Dell North America Privacy Statement

The types of information we collect about you depend on your use of our Sites and Services, and the ways that you interact with us.  This includes personal information you provide directly to us when you:

• apply for, purchase and/or use our Sites and Services, including financial services to commercial customers;
• create an account;
• access and use our websites and mobile apps;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion, or survey; or
• give us feedback, provide a testimonial, or contact us.

• Service providers that collect or provide data in connection with work they do on our behalf, including companies that determine your device’s location based on its IP address, communication providers (such as our email, telephone, and chatbot providers), and cloud-hosting service providers;
• Analytics providers, advertising networks, and communication services providers, including email providers and social networks, when you allow access to your information available on third-party services or networks. This may include data collected through cookies, pixels, and similar tracking technologies provided by our service providers and ad tech providers, to help us understand your interactions with our advertisements and measure and improve our marketing efforts;
• Partners with which we offer co-branded products or services or engage in joint marketing activities;
• Publicly available sources, such as open government databases;
• Credit and fraud prevention agencies;
• Insurance companies, brokers, and administrators;
• Auditors, regulators, and supervisory bodies; and
• Public authorities and law enforcement agencies.

We collect personal information from these sources, directly from you and automatically from the devices you use to access Dell’s Sites and Services, including:

• Contact data, identity data, first name, last name, title, job title, date of birth, gender, address, email address, telephone number, or similar identifier, proof of identity which may include photographic ID.
• Payment data, bank account details, payment card details, transaction details, finance application details and records, details about payments to and from you, and the results of any checks (for financial service offerings) we carry out about you.
• Transaction data, details of products and services you have purchased from us.
• Cookies and tracking information, such as internet protocol (IP) address, your login data, access times, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, the Uniform Resource Locator (URL), and other technology on the devices you use to access this website.
• Account data, including identity data, your username, password, password hints, and similar security information, used for authentication and MyAccount access.
• Preferences data, such as purchases or orders made by you, your interests, feedback, and survey responses. When you attend our in-person events, we may ask you for your dietary preferences or other information to help make your experience more enjoyable.
• Usage data, information about how you use, interact, and access our Sites and Services, and information relating to operation of Dell products and services. This includes system information related to your device, system, or network (such as your Dell Service Tag, IP address, hardware model, operating system version, hardware settings, installed Dell Solution, system and application configuration data, and MAC address) and how your device, system, network interacts with Dell Solution (such as statistical information, network connection indicators, system crashes, data logs, and routing).
• Troubleshooting information, error reports and Sites and Services performance information, and any problems you experience when you contact Dell for technical support or customer support services, phone conversations, or chat sessions with our representatives, which may be monitored and recorded.
• Marketing and communications data, your preferences in receiving marketing from us and our third parties and your communication preferences.
• Inferred Data, information we create or generate based on the personal information we collect, including using automated means to generate information about your likely preferences or characteristics. For example, we infer your general geographic location (such as city, state, or country) based on your IP address.
• Aggregated data, statistical or demographic data. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyze general trends in how users are interacting with our website to help improve the website and our service offering.

Categories of Sensitive Data

Through our interactions with you, and in order to provide you with the Dell Sites and Services or fulfil your request, we may collect Account data, Payment data, or Preferences data as described above. Under applicable privacy laws some of this may be considered “sensitive data.” Recipients of this data include service providers and payment processing providers. For categories of sensitive personal information that we collect, we will use or disclose it either with your specific consent when required, or as otherwise permitted by law, including the CCPA. Please note that we do not disclose sensitive data for purposes other than those specified under the CCPA Regulations in §7027(m).

We describe below ways we may use the various categories of your personal information and the legal bases we rely on to do so.

We may disclose personal information to the following recipients:

• other parties (such as a service provider or contractor) we use to help deliver our Sites and Services to you or otherwise run our business, e.g., payment service providers, warehouses, delivery companies, marketing agencies, website hosts, analytics providers, etc.;
• advertising companies may receive personal information from us and also collect personal information through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this Privacy Statement. These vendors may combine this data across multiple sites to improve analytics for their own purpose and others;
• external auditors or professional advisors, e.g., lawyers and other advisors, in which case confidentiality obligations will bind the recipient of the information;
• law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations;
• such third parties to whom we may sell, transfer, or merge parts of our business or assets; we may also seek to acquire other businesses or merge with them. If a change happens to our business, then the recipients of your personal information may use your personal information in the same way as set out in this privacy policy;
• we may disclose your personal information to a third party where you direct and/or authorise us to do so;
• we may disclose de-identified information in accordance with applicable law.

• Notice at Collection: At or before the time of collection, you have a right to receive notice of our privacy practices, including the categories of personal information and sensitive personal information we collect, the purposes we collect or use personal information, whether such information is “sold” or “shared”, and how long we retain personal information. You can find those details in this Privacy Statement by clicking on the above links.
• Right to Know or Access: you may have the right to request access to the personal information we have collected about you and for what purpose.
• Right to rectification: you may have the right to request that we correct incomplete or inaccurate personal information. We may need to verify the accuracy of the new data you provide.
• Right to request deletion (“right to be forgotten”): you may have the right to request the deletion of the personal information that we process about you.
• Right to opt-out from targeted advertising and our sales and sharing of personal information – you may have the right to opt out from targeted advertising and future “sales” of personal information, including “sharing” of personal information for cross-context behavioral advertising (or as these terms are defined by local laws). For example, we “sell” or “share” certain cookies and tracking data and usage data with online advertising providers for targeted advertising purposes, as defined under California and other applicable laws. Please see our Cookies, Ads and Emails notice for more information on how we and our online advertising providers collect and use information for targeted advertising purposes. If you opt-out, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the law. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising. Finally, we do not knowingly sell or share the personal information of minors under 16 years of age.
• Right to Limit Use and Disclosure of Sensitive Personal Information: you may have the right to limit our use of sensitive personal information for any purpose other than to provide the Sites and Services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.
• Right to Opt-Out from Profiling and Automated Decision-Making: You may have a right to opt-out from profiling and/or automated decision-making that produces a legal or similarly significant effect.
• Right to restriction of processing: you may have the right to request the restriction of processing of your personal information.
• Right to Portability: you may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization in certain circumstances.
• Right to object to processing: you may have right to object to processing of your personal information where we rely on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data.
• Right to withdraw Consent: you may have the right to withdraw consent, where we process your personal information based on your consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
• Right not to be retaliated against: you have the right to exercise your privacy rights conferred upon you by applicable law, such as the CCPA, without being retaliated against.

You may see our California Privacy Rights Reporting Metrics here.

Exercising Your Rights:

This section describes how to exercise the rights described above.

• Right to opt out from “sales” of personal information or “sharing” of personal information for cross context behavioral advertising
  • Your Privacy Choices Link: You can visit our “Your Privacy Choices" page via the link at the bottom of our website to exercise your request. This will direct you to our privacy request portal to complete your request.
  • Global Privacy Control. Please review the “Browser and Platform Controls” section of our Cookies, Ads and Emails notice for more information on how we process signals from the Global Privacy Control.
  • Email and Postal Mail Requests You, and (where permitted by law) your authorized agent may send a request by email or mail using our contact information listed below.

Non-Logged-In Users: If you or your authorized agent use the Your Privacy Choices link or Global Privacy Control to exercise your sale/sharing opt out and are not logged in to your Dell account, we will need some additional information from you to fully process your request. If you choose to proceed with the sale/sharing opt out without logging into your account or providing additional information, we will process this opt out request for your specific browser, application, or device (including any associated profile in our system).

• Right to opt-out from targeted advertising: Please review the “Browser and Platform Controls” described in our Cookies, Ads and Emails notice for details on how you can opt out from targeted advertising. You can also exercise your right to opt out by clicking here and toggling off the Marketing and Statistical cookies. If you wish to opt from sales or sharing of personal information in addition to opting out from targeted advertising, please follow the instructions provided above. Please note that even if you opt out of targeted advertising, we will still use some personal information to help us perform advertising-related functions, but the advertising will not be personalized to you.
• All other rights: If you wish to exercise your privacy rights, please visit our Privacy Center and submit a request via our Privacy Request Portal Dell-PMC or send us your request by email or postal mail using the contact details below. To help protect the security of your personal information, we will request specific information from you to verify your identity. There may be circumstances where we cannot grant your request — for example, if you ask us to delete your transaction data and Dell is legally obligated to keep a record of that. If you have exercised your rights and believe your request was denied, you can exercise your right to appeal the results of your request by contacting privacy@dell.com. If your appeal is unsuccessful and depending upon the state where you live, you may have the right to raise a concern or lodge a complaint with your state attorney general.

Depending on where you reside, you may designate an authorized agent to submit an opt-out request on your behalf. If you are an authorized agent submitting an opt-out request on behalf of a customer, you may do so my sending an email to privacy@dell.com and including the customer’s name an email address. We can only process this request, where eligible under applicable state privacy laws, if we can match the email to a known customer account. This request will not apply at the device level so it will not affect browser-specific or app-specific settings.

Except for any automated controls described above, if you send us a request to exercise your rights or your privacy choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates (where we are required to first authenticate), the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may have a right to appeal that decision by submitting your appeal using the contact method described at the bottom of this Privacy Statement or submitting your request via our Privacy Request Portal Dell-PMC.

Communication Preferences: You have choices about how we reach you with marketing offers and other uses of your information. To update your preferences, you can:

• Click “unsubscribe” in any email marketing communications we send you.
• Go to your MyAccount or visit our Preference Management Center to select your marketing communication choices.
• Go to our List Removal Page to be removed from receiving marketing-related communications or otherwise indicate which channels you do not want us to use to provide you with marketing communications.

Please be aware that your email preferences may take up to 10 business days to take effect. Further, even if you opt out of receiving marketing communications, you will still receive transactional communications that are essential for administrative or customer service purposes, such as order confirmations for a product/service warranty registration, updates to our Terms and Conditions, etc.

Targeted Advertising: To opt-out from or otherwise control targeted advertising, you have several options Please see our Cookies, Ads and Emails notice for more information about the controls you can use to opt out from targeted advertising.

We use appropriate mechanisms for international data transfers. For example, we rely on Standard Contractual Clauses, approved by the European Commission (and the equivalent standard contractual clauses for the UK or Switzerland, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

We comply with this law by offering our customers a choice about the disclosure of personal information to third parties for their direct marketing purposes, and you can make or change such choice as described in the “Your marketing communication choices” section above.

Summary of the Program. Through our Dell Rewards Program, participants may receive rewards or other benefits in connection with purchases or account activity. Participation is voluntary and subject to the applicable program terms.

Personal Information Collected. When you opt in to participate in a Dell Rewards Program, we may collect and process the following categories of personal information, depending on how you interact with the program:

• Identifiers (such as name, email address, account credentials);
• Commercial information (such as purchase history and rewards activity);
• Internet or other electronic network activity information (such as interactions with our website or account portal).

The categories of personal information involved may vary by program.

How to Participate. You may join a Dell Rewards Program by enrolling through your online account or other registration method provided at the time of sign‑up. By enrolling, you understand that we will collect, use, retain, and disclose personal information as described in our Privacy Statement and the applicable program terms.

Right to Withdraw. You may withdraw from a Dell Rewards Program at any time by following the instructions in your account settings or by contacting us as described in the “Contact Us” section of this Privacy Statement. If you withdraw, you will no longer receive program benefits going forward, but withdrawal will not affect benefits already earned to the extent permitted by program terms.

How the Incentive Is Valued. The benefits offered through our Dell Rewards Programs are reasonably related to the value of the personal information provided. We estimate the value of personal information in good faith by considering factors such as:

• the financial value derived from increased customer engagement and purchases associated with program participation; and
• the costs associated with providing program benefits.

You can email to: privacy@dell.com to contact us and our Chief Privacy Officer, Lavonne Burke, Vice President, Legal if you have any questions about this Privacy Statement or the information we hold about you, to exercise a right under data protection law, or to make a complaint.