under 16 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act of the United States, then EmpowerID will delete this information as soon as practicable.

Contact Information

For disputes regarding EmpowerID’s collection or use of your Personal Information or for more information, or questions or comments concerning the Privacy Statement, please contact EmpowerID at:

c/o Web Privacy Manager
4393-A Tuller Road
Dublin, Ohio 43017

You may also stop email messages and other promotional mailings by contacting EmpowerID at the above address or email.

Our goal is to resolve all disputes through our internal processes. If you have a complaint regarding our collection, use, disclosure or retention of Personal Information originating from the European Economic Area or Switzerland that cannot be resolved through those processes, you may:

      submit the complaint to the relevant data protection authorities, EU Data Protection Authorities and Swiss Federal Data Protection and Information Commissioner (FDPIC) (“DPAs”);
      at no cost to you, resolve the complaint through JAMS using this link:; or
      provide notice to EmpowerID that you desire to resolve the complaint through binding arbitration. EmpowerID is subject to the enforcement powers of the U.S. Federal Trade Commission. In the event that we or such authorities determine that we did not comply with this Privacy Statement, we will take appropriate steps to address any adverse effects and to promote future