MOBILE APPLICATION PRIVACY POLICY

Dovu Limited (DOVU) (we) are committed to protecting your personal data and respecting your privacy.

INTRODUCTION  

This policy (together with our End-user licence agreement) and Terms and Conditions DOVU Wallet, together our Terms of Use) applies to your use of:


  • DOVU Wallet VERSION BETA mobile application software (App) available on our site (Dovu.App Site) or in Google Play BETA, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

Dovu Limited (DOVU) is the controller and is responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 28 March 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

  1. THE DATA WE COLLECT ABOUT YOU  

We may collect, use, store and transfer different kinds of personal data about you as follows:

We explain these categories of data here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?  

We collect your personal data through a signup form on mobile and/or web app. We will collect and process the following data about you:

          Device Data from the following parties:

 

 

  1. HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user and verify your account

Identity

Contact

Device

Your consent

To process in-App purchases and deliver Services including managing transfers of DOV tokens and collecting DOV tokens owed to us

Identity

Contact

Transaction

ERC-20 Wallet

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, including notifying you of changes to the App or any Services

Identity

Contact

Profile

Marketing and   Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content to you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)



  1. DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

 

  1. INTERNATIONAL TRANSFERS

We aim to keep your personal data inside the European Economic Area (EEA).

Some of our External third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. DATA SECURITY  

All information you provide to us is stored on our secure servers. Any transfer of DOV tokens transactions carried out by us or our chosen third-party provider of processing services will be encrypted using Transport Layer Security technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will store the data in External Third Party servers: AWS  and Google Cloud simultaneously. Further details about these External Third Parties could be found in Glossary. All data is being stored in the relevant legal entities UK datacenters. We use industry-standard encryption of passwords, by hashing the passwords by secure algorithm. Access to all channels containing critical and sensitive information, to the database is protected with two-factor authentication (2FA). We use TLS (Transport Layer Security) - traffic to and from our server and user passwords are appropriately encrypted. Company wide policy on Security.

We will collect and store your preferences on your Device using application data caches and browser web storage (including HTML5).

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

  1. DATA RETENTION  

By law we have to keep basic information about our customers (including Contact, Identity, ERC-20 Wallet and Transaction Data) for 6 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 1 year then we will treat the account as expired and your personal data may be deleted.

  1. YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

(a)  if you want us to establish the data’s accuracy;

(b)  where our use of the data is unlawful but you do not want us to erase it;

(c)  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)  you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at [email protected]

 

  1. GLOSSARY  

LAWFUL BASIS  

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES  

Internal Third Parties: None.

External Third Parties:

Service providers acting as processors based in United Kingdom and United States of America, who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers based in United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, FCA (Financial Conduct Authority) regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Amazon Web Services Inc. (AWS), P.O.Box 81226, Seattle, WA 98108-1226, USA, we use their servers in EEA. Their Privacy Policy could be found here.

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94042, USA, we use their servers in EEA. Their Privacy Policy could be found here.

Crashlytics, defined as Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4 , Ireland, we use their servers in EEA. Their Privacy Policy could be found here.

SendinBlue SAS, Politique de confidentialité, 55, rue d’Amsterdam 75008 Paris, France, we use them for marketing and newsletter distribution purposes. Their Privacy Policy could be found here.

Atlassian Corporation Plc., with registered office Exchange House, Primrose Street, London EC2A 2EG, c/o Herbert Smith Freehills LLP. We use them for smooth customer support integration purposes only. There is a potential some of the data to be transferred outside the EEA. They are approved member of the EU-US Privacy Shield Frameworks. Their Privacy Policy could be found here.

Twilio Inc, 375 Beale Street, Suite 300, San Francisco, CA 94105. We use Twilio for account wallet verification, where we limit the data sharing to minimum. There is a potential some of the data to be transferred outside the EEA. Their Privacy Policy could be found here.

Your mobile network operator.

  1. DESCRIPTION OF CATEGORIES OF PERSONAL DATA  

 

This Policy was last updated on 28 March 2019.