Privacy Policy
Last updated: May 13th, 2025
1. INTRODUCTION AND GENERAL BACKGROUND
1.1. SP Distribution LLC ("DFY Ordinary", "we", "us", "our") presents this privacy policy, as may be amended from time to time (the "Privacy Policy" or "Policy") in order to provide our website user ("User", "you" or "your") information about DFY Ordinary’s information protection practices in relation to Personal Information that is collected, used and/or otherwise processed by DFY Ordinary and/or third parties acting on its behalf, through the website its related domain (i.e., www.dfyordinary.com) (the "Website").
1.2. When accessing, browsing and using the Website, you may be required to provide DFY Ordinary with Personal Information about yourself that is protected by law.
1.3. This Privacy Policy supplements our Terms & Conditions and our Cookie Notice.
1.4. If you have questions or concerns regarding this Privacy Policy, please contact us at privacy@us.dfyordinary.com.
1.5. PLEASE SEE OUR FULL PRIVACY POLICY BELOW IN ORDER TO BETTER UNDERSTAND OUR PRACTICES IN DETAIL.
2. WHAT PERSONAL INFORMATION DO WE PROCESS ABOUT YOU AND FOR WHAT PURPOSES?
When we use the term “Personal Information” in this Privacy Policy, we mean any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device.
We have collected the following categories of personal information within the last twelve (12) months:
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Category of Personal Information we Collect |
Category of Sources of Personal Information |
Purposes |
Example of use of Personal Information |
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· Identifier: i.e., first and last name, country/region, ZIP code, state, city, address, apartment (optional), email address, IP address.
· Contact details: i.e., phone number.
· Sensitive Personal Information (SPI): i.e., financial information, such as bank account, credit/debit card number, holder of the card, or any other financial information
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Such Personal Information is provided directly from the User through the Website during the purchasing process. |
Processing order |
· to confirm your product(s) purchase · to pay your selected product(s) · to deliver your selected product(s) |
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Pre-litigation or litigation management |
· to manage any dispute or litigation involving you with respect to the Website · to establish, protect, or exercise our legal rights · to defend against legal claims or demands. |
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Compliance with legal and regulatory obligations |
· to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities · to process your requests to exercise your rights · to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. |
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· Identifier: i.e., first and last name, ZIP code, state, city, address, email address, IP address.
· Contact details: i.e., phone number.
· Data related to your exchanges with DFY Ordinary for contact requests (i.e., date, area of subject and content of your exchanges with DFY Ordinary's staff). |
Such Personal Information is provided directly from the User through the Website through forms. |
Managing your contact request |
· to answer your questions · to respond to inquiries |
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Managing your support request |
· To create a ticket · To process your request · To answer your request |
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Managing marketing communications |
· to add you in our mailing list · to send you updates and exclusive offers · to unsubscribe you from our mailing list |
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Pre-litigation or litigation management |
· to manage any dispute or litigation involving you with respect to the Website · to establish, protect, or exercise our legal rights · to defend against legal claims or demands. |
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Compliance with legal and regulatory obligations |
· to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities · to process your requests to exercise your rights · to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. |
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Internet or other similar network activity: We collect such information when the User interacts with the Website, such as browsing history, search history, information on interaction with the Website, or advertisement. This data might be collected directly by us or by through our use of third parties' cookies and advertisement platforms. For more information on the cookies used, please see our Cookie Notice.
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Such data is directly and indirectly from activity on our Website: For example, directly from you when you inquire about our services via the Website, or indirectly, we collect your usage data automatically from measurement tools.
We do not respond to web browser-based DNT signals at this time, but we do not collect information about Users’ online activities across third-party websites. For more information, visit: https://www.eff.org/issues/do-not-track |
Improving the Website |
· to monitor and analyze your use of the Website · to develop, customize and improve the Website; · research and further development, analysis and statistics. |
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Supporting and enhancing data security measures of the Website |
· to prevent and mitigate the risks of fraud, error or any illegal or prohibited activity · technical administration and troubleshooting of the Website · to diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse. |
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Pre-litigation or litigation management |
· to manage any dispute or litigation involving you with respect Website · to establish, protect, or exercise our legal rights · to defend against legal claims or demands. |
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Compliance with legal and regulatory obligations |
· to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities · to process your requests to exercise your rights · to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. |
3. WITH WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
3.1. We may disclose your Personal Information to a contractor or service provider for a business purpose. We further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we have disclosed the categories of Personal Information described in section 2 above for a business purpose:
3.1.1. Our Affiliates. Your Personal Information has been shared with our affiliates to manage the Website and the companies' services.
3.1.2. Contractors and Service Providers, including shipping companies, financial service providers, data storage providers, data security services, fraud detection and prevention services, product analytics, session or activity recording services, content transcription and analysis services, performance measurement, advertising and marketing service providers, partnered brand, consent manager (CMP) which is external service that provides use with the ability to allow website visitors to control and manager their cookies and other tracking preferences and consent, insurers. We disclose Personal Information with selected third-party companies and individuals we engage to perform services on our behalf, such as improving and optimizing the Website, process Personal Information in the context of provision of analytical services to us, for operational, commercial and technical purposes related to the management of the Website and its services as well as for the purchase and delivery of DFY Ordinary’s products. We only provide such contractors and service providers with Personal Information so they can perform their required functions on our behalf.
3.1.3. Public Authorities. We have disclosed or allowed government and law enforcement officials access to certain Personal Information, exclusively subject to a law request, such as tax authorities.
4. HAVE WE SHARED OR SOLD YOUR PERSONAL INFORMATION?
4.1. In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment. However, for retargeting and analytic purposes, when we promote our products, we use third-party tools that are able to market our products online, measure these marketing efforts, identify individuals that are interested in our products, etc. This is done by placing cookies, pixel or other tracking technology on our Website and sharing with these vendors the online identifiers and online behavior information.
4.2. In the preceding twelve (12) months, we “sell” or “share” the categories of Personal Information described in section 2 above to partnered brand when you decide to take part in a giveaway.
5. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION FOR?
5.1. We retain Personal Information for as long as you use our Website, until we answer your requests and as necessary to deliver our products and its related services.
5.2. Other circumstances in which we will retain your Personal Information for longer periods of time include:
5.2.1. where we are required to do so in accordance with legal and regulatory requirements, or
5.2.2. for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or
5.2.3. to resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
5.3. Please note that except as required by applicable law, we will not be obligated to retain your information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
6. HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
6.1. We endeavor to maintain appropriate technical and organizational measures compliant with industry standards to protect Personal Information in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
6.2. However, although we make every effort to protect the Personal Information which you provide to us or we generate, we cannot completely ensure the security of any Personal Information you transmit to us over the internet or guarantee that this Personal Information will not be accessed, disclosed, altered, or destroyed.
6.3. If you have found a vulnerability or would like to report a security incident, you may send an email to privacy@us.dfyordinary.com.
7. CHILDREN
7.1. The Website and its services are directed towards and designed for use by individuals aged 16 and older. We do not solicit or knowingly collect Personal Information from children under the age of 16.
8. WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL INFORMATION?
8.1. Users Personal Information Rights
8.1.1. Rights of California Residents. If our Processing of your Personal Information is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Right Act of 2020 ("CCPA"), you are entitled to the following rights:
i. Right to Know what Personal Data we Have Collected. You have the right to request what Personal Information we have collected, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
ii. Right to Deletion. You have the right to request the deletion of your Personal Information that we collect or maintain, subject to certain exceptions.
iii. Right to Correction. You have the right to request the correction of your inaccurate Personal Information that we maintain about you.
iv. Right to Opt-Out of Sharing for Cross-Contextual Behavioral Advertising. You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising”.
v. Right to Opt-Out from Selling. You have the right to opt-out of the sale of your Personal Information to third parties.
vi. Right to Limit the Use or Disclosure of Sensitive Personal Information. Under certain circumstances, to the extent we use or disclose SPI, you have the right to limit the use or disclosure of SPI.
vii. Right to Opt-Out of the Use of Automated Decision Making. In certain circumstances, and to the extent applicable, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
viii. Right to Data Portability. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.
ix. Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights regarding your Personal Information under the CCPA.
8.1.2. Only you may make a request related to your Personal Information. If you are a California resident a request can be made by a person registered with the California Secretary of State that you authorize to act on your behalf, in such event you must provide us with signed documentation that you have authorized an agent to act on your behalf.
8.1.3. Rights of Colorado Residents. If our Processing of your Personal Information is subject to the Colorado Privacy Act ("CPA"), you are entitled to the following rights:
i. Right to Access/Right to Know. You have the right to confirm whether and know the Personal Information we collected on you.
ii. Right to Deletion. You have the right to request the deletion of your Personal Information that we collect or maintain, subject to certain exceptions. Please note that we will delete or de-identify Personal Information not subject to one of the exceptions and will direct our subcontractors to take similar action.
iii. Right to Correction. You have the right to correct inaccuracies in your Personal Information, taking into account the nature and purposes of Processing of such Personal Information.
iv. Right to Opt-Out from Selling. You have the right to opt-out of the sale of your Personal Information to third parties. We do not have actual knowledge that we sell Personal Information.
v. Right to Opt-Out of the Use of Automated Decision Making. In certain circumstances and to the extent applicable, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
vi. Right to Data Portability. You have the right to obtain the Personal Information in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance.
vii. Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights regarding your Personal Information under the CPA.
8.1.4. Rights of Virginia Residents. If our Processing of your Personal Information is subject to the Virginia Consumer Data Protection Act, as amended ("VCDPA"), you are entitled to the same rights as Colorado residents described above in Section 8.1.3.
8.1.5. Rights of Connecticut Residents. If our Processing of your Personal Information is subject to the Connecticut Data Privacy Act ("CDPA"), you are entitled to the same rights as Colorado residents described above in Section 8.1.3.
8.1.6. Rights of Utah Residents. If our Processing of your Personal Information is subject to the Utah Consumer Privacy Act ("UCPAA"), you are entitled to the same rights as Colorado residents described above in Section 8.1.3.
8.1.7. Right of Nevada Residents. Subject to several exceptions, Nevada law allows Nevada residents to opt out of the sale of certain types of Personal Information. We currently do not “sell” Personal Information as defined in the Nevada law.
8.2. Exercise your rights. You can exercise your above rights by contacting us via contact details described in Section 11 below.
9. DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY LINKS?
9.1. You may, during your use of the Website, access links to or other websites operated by third parties outside of DFY Ordinary.
9.2. Please note that this Privacy Policy only applies to Personal Information that we (or third parties on our behalf) collect from or about you on the Website only and we cannot be responsible for Personal Information collected and stored by third parties.
9.3. Third party websites, have their own terms and conditions and privacy policies, and you should read these carefully before you submit any Personal Information to these websites.
9.4. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
10. CHANGES TO THIS PRIVACY POLICY
10.1. This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new or updated privacy policy in our Website. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy. The new or updated privacy policy will be effective from the date mentioned at the top page of the new privacy policy.
10.2. This Privacy Policy was last updated on May 13th, 2025, and we will update it every 12 months.
11. CONTACT INFORMATION
SP Distribution LLC
• By email: privacy@us.dfyordinary.com
• By mail: 320 Miracle Mile, Suite 201, Coral Gables, Florida, USA, 33134