This Policy was updated on 31 March 2020.
Dovu respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.
You can view an archived version of the previous version of the policy here.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how DOVU collects and processes your personal data through your use of our websites, including any data you may provide through our websites when you sign up to our newsletter or take part in a competition or a survey.
This website is not intended for children and we do not knowingly collect data relating to children. If we learn that we have collected PII of a child under 13 years old, we will take steps to delete such information from our files as soon as possible.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Dovu Limited is the controller and responsible for your personal data (collectively referred to as ”COMPANY”, “we”, “us” or “our” in this privacy notice). We are registered as a data controller with the Information Commissioner's Office with number ZA251455.
This privacy notice is issued on behalf of the Group so when we mention ”COMPANY”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data. Dovu Limited is the controller and responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Dovu Limited
Name or title of data privacy manager: Krasina Mileva
Email address: [email protected]
Postal address: Dovu Limited, 86 Bedminster Parade, BS3 4HL, Bristol, United Kingdom
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
YOUR DUTY TO INFORM US OF CHANGES
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 your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Device Data from the following parties:
4. 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
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data||Lawful basis for processing including basis of legitimate interest|
To register you as a new customer and verify your account.
To install the App, register you as a new App user and verify your account.
(a) Performance of a contract with you
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Subscribe to a plan and/or redeem DOV tokens
(d) To process in-App purchases and deliver Services including managing transfers of DOV tokens and collecting DOV tokens owed to us
(f) Device and Location
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(f) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you
To monitor trends so we can improve the App
(h) Marketing and Communications
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing .
We will get your express opt-in consent before we share your personal data with any company outside the group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. 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 might 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:
7. DATA SECURITY
All information you provide to us is stored on our secure servers. 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. 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.
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: DigitalOcean LLC, 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 might 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights and Request erasure below for further information.
In some circumstances we may 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
You can exercise any of these rights at any time by contacting us at [email protected]
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES None
EXTERNAL THIRD PARTIES
Service providers acting as processors based in the 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 the 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.
DigitalOcean LLC, 101 6th Avenue, New York, NY (https://www.digitalocean.com/legal/), we use their servers in EEA.
Amazon Web Services Inc. (AWS), P.O.Box 81226, Seattle, WA 98108-1226, USA (http://aws.amazon.com/), we use their servers in EEA.
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94042, USA (http://www.google.com/policies/privacy/partners/), we use their servers in EEA, including Firebase.
The Rocket Science Group LLC (Mailchimp), 675 Ponce de Leon Ave, NE Suite 5000, Atlanta, GA 30308, USA (https://mailchimp.com/legal/privacy/), we use them for marketing and newsletter distribution purposes.
Laravel LLC, P.O. Box 196, Cramerton, North Carolina, 28032, USA.
Stripe, 510 Townsend Street, San Francisco, CA 94103, USA, (https://stripe.com/gb/privacy) we use for payment integration.
Veriff OÜ, registry code 12932944, registered address at Niine 11, 10414 Tallinn, Estonia (https://www.veriff.com/privacy-policy) we use them to perform Know Your Customer checks when needed.
This Privacy Notice will be subject to regular review and may change from time to time. The current